The governing distinction
Ordinarily, no. Section 70(1) of the Virtual Assets Act, 2026 required a person already providing Virtual Asset Services immediately before the Act commenced to apply within six months or cease providing those services. PVARA identifies 5 September 2026 as the relevant deadline for transitional NOC applications. A late filing does not automatically restore the right to operate.
When continuation was possible
Regulation 5A(2) of the Pakistan Virtual Asset Services Regulations, 2026 addresses a qualifying existing provider that submitted a complete application meeting the NOC requirements within the period. Such a provider may continue its existing services while the application is determined, provided it complies with interim directions and the Act's customer-protection and AML/CFT/CPF obligations. It must seek prior approval for marketing during that period. PVARA may impose proportionate restrictions on onboarding, products, transaction volumes or custody.
Why a later NOC is not enough
Regulation 6(4) expressly provides that an NOC is not a licence to provide Virtual Asset Services. It is therefore unsafe to treat a late NOC application, an acknowledgement, a bank account or the incorporation of a Pakistani company as a retrospective operating permission. An ordinary NOC-to-licence route remains distinct from the transitional continuation provision.
What the operator should do
Identify the person who actually operated before commencement, obtain the complete submission history and all PVARA correspondence, and establish which services were supplied before and after the deadline. If the qualifying filing was not made, management should address cessation, safeguarding and return of customer assets, record preservation and a truthful request for regulatory directions. It should not market new services or onboard customers on an assumed exemption. The precise legal response depends on the written instruments and the facts.
Further reading
For the full statutory analysis, see PVARA Transitional Arrangements in 2026 and the related NOC-to-licence study.