Service overview
Custody Services involve holding or controlling client virtual assets or relevant keys and demand specialised safeguarding.
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 Custody Services Licence?
A prospective custodian must meet the licensing category's custody security, governance, technology, segregation and resilience requirements. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 200,000,000. Under the published framework the VASP applicant company must have at least three directors, with applicable independent-director and fit-and-proper controls.
Custodians must demonstrate safe control of private keys, segregated customer assets, incident response and the higher Schedule I custody capital. A wallet development vendor is not necessarily a licensable custodian.
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 Custody Services Licence
Prepare the following information for virtual asset custody services licence. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.
- Custody technology and key management
- Wallet architecture
- Insurance/risk policies
- Beneficial ownership
- AML controls
- Incident response and reconciliation plan.
- Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
How can I obtain Virtual Asset Custody Services Licence in Pakistan?
- 01Define who controls client private keys
Document custodial wallets, signing permissions, asset segregation and responsibility for client loss.
- 02Arrange PVARA NOC and licensed corporate vehicle
Prepare owners, minimum paid-up capital, directors and safeguarding/technology architecture.
- 03Submit Custody Services licence application
Demonstrate key management, cyber audit, segregation, reconciliation, incident recovery and insurance/risk programmes as required.
- 04Operate controlled custody after licensing
Maintain client asset reporting, security testing and incident escalation.
Regulator resource: PVARA published 2026 licensing tracks
After registration or approval
Maintain segregation, reconciliation, incident reporting, independent controls and client asset protection.
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 Custody Services Licence
Who is eligible for Virtual Asset Custody Services Licence in Pakistan?
A prospective custodian must meet the licensing category's custody security, governance, technology, segregation and resilience requirements. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 200,000,000. 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 Custody Services Licence?
Custody technology and key management; Wallet architecture; Insurance/risk policies; Beneficial ownership. Additional requirements can apply to the actual business or regulator.
How can I obtain Virtual Asset Custody Services Licence in Pakistan?
Define who controls client private keys: Document custodial wallets, signing permissions, asset segregation and responsibility for client loss. Arrange PVARA NOC and licensed corporate vehicle: Prepare owners, minimum paid-up capital, directors and safeguarding/technology architecture. Submit Custody Services licence application: Demonstrate key management, cyber audit, segregation, reconciliation, incident recovery and insurance/risk programmes as required. Operate controlled custody after licensing: Maintain client asset reporting, security testing and incident escalation.
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.