A fixed-scope review that tells you, before you file, where your business sits under PVARA’s licence categories, what the No-Objection Certificate and licence applications will test, and what has to change for them to succeed.
Why assess before you apply
Under the Pakistan Virtual Asset Services Regulations, 2026, PVARA’s 60-day NOC period and 90-day licence period run only from its written confirmation that an application is complete. Elapsed time is therefore decided mostly by the applicant: how quickly the file is complete, and whether the business has been mapped to the right categories at the outset. Applications that arrive with the wrong categories, an unsettled Pakistani operating model, or gaps in the fit-and-proper material lose months in information requests. The assessment is designed to find those problems first.
Who it is for
- Global exchanges, custodians and broker-dealers serving, or intending to serve, users in Pakistan.
- Stablecoin and asset-referenced token issuers, and payments and remittance operators using virtual asset rails.
- Groups already licensed elsewhere (VARA, MAS, MiCA or comparable) that need to know what a Pakistani licence will require on its own terms.
- Applicants that already hold an NOC and need to be licence-ready within its validity period.
What you receive
- Activity-to-category mapping. Each of your products and services mapped against the eleven licence categories in Schedule I, with the minimum paid-up capital that applies to each category you need.
- Pakistan exposure analysis. Whether your current or planned activity is carried on in Pakistan under Regulation 3(4), and whether the Regulation 3(5) position for merely accessible platforms is available to you in the meantime.
- Ownership, governance and fit-and-proper gaps. Beneficial ownership chain, proposed directors, and the Pakistan-resident key individual required by Regulation 10(4), with the gaps PVARA is likely to raise.
- Form I readiness review. The documents the NOC and licence applications require, each marked ready, needs work, or missing.
- Sequenced action plan. NOC, incorporation and FMU registration, then the licence application, with owners, dependencies, and an assessment of whether the Regulatory Sandbox is the better route for any product.
- Partner review call. A session with Safi Ghauri to take your team through the findings and the decisions they require.
What we need from you
- Group structure chart and ultimate beneficial ownership.
- A description of each product and service, target users, and current Pakistan-facing activity (marketing, onboarding, PKR rails).
- Licences held in other jurisdictions and their scope.
- Your proposed Pakistani operating model: entity, directors, key individual, custody model and outsourcing.
- Your current AML/CFT and compliance policies.
What it does not include
Preparing and filing the NOC or licence application, incorporating the Pakistani company, drafting policies and procedures, and SECP or State Bank of Pakistan opinions are separate engagements. We scope them once the assessment shows what your application needs. The delivery timetable is agreed when we confirm the scope of the assessment.
Who leads it
The assessment is led by Safi Ghauri, Barrister and Managing Partner of Esquare Legal and a Partner of Tahota Law Firm, who has obtained a VARA licence for a UAE digital asset platform. He is supported by Esquare Legal’s team of Pakistan-licensed associates working from Islamabad and Karachi.
For the regulatory background, read our PVARA licensing guide and our 29-point submission to PVARA on the draft Regulations.
This page describes a legal service offered by Esquare Legal. It is not legal advice, and no outcome of any PVARA application is promised or implied. References to the Regulations are to the Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026).