Service overview
Virtual-asset advice involves recommendations on virtual assets and may require PVARA's Advisory Services category.
PVARA differentiates the initial NOC, incorporation in Pakistan, and final licensing for one or more authorised services. An NOC is not an operating licence, and each chosen licence class has its own safeguarding, capital, competence and activity rules.
Who is eligible for Virtual Asset Advisory Services Licence?
Applicants must satisfy VASP licensing, personnel competence, fitness, conflict management and any class-specific capital provisions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 15,000,000. Under the published framework the VASP applicant company must have at least three directors, with applicable independent-director and fit-and-proper controls.
Applicants must meet Schedule I paid-up capital, Pakistani company, directors and fit-and-proper requirements for advisory services, including professional competence and management of client conflicts.
For VASP licences, paid-up capital, eligible company form, director qualifications and actual regulated activity must be tested separately for the chosen licence class. A PVARA NOC does not grant permission to operate.
Documents and information for Virtual Asset Advisory Services Licence
Prepare the following information for virtual asset advisory services licence. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.
- Advisory business plan
- Responsible persons and qualifications
- Ownership
- Conflicts and suitability framework
- AML/CFT and consumer communication policies.
- Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
How can I obtain Virtual Asset Advisory Services Licence in Pakistan? — step-by-step guide
- 01Identify the appropriate application route and eligibility
First determine whether the proposed applicant and activity fall within this procedure. Applicants must satisfy VASP licensing, personnel competence, fitness, conflict management and any class-specific capital provisions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 15,000,000. Under the published framework the VASP applicant company must have at least three directors, with applicable independent-director and fit-and-proper controls. Review the separate conditions and exclusions in the eligibility section before submitting any form or payment.
- 02Prepare the application documents and evidence
Start with the particulars listed for this service: Advisory business plan; Responsible persons and qualifications; Ownership; Conflicts and suitability framework; AML/CFT and consumer communication policies.; Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category. Ensure the names, applicant identity and documents are consistent. The authority may require further supporting material under its current checklist.
- 03Check the current regulator instructions before filing
Refer to the regulator resource identified on this page (PVARA published 2026 licensing tracks ↗). Reconfirm the currently prescribed forms, online or physical submission method, supporting evidence, fee and any current amendments. Do not assume that historic processing times or fees remain applicable.
- 04Define virtual-asset advice offered to clients
Identify whether proposed recommendations fall under PVARA Advisory Services and draft suitability/conflict safeguards.
- 05Prepare NOC and admissible applicant status
Complete promoter fitness, prescribed capital and local incorporation process under PVARA's NOC-to-licence route.
- 06Seek Advisory Services licence
Submit class-specific adviser competence, systems, customer disclosure and market conduct materials to PVARA.
- 07Implement authorised advice controls
Maintain suitability, conflicts, AML/CFT and recordkeeping after licensing.
- 08Keep the approval record and track ongoing obligations
After the authority has made its decision, retain the acknowledgement, correspondence, evidence of approval and any conditions attached to it. Maintain suitability and disclosure controls, records of recommendations and regulator reports. Check whether separate approvals, renewals or reporting duties apply to the actual business.
Use the current regulator checklist to confirm that every listed item is still required and that any activity-specific conditions have been met. The items below are drawn from the document requirements identified on this page, not a representation that the checklist is exhaustive.
- Advisory business plan
- Responsible persons and qualifications
- Ownership
- Conflicts and suitability framework
- AML/CFT and consumer communication policies.
- Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
Before signing or paying, reconcile the particulars across Advisory business plan and Responsible persons and qualifications; check the applicant and business classification, identify the person authorised to submit, and retain a copy of the final application and official correspondence. Official instructions control if the portal or law has changed.
Regulator resource: PVARA published 2026 licensing tracks
After registration or approval
Maintain suitability and disclosure controls, records of recommendations and regulator reports.
Virtual asset advice: distinguish recommendations from dealing and portfolio management
Primary-source research. The following procedural analysis is based on the identified government or regulator sources. Confirm enacted amendments, applicable forms, fees and filing requirements on the date of submission. A consultation draft is not operative law merely because it has been published. This note does not represent final legal-editor certification of the entire guide.
The approved advice perimeter
PVARA's Schedule I identifies Advisory Services as advising on virtual assets, portfolio composition and the merits of particular assets. It is legally different from receiving customer orders, acting as broker-dealer, managing discretionary assets or controlling wallet keys. Examine whether the platform gives personalised recommendations and whether execution or investment discretion also arises.
Category-specific capital
PVARA's notified Services Regulations, 2026 Schedule I lists PKR 15 million minimum paid-up capital for Advisory Services. The applicant must be a Pakistani incorporated company with at least three directors under the published licensing criteria; verify capital and any updated conditions from the effective rules before funding or filing. Lower capital for advice does not permit custody or exchange business.
Evidence of competent advisory controls
Prepare proposed investment/adviser personnel, qualifications and competence, advice methodology, conflicts, client suitability procedures, risk warnings, research audit trail, remuneration and referral arrangements. Identify whether advice concerns a regulated token, security or another product also requiring assessment by a different regulator.
NOC and final approval
Follow the Services Regulations' current Form I NOC and licence route, or authorised sandbox exit, and submit category-specific documentation under the Activity Specific Regulations. Maintain AML/CFT screening, client records, governance, reporting and complaint handling after grant. Publication of market commentary must not be marketed as proof of an advisory licence.
Official legal and regulatory sources
Governing law & official references
Virtual Assets Act, 2026; Pakistan Virtual Asset Services Regulations, 2026; and Pakistan Virtual Asset Services Activity Specific Regulations, 2026.
The links below lead to government or official regulatory sources relevant to this service. Use the currently consolidated Act, regulations, statutory checklist and official portal when making an application.
How Chambers can assist
Chambers can review the legal route, identify regulatory constraints, prepare or review the supporting corporate and legal documents, manage the prescribed submission and correspond with the competent authority where instructed. The scope of the engagement will be determined by the applicant’s particular circumstances.
For an initial enquiry, identify the proposed activity, applicant entity and current stage, and provide the available documents indicated above. Please avoid sending confidential or identity-sensitive records through an unencrypted first contact.
Common questions about Virtual Asset Advisory Services Licence
Who is eligible for Virtual Asset Advisory Services Licence in Pakistan?
Applicants must satisfy VASP licensing, personnel competence, fitness, conflict management and any class-specific capital provisions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 15,000,000. Under the published framework the VASP applicant company must have at least three directors, with applicable independent-director and fit-and-proper controls.
What documents are needed for Virtual Asset Advisory Services Licence?
Advisory business plan; Responsible persons and qualifications; Ownership; Conflicts and suitability framework. Additional requirements can apply to the actual business or regulator.
How can I obtain Virtual Asset Advisory Services Licence in Pakistan?
Define virtual-asset advice offered to clients: Identify whether proposed recommendations fall under PVARA Advisory Services and draft suitability/conflict safeguards. Prepare NOC and admissible applicant status: Complete promoter fitness, prescribed capital and local incorporation process under PVARA's NOC-to-licence route. Seek Advisory Services licence: Submit class-specific adviser competence, systems, customer disclosure and market conduct materials to PVARA. Implement authorised advice controls: Maintain suitability, conflicts, AML/CFT and recordkeeping after licensing.
This guide is general information, not advice on your facts. Check the applicable law, notifications, updated regulator checklists and jurisdiction before acting. The authority alone determines eligibility, acceptance and approval; no outcome or processing period is guaranteed.