A decision by the Pakistan Virtual Asset Regulatory Authority is not the end of the road. A virtual asset service provider, Licensee, or other affected person has a defined route to challenge it — but that route runs on a tight clock and lands in a forum built to act like a civil court.
This article walks through how an appeal to the Virtual Assets Appellate Tribunal actually works: the filing window, what the Tribunal must decide by when, and the powers it exercises once your case is in front of it.
How much time do you have to appeal a PVARA order?
Thirty days. Section 63 of the Virtual Assets Act 2026 gives any virtual asset service provider, Licensee, or other Person aggrieved by an order of the Authority the right to appeal to the Virtual Assets Appellate Tribunal within thirty days of the date on which the order was communicated to them, in accordance with the prescribed Rules.
Section 64(1) repeats the thirty-day window when it sets out the mechanics of filing the appeal itself, describing it as thirty days “from the date of such order.”
“Any Virtual Asset Service Provider, Licensee, or any other Person aggrieved by an order of the Authority may prefer an appeal before the Virtual Assets Appellate Tribunal within thirty days of the date on which the order was communicated, in accordance with the Prescribed Rules.” — section 63
Our reading is that these two clocks are intended to run from the same point — the point the order reaches the affected person — but the Act uses slightly different language in the two sections (“date… communicated” in section 63, “date of such order” in section 64(1)). This is worth flagging rather than glossing over: where the two dates could genuinely differ, the more conservative reading is to calendar thirty days from whichever date is earlier.
What must an appeal to the Tribunal contain?
Section 64(1) requires the appeal to be filed “in such form, contain such particulars, and be accompanied by such documents and fees as may be prescribed under this Act.” The Act sets the deadline and leaves the format to Rules that are not reproduced in the source documents reviewed here.
Practically, this means an appellant needs to confirm the current prescribed form, the specific particulars required, and the applicable fee before filing — the Act’s own text does not specify any of these beyond the thirty-day deadline itself.
How long does the Tribunal have to decide an appeal?
Not later than three months from the date the appeal is presented to it. Section 64(2) requires the Tribunal to decide an appeal “expeditiously but not later than three months of its presentation to the Tribunal.”
The Act does not set out a consequence if the Tribunal misses this deadline — no provision in section 64 states what happens to an appeal, or to the underlying PVARA order, if the three-month period lapses without a decision. In our reading, the deadline functions as a statutory expectation for the Tribunal rather than a mechanism that automatically resolves the appeal one way or the other, but the Act does not say so directly.
What powers does the Tribunal have when deciding an appeal?
For the purpose of deciding an appeal, the Tribunal is deemed to be a civil court, with the same powers vested in such a court under the Code of Civil Procedure, 1908. Section 64(3) lists three of those powers specifically:
- Enforcing the attendance of any person and examining that person on oath
- Compelling the production of documents
- Issuing commissions for the examination of witnesses and documents
This matters for anyone preparing an appeal: the Tribunal is not limited to reviewing PVARA’s paper file. It can summon witnesses, compel production of documents that were not before the Authority, and take formal evidence — the same toolkit a civil court would use to build a factual record.
What standard of proof applies in the Tribunal?
The civil standard, applied summarily. Section 64(4) provides that it is sufficient for the Tribunal to establish, or to be satisfied as to, any matter “on the standard of proof applicable to civil proceedings in a summary manner in a court of law.”
This is a lower bar than the criminal standard used for offences prosecuted under Chapter 10 of the Act. An appellant should not expect the Tribunal to require proof beyond reasonable doubt on any factual question — the civil, balance-of-probabilities standard governs, and the Tribunal is entitled to reach its conclusions through a summary process rather than a full civil trial.
What legal weight does a Tribunal decision carry?
The same weight as a civil court decree. Section 64(5) states that the Tribunal’s determinations or decisions under the Act “shall be deemed to be the decrees of a civil court under the Code of Civil Procedure, 1908.”
| Feature | Position under section 64 |
|---|---|
| Filing deadline | 30 days from the order (see the note on wording above) |
| Decision deadline | Not later than 3 months from presentation |
| Standard of proof | Civil standard, applied summarily |
| Legal status of the decision | Deemed a decree of a civil court under the CPC 1908 |
That status matters practically: a civil court decree is directly enforceable through the ordinary machinery for enforcing decrees, rather than requiring a fresh proceeding to give it legal force. A losing party at the Tribunal faces a decision with the same enforceability as if a civil court had made it.
Where does an appeal go if you lose at the Tribunal?
The Tribunal is not the final word. A separate right of appeal to the Supreme Court of Pakistan exists under section 65 of the Act, on its own thirty-day timeline — a route this analysis does not cover in detail here.
Does filing an appeal pause the order being challenged?
Sections 63 and 64 do not say so. Neither provision states that lodging an appeal automatically suspends or stays the underlying order of the Authority while the Tribunal considers the case. This is a genuine silence in the Act’s text, not an oversight on our part in reading it: an appellant should not assume that a suspended licence, a frozen approval, or a fine remains inactive purely because an appeal has been filed within the thirty-day window.
In practice, this means the safer working assumption is that a PVARA order continues to have effect unless the Tribunal, or the Authority itself, grants some form of interim relief — and the Act’s own text, at least in sections 63 and 64, does not describe a mechanism for seeking that relief. Anyone weighing whether to appeal an order that affects day-to-day operations, such as a suspension under section 23, should treat this as an open question to raise directly with the Tribunal or with PVARA, rather than something the Act resolves on its face.
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
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 sections 63 and 64(1) through 64(5) — read as published. Where the Act’s wording differs between sections on the same point, or is silent on a consequence, 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.
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