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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
01

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.

02

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.

03

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
04

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

  1. 01
    Design virtual-asset loan and collateral products

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

  2. 02
    Prepare NOC, ownership and capital evidence

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

  3. 03
    Apply for Lending and Borrowing Services licence

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

  4. 04
    Operate only within permitted credit arrangements

    Monitor collateral ratios, losses, disclosure and regulatory reports.

Regulator resource: PVARA published 2026 licensing tracks

05

After registration or approval

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

07

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.