Can You Advertise Crypto in Pakistan? Section 43 Explained

A crypto marketing campaign in Pakistan can be unlawful even if the person running it never touches a customer’s money. Section 43 of the Virtual Assets Act, 2026 conditions the right to advertise on the licensing status of the issuer behind the asset — not the licensing status of the marketer placing the advertisement. That distinction changes who carries the risk, and it is worth understanding before any campaign, sponsorship or influencer deal touching a virtual asset goes live.

Can anyone advertise a virtual asset in Pakistan?

Only where the issuer is licensed or registered. Section 43(1) states:

“No person shall advertise or market a Virtual Asset unless the Issuer holds a valid license or registration under this Act.”

Read that condition carefully: it is not framed as “no unlicensed person shall advertise.” It is framed around whether the Issuer holds a valid licence or registration. On its wording, the prohibition falls on “no person” — meaning any person who advertises or markets a virtual asset tied to an unlicensed issuer is potentially caught, whether that person is the issuer itself, a marketing agency, a media platform running the advert, or an individual influencer promoting the token to followers.

What counts as “advertising or marketing” under section 43?

The Act does not define either term for the purposes of this section, and no Regulations narrowing the scope had been issued in the material reviewed here. Section 43(2) gives a partial sense of the intended reach by regulating the content of marketing materials rather than defining the activity itself:

“All marketing materials shall contain risk disclosures and shall comply with such conditions, standards and limitations, in such form and manner, as may be prescribed by the Authority.”

“Marketing materials” implies a reasonably broad category — likely to cover paid advertisements, sponsored social media content, promotional emails, and website copy, though the Act’s text does not itemise formats. Our reading is that anything designed to induce a person to acquire or trade a virtual asset is intended to fall within scope, but until PVARA issues the “form and manner” Regulations under section 43(2), a marketer cannot point to a definitive boundary and should treat the provision as broad rather than narrow.

Who can be penalised — the issuer, the platform, or the marketer?

Section 43(1) itself does not carry its own penalty clause, so exposure runs through the Act’s general prohibition and enforcement provisions. Section 50(1) prohibits any person from engaging in a Virtual Asset Service by way of business without being an incorporated company holding a valid licence. Advertising is arguably closer to a marketing activity than a Virtual Asset Service in its own right, but where the advertised offering is itself an unlicensed Initial Virtual Asset Offering, section 51’s prohibition and section 54(2)’s penalty — up to three years’ imprisonment, a fine of up to twenty-five million rupees, or both — apply directly to the offering, and the marketing of it sits alongside that exposure.

More generally, section 59(1) allows PVARA to impose administrative sanctions — a written reprimand or public censure, a directive to cease or remedy conduct, a financial penalty up to the prescribed maximum, or suspension or revocation of a licence — on “a Person” found to have contravened the Act. Because section 43(1)’s prohibition is addressed to “no person,” an agency, platform, or individual promoter is a plausible target for that sanctions power, not only the issuer. Given the breadth of that wording, anyone running a paid crypto marketing campaign in Pakistan is taking on personal exposure tied to the licensing status of an issuer they may not control or fully vet.

Can PVARA get an advertisement taken down?

Yes, and its power here is unusually direct. Section 61(1) allows the Authority to “remove, block, or direct the removal or blocking of any online material (e.g., websites, apps, ads, payment links) if, on reasonable grounds, it promotes, operates, or relates to an unlicensed Virtual Asset Service or contravenes this Act, its Rules, or Regulations.” Section 61(2) extends that power to directions issued to “telecommunication authorities, Virtual Asset Service Providers, intermediaries, hosting providers, app stores, search engines, advertising networks, registrars, payment providers, or any person facilitating such material” — a list that reaches advertising networks by name.

Section 61(3) requires such orders to be in writing, stating reasons and the statutory basis, and communicated to the affected person. Section 61(5) gives a person aggrieved by such an order ten days to submit a representation, with the Authority required to respond in writing within fifteen days. So there is a due-process route attached to any takedown, but the underlying power to act first and hear representations after is real and reaches advertising networks directly, not only the advertiser.

How does section 43 interact with the whitepaper and disclosure regime?

Section 43 does not operate in isolation. An issuer that has not yet published its whitepaper under section 42(1), or has not obtained the licence or registration section 43(1) requires, cannot lawfully be advertised at all, regardless of how compliant the advertisement’s content might otherwise be. Section 42(4) requires PVARA to prescribe “mandatory risk disclosures, periodic reporting requirements and disclosure templates applicable to Issuers and Licensees,” which will likely feed directly into the “form and manner” of the risk disclosures section 43(2) requires marketing materials to contain. A marketer relying on an issuer’s own compliance claims should ask specifically whether the issuer holds a licence or registration under the Act — not merely whether it “operates legally” in a general sense — since section 43(1)’s test is that narrow and that literal.

What should marketers and influencers do before running a crypto campaign in Pakistan?

Four practical steps:

• Confirm the issuer’s licence or registration status directly with PVARA, using the public register PVARA is required to maintain and publish under section 21(4), rather than relying on the issuer’s own representation.
• Do not assume an exchange listing or a token’s general market presence substitutes for a Pakistan-specific licence. Section 43(1)’s test is whether the Issuer holds a valid licence or registration under this Act — a foreign listing does not satisfy it.
• Build risk disclosures into every piece of marketing material as standard, anticipating that section 43(2)’s prescribed conditions will require them, rather than adding them only once PVARA’s form and manner Regulations are published.
• Treat sponsorship and influencer arrangements as carrying the same exposure as a paid advertisement, since section 43(1)’s “no person” wording does not appear to distinguish between a formal ad buy and an individual promotional post.

Anyone planning a market entry into Pakistan that depends on visible marketing — exchange launches, token campaigns, KOL partnerships — should sequence the marketing plan behind the licensing timeline, not alongside it. A campaign that runs ahead of the issuer’s licence is not a compliance risk sitting only with the issuer; on the wording of section 43(1), it is a risk sitting with everyone who places the advertisement.

Related reading

• PVARA Exchange License: Capital, Rules & Obligations 2026
• PVARA Transfer & Settlement License: Crypto Payments 2026
• PVARA Licensing Process: NOC to Full Licence, Step by Step
• The PVARA Licensing Gold Rush: Pakistan’s Crypto Frontier
• PVARA Custody License: Safeguard Customer Crypto 2026
• goAML Registration for VASPs: Who Registers, and When

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026 as passed by the National Assembly, read as published. Where practice is not yet settled or guidance has not been issued, that is stated in the text above.

Regulatory positions change and specific requirements should be verified against the current position published by the relevant authority before you act on them. This is information and analysis, not legal advice, and it does not create an advisory relationship. Take professional advice on your own circumstances.