How PVARA Staffs Itself: Posts, Hiring and Secondments

A regulator is only as capable as the people inside it. Section 13 of the Virtual Assets Act 2026 is the provision that lets the Pakistan Virtual Assets Regulatory Authority (PVARA) build its own workforce — creating posts, hiring staff and consultants, and pulling in expertise from elsewhere in government on secondment.

This matters to anyone dealing with PVARA for a practical reason: a young regulator staffing up under section 13 will, for some period, be reviewing applications with a mix of permanent officers, newly hired specialists and seconded officials from other agencies. Understanding how that workforce is assembled helps explain why review capacity, response times and institutional memory can vary while the Authority is still building out its teams.

What does section 13 of the Act actually say?

Section 13, titled “Appointment of Officers, Staff, Consultants, Advisors and other personnel,” gives PVARA three distinct staffing powers. It may create and sanction posts, hire staff and advisers through a competitive process, and request officials on secondment from other government bodies. All three routes are exercised through Regulations made by the Authority, not through ad hoc decisions.

This is separate from the appointment of the Chairperson under section 11 and the Managing Director under section 12, both of which follow their own dedicated procedures. Section 13 covers everyone below that top layer — officers, employees, consultants and technical advisers.

How does PVARA create and structure new posts?

Under section 13(1), “the Authority may, from time to time, create and sanction such posts, prescribe required qualifications and experience, and determine terms of service through Regulations as required.” This is the foundational power — before PVARA can hire anyone into a role, that role has to exist as a sanctioned post, with qualifications and terms of service fixed in advance by Regulations.

In practice, this means PVARA’s organisational structure is not fixed by the Act itself. The Act does not list PVARA’s departments, divisions or job titles — Chapter 3’s licensing framework and Chapter 8’s anti-money laundering (AML) provisions describe what needs to be done, but who inside PVARA does it is left to section 13(1) Regulations, which the Authority can revise as its workload changes. A VASP going through the licensing framework should not assume the reviewing division or the named contact point is fixed indefinitely.

How does PVARA actually hire people?

Section 13(2) requires that hiring happen “through a transparent and competitive process prescribed by Regulations.” The Authority may “appoint such employees, officers, consultants, and technical or professional advisers as are necessary for the performance of its functions and the exercise of its powers under this Act.”

Two things stand out in this text. First, the word “transparent” is doing real work — it is a statutory constraint on how hiring is conducted, not just an aspiration. Second, the category of people covered is broad: employees and officers on one hand, consultants and technical or professional advisers on the other. This lets PVARA bring in specialist expertise — cybersecurity, blockchain forensics, AML — without necessarily converting every specialist into a permanent employee. Given the technical depth required to assess custody arrangements or derivatives products, the consultant and adviser route is likely to be used heavily in the Authority’s early years.

The Act does not itself prescribe what “transparent and competitive” means in operational terms — job postings, minimum notice periods, panel composition and so on. Those details sit in Regulations that had not been separately reviewed for this analysis. If a specific hiring process becomes relevant to a matter you are dealing with, verify the current Regulations directly with PVARA.

Can PVARA borrow staff from other regulators?

Yes. Section 13(3) gives PVARA a secondment power: “The Authority may, as prescribed by Regulations, request any Ministry, Division, public authority, public entity or autonomous or regulatory body to assign an official with requisite expertise to the Authority for such period as may be mutually agreed.”

“The Authority may, as prescribed by Regulations, request any Ministry, Division, public authority, public entity or autonomous or regulatory body to assign an official with requisite expertise to the Authority for such period as may be mutually agreed.”

This is a meaningful power for a new regulator. Rather than building every specialism from scratch, PVARA can pull in an experienced official from the State Bank of Pakistan, the Securities and Exchange Commission of Pakistan (SECP), the Financial Monitoring Unit (FMU), or another body — both of which already sit on the Authority’s own governing board under section 7(1) — for a mutually agreed period. It also explains why PVARA’s supervisory approach in its first years may echo the practices of the agency an individual seconded official came from, particularly on AML matters where the FMU’s own institutional experience under the Anti-Money Laundering Act, 2010 is directly relevant.

The section is silent on how many secondments PVARA may run at once, or how long “such period as may be mutually agreed” typically runs. Those are matters of negotiation between PVARA and the lending body, not fixed statutory limits.

Who sits above section 13 staff — the Chairperson and Managing Director?

Section 13 staffing sits underneath two separately appointed leadership roles. Under section 11, the Chairperson is appointed by the Federal Government, must have demonstrable expertise in digital finance or technology and at least three years’ relevant professional experience, and is eligible for reappointment for a maximum of two further terms. Under section 12, the Authority itself appoints a Managing Director for a three-year term, extendable for a further maximum of two three-year terms, who must be “a person of proven integrity and competence” meeting further qualifications prescribed by Regulations, and who acts as Secretary of the Authority’s proceedings without a vote unless specifically authorised.

Section 10 of the Act adds a further layer: “The Authority may delegate any of its powers and functions to the Managing Director, subject to such terms, conditions, and limitations as it may deem appropriate.” In practice, this means the Managing Director is likely to be the operational point of contact for much of PVARA’s day-to-day supervisory work, even though the Authority as a body — chaired by the Chairperson and including the Secretary of Finance, the Secretary of Law and Justice, the Governor of the State Bank, the SECP Chairperson, the National AML-CFT Authority Chairman, the Pakistan Digital Authority Chairperson, and two independent directors under section 7(1) — retains ultimate policy and strategic direction under section 7(3).

What does this mean for a company applying to PVARA?

The practical takeaway is that PVARA’s institutional capacity is being built in real time, through three parallel channels: permanent posts sanctioned under section 13(1), competitively hired staff and consultants under section 13(2), and seconded officials from other regulators under section 13(3). An applicant preparing an NOC application or planning a market entry into Pakistan should expect review teams, contact points and even areas of specialist focus to evolve as staffing matures, rather than treating the Authority’s current structure as permanent.

This also has a bearing on timelines. A regulator relying partly on secondments and newly hired consultants under section 13 may take longer to build sustained institutional review capacity than one with a fully staffed permanent bench — a factor worth weighing when planning your own corporate setup and licensing timeline, alongside the fit and proper and capital requirement work you will be doing on your own side.

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act 2026 as passed by the National Assembly — principally section 13, and its cross-references to sections 7, 10, 11 and 12 — 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.