The short legal position
No. Under Regulation 6(4) of the Pakistan Virtual Asset Services Regulations, 2026, an NOC is not a licence to carry on Virtual Asset Services. A founder who has obtained preliminary approval should not describe the business as fully licensed or begin offering an exchange, custody or brokerage service merely on that basis. The activity and the authorisation expressly granted must be examined separately.
What the NOC does
The NOC is part of an application route. It allows the applicant to advance the steps contemplated by the licensing framework, including establishing the Pakistani corporate structure and preparing the full application. Its issue is not a final determination that the proposed systems, governance, capital and customer safeguards satisfy every licence condition. The regulator may require more information and will assess the full application independently.
How long the process can take
The published Services Regulations provide a decision period for a complete NOC application and a separate period for a complete full licence application. The NOC has a limited validity period and a possible extension if the regulatory conditions are met. These periods cannot safely be calculated from an incomplete filing. Keep the dated application, written acknowledgment of completeness, further-information requests and the NOC itself.
What counts as operating
Customer onboarding, receiving orders, executing transactions, holding keys, maintaining client balances and publicly offering regulated services may engage different licence categories. A commercial platform can conduct more than one regulated service even if the interface is described as a single product. The business should examine contracts, product flows and representations to determine whether it has crossed from technical preparation into regulated activity.
What to do before launch
Prepare an activity map, confirm the appropriate categories under Schedule I, document the entity and controller structure, satisfy the applicable financial and governance conditions and obtain the specific full licence. Regulatory sandbox participation may provide a distinct path, but controlled testing is subject to its own restrictions and is not open-ended commercial permission. Seek clarification where a proposed feature goes beyond the approved scope.
Bank account does not equal licence
SBP's Circular Letter No. 10 of 2026 permits limited-purpose banking for certain NOC holders to complete licensing formalities. It separately describes arrangements for licensed VASPs. Opening an account at this stage is not evidence that exchange or custody operations have been authorised. Customer communications should accurately identify the entity's status and avoid suggesting a government endorsement of a particular token.
The evidence needed for a specific answer
The full NOC including conditions, PVARA correspondence, proposed service description, incorporation documents, platform screenshots, customer terms and all custody or settlement agreements should be reviewed. The applicable instrument is the final 2026 regulatory framework, not a historical NOC guidance document or informal statement. The precise answer for a particular launch depends on those records.
For a closely related legal analysis, read PVARA Licensing in Pakistan: From Preliminary NOC to a Full Virtual Asset Service Licence. The legal and factual position should be verified against the currently operative statutory instruments and the documents of the particular transaction.