Service overview
Management and investment services cover regulated discretionary or other management of virtual-asset investments.
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 Management and Investment Services Licence?
Evaluate regulated management scope, investor protection, mandate terms, competence, segregation and applicable capital 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.
Portfolio managers must have the eligible VASP vehicle and prescribed capital, personnel competence, custody independence and investor-protection policies. Mere virtual-asset advisory status does not confer discretion.
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 Management and Investment Services Licence
Prepare the following information for virtual asset management and investment services licence. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.
- Investment mandates
- Portfolio and valuation policies
- Ownership and management profiles
- Custodian arrangements
- Conflicts and AML/CFT programme.
- Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
How can I obtain Virtual Asset Management and Investment 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. Evaluate regulated management scope, investor protection, mandate terms, competence, segregation and applicable capital 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. 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: Investment mandates; Portfolio and valuation policies; Ownership and management profiles; Custodian arrangements; Conflicts and AML/CFT programme.; 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.
- 04Set out managed portfolios or investment products
Distinguish discretionary portfolio management from advice and exchanges; prepare investor mandate and valuation model.
- 05Apply for NOC and satisfy manager capital
Present owners, professional team, investor custody and source-of-funds framework.
- 06Submit Management and Investment Services licence
Provide investment policy, portfolio risk, third-party custody, valuation, conflicts and suitability controls.
- 07Manage only under approved mandates
Deliver statements, asset custody controls, disclosures and continuing regulator returns.
- 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 mandate limits, conflicts, performance reporting, custody and client disclosures. 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.
- Investment mandates
- Portfolio and valuation policies
- Ownership and management profiles
- Custodian arrangements
- Conflicts and AML/CFT programme.
- Evidence of subscribed and paid-up capital, with supporting attestation for the applicable PVARA licensing category
Before signing or paying, reconcile the particulars across Investment mandates and Portfolio and valuation policies; 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 mandate limits, conflicts, performance reporting, custody and client disclosures.
Discretionary virtual asset management: investment mandates and custody separation
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.
Discretionary management is not merely advice
PVARA's category covers managing virtual assets or client virtual-asset portfolios on a discretionary basis. The decisive questions include who decides transactions, can allocate customer holdings and controls wallet permissions. Pure recommendations may fall within the lower-capital advisory category, but executing investment discretion or operating a collective scheme raises different legal responsibilities.
Prudential category and other regulators
The Services Regulations list PKR 200 million minimum paid-up capital for Virtual Asset Management and Investment Services. Examine whether the structure also constitutes a securities fund, private fund or other regulated investment arrangement under SECP law; a PVARA licence should not be assumed to eliminate separate legally required authorisations.
Investor arrangements and operations
Prepare investment mandates, client risk categories, permitted assets and strategies, valuation, fee and performance methodology, custody arrangements, conflict restrictions, best-execution controls, client statements, risk monitoring and independent oversight. Document discretion granted by the actual client agreement rather than relying on vague trading power-of-attorney wording.
Ongoing obligations
Maintain investment decisions, trades, fees, portfolios, reconciliation, safeguarding, complaints, cyber incidents and AML/CFT records under PVARA's notified regulations and final licence conditions. Do not describe a sandbox participant or NOC holder as an approved investment manager before final licensing.
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 Management and Investment Services Licence
Who is eligible for Virtual Asset Management and Investment Services Licence in Pakistan?
Evaluate regulated management scope, investor protection, mandate terms, competence, segregation and applicable capital 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 Management and Investment Services Licence?
Investment mandates; Portfolio and valuation policies; Ownership and management profiles; Custodian arrangements. Additional requirements can apply to the actual business or regulator.
How can I obtain Virtual Asset Management and Investment Services Licence in Pakistan?
Set out managed portfolios or investment products: Distinguish discretionary portfolio management from advice and exchanges; prepare investor mandate and valuation model. Apply for NOC and satisfy manager capital: Present owners, professional team, investor custody and source-of-funds framework. Submit Management and Investment Services licence: Provide investment policy, portfolio risk, third-party custody, valuation, conflicts and suitability controls. Manage only under approved mandates: Deliver statements, asset custody controls, disclosures and continuing regulator returns.
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.