Esquare Legal · July 2026
In July 2026, Esquare Legal submitted a detailed response to the Pakistan Virtual Assets Regulatory Authority (PVARA) during the public consultation on the draft Pakistan Virtual Asset Services Regulations 2026 and its accompanying Activity-Specific Handbooks, issued under the Virtual Assets Act 2026.
Our submission sets out 14 recommendations sharpening the draft framework, covering stablecoin redemption and reserve standards, State Bank coordination on rupee-pegged tokens, a workable Travel Rule, market-abuse rules, custody and proof-of-reserves standards, minimum capital, and Shariah governance, among others, plus 15 further recommendations addressing gaps the draft leaves open, including insolvency protection for customer assets, a workable licensing transition, cross-border and reverse-solicitation rules, token listing due diligence, crypto marketing standards, tax treatment, and financial-sovereignty safeguards. A third section sets out clause-level drafting fixes to definitions, timelines, and application forms.
Throughout, our recommendations are benchmarked against the leading international regimes: the EU’s Markets in Crypto-Assets Regulation (MiCA), Dubai’s Virtual Assets Regulatory Authority (VARA), Singapore’s Monetary Authority (MAS), the Abu Dhabi Global Market (ADGM), the Hong Kong Securities and Futures Commission (SFC), the New York State Department of Financial Services (NYDFS), and FATF standards.
The full submission is available below for download.
Esquare Legal’s Submission to PVARA (PDF)
For our point-by-point commentary on all 29 recommendations, read our article: Strengthening Pakistan’s Virtual Asset Framework: Our 29 Recommendations to PVARA →
Esquare Legal advises exchanges, token issuers, custodians, banks and fintech businesses on virtual asset licensing, regulation and compliance in Pakistan, UAE, Europe, Hong Kong and LATAM. If you would like to understand how these rules affect you, we would be glad to help.