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Virtual Asset Lending and Borrowing Services Licence

Lending and borrowing of virtual assets is separately regulated from exchange or custody activity.

PAKISTAN BUSINESS REGISTRATION & LICENSING GUIDESDRAFT UPDATED 11 OCTOBER 2026PVARA
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Service overview

Lending and borrowing of virtual assets is separately regulated from exchange or custody activity.

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.

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Who is eligible for Virtual Asset Lending and Borrowing Services Licence?

Statutory eligibility

Eligibility involves business model, counterparty risk, collateral, asset safeguarding, disclosure and PVARA licence class conditions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 500,000,000. Under the published framework the VASP applicant company must have at least three directors, with applicable independent-director and fit-and-proper controls.

Conditions and exclusions for this application

Virtual asset lending/borrowing applicants must have the relevant Schedule I capital and professional risk management for collateral, maturity and liquidation. Not every unsecured loan arrangement is lawful under VASP permissions.

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.

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Documents and information for Virtual Asset Lending and Borrowing Services Licence

Prepare the following information for virtual asset lending and borrowing services licence. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.

  • Lending terms and collateral policy
  • Liquidity and risk model
  • Ownership and capital
  • AML controls
  • Custody arrangements
  • Client disclosures.
  • Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
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How can I obtain Virtual Asset Lending and Borrowing Services Licence in Pakistan? — step-by-step guide

  1. 01
    Identify the appropriate application route and eligibility

    First determine whether the proposed applicant and activity fall within this procedure. Eligibility involves business model, counterparty risk, collateral, asset safeguarding, disclosure and PVARA licence class conditions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 500,000,000. 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.

  2. 02
    Prepare the application documents and evidence

    Start with the particulars listed for this service: Lending terms and collateral policy; Liquidity and risk model; Ownership and capital; AML controls; Custody arrangements; Client disclosures.; and the remaining items in the documents section. Ensure the names, applicant identity and documents are consistent. The authority may require further supporting material under its current checklist.

  3. 03
    Check 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.

  4. 04
    Design virtual-asset loan and collateral products

    Define lending source, custody, margin/collateral, liquidation scenarios and borrower disclosures.

  5. 05
    Prepare NOC, ownership and capital evidence

    Meet class-specific PVARA paid-up capital and company/director fitness rules.

  6. 06
    Apply for Lending and Borrowing Services licence

    Present underwriting, collateral custody, liquidity, concentration and customer protection controls.

  7. 07
    Operate only within permitted credit arrangements

    Monitor collateral ratios, losses, disclosure and regulatory reports.

  8. 08
    Keep 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 prudential risk, collateral and liquidation controls, reporting and client disclosures. Check whether separate approvals, renewals or reporting duties apply to the actual business.

Before you submit: application file check

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.

  • Lending terms and collateral policy
  • Liquidity and risk model
  • Ownership and capital
  • AML controls
  • Custody arrangements
  • Client disclosures.
  • Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category

Before signing or paying, reconcile the particulars across Lending terms and collateral policy and Liquidity and risk model; 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

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After registration or approval

Maintain prudential risk, collateral and liquidation controls, reporting and client disclosures.

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Virtual asset lending and borrowing: client funds, collateral and liquidation controls

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.

Recognise the lending category

PVARA's Schedule I classifies facilitating virtual-asset lending or borrowing between clients or on the firm's own account as Lending and Borrowing Services. A platform arranging loans, using pooled customer assets or rehypothecating collateral should not assume an exchange or custody licence alone covers these functions. Identify borrower and lender, ownership of assets and legal exposure.

Licensing and financial requirements

The notified Services Regulations, 2026 list minimum paid-up capital of PKR 500 million for Lending and Borrowing Services. PVARA's published route requires an appropriate NOC followed by Pakistani incorporation and category-specific licensing, or an authorised sandbox completion route. Map additional custody, advisory and transfer functions to their own categories.

Loan terms and risk management

Design collateral valuation and custody, credit limits, liquidation and margin-call triggers, security rights, default/insolvency processes, interest or fee disclosures, customer consent and connected-party restrictions. Crypto-collateral volatility and liquidation can create losses even in transactions described as secured. Prepare rigorous technical architecture and audit trails addressing unauthorised asset reuse.

Continuing supervision

Establish market and counterparty exposure reporting, AML/CFT screening, protection of customer assets, customer complaints and risk committees. Approval of a NOC is not authority to accept public deposits or offer all financial products. Check whether fiat loans or banking functions create separate State Bank or SECP issues.

Official legal and regulatory sources

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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 Lending and Borrowing Services Licence

Who is eligible for Virtual Asset Lending and Borrowing Services Licence in Pakistan?

Eligibility involves business model, counterparty risk, collateral, asset safeguarding, disclosure and PVARA licence class conditions. For a licence in this category, Schedule I to the Pakistan Virtual Asset Services Regulations, 2026 prescribes minimum paid-up capital of PKR 500,000,000. 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 Lending and Borrowing Services Licence?

Lending terms and collateral policy; Liquidity and risk model; Ownership and capital; AML controls. Additional requirements can apply to the actual business or regulator.

How can I obtain Virtual Asset Lending and Borrowing Services Licence in Pakistan?

Design virtual-asset loan and collateral products: Define lending source, custody, margin/collateral, liquidation scenarios and borrower disclosures. Prepare NOC, ownership and capital evidence: Meet class-specific PVARA paid-up capital and company/director fitness rules. Apply for Lending and Borrowing Services licence: Present underwriting, collateral custody, liquidity, concentration and customer protection controls. Operate only within permitted credit arrangements: Monitor collateral ratios, losses, disclosure and regulatory reports.

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.