Initial Virtual Asset Offerings: Who May Conduct One in Pakistan?

Raising money by offering a token to the public looks, on its face, like something anyone with a whitepaper and a wallet address could attempt. Pakistan’s Virtual Assets Act, 2026 closes that gap directly: sections 30 and 51 together decide who is legally permitted to conduct an Initial Virtual Asset Offering, and what happens to anyone who does so without meeting the conditions.

What is an Initial Virtual Asset Offering under the Act?

Section 3(1)(xiv) defines an Initial Virtual Asset Offering as a method of raising funds by an Issuer through the public offering of Virtual Assets, in exchange for funds, other Virtual Assets, or anything of commercial value, subject to the limitations and disclosure requirements prescribed under the Act.

Section 3(1)(xiv) states an Initial Virtual Asset Offering means:

a method of raising funds by an Issuer through the public offering of Virtual Assets in exchange for funds or other Virtual Assets or anything of commercial value, subject to the limitations and disclosure requirements Prescribed under this Act.

Three features of this definition matter. First, it is expressly keyed to an Issuer — a Person who did not originate the asset and does not control its supply, reserves or governance under section 3(1)(xiii) is not conducting an Initial Virtual Asset Offering, whatever the marketing calls it. Second, the consideration accepted is drawn broadly: funds, other Virtual Assets, or “anything of commercial value” — a raise structured to accept payment in tokens rather than fiat currency does not escape the definition. Third, the offering is explicitly made subject to limitations and disclosure requirements the Act prescribes elsewhere, rather than being self-contained within this one definition.

Who is permitted to conduct an Initial Virtual Asset Offering?

Section 30(1) restricts eligibility to legal entities registered in Pakistan that also meet eligibility criteria prescribed by Regulations. Both conditions must be satisfied — Pakistani registration alone is not sufficient if Regulations impose additional eligibility criteria the entity does not meet.

Section 30(1) states:

Only legal entities, as registered in Pakistan and meeting the eligibility criteria prescribed by Regulations shall be permitted to conduct an Initial Virtual Asset Offering.

This is a narrower gate than the general licensing regime in several respects. Section 21(2) allows the Authority to grant a provisional or limited-scope licence to an applicant on a case-by-case basis, giving PVARA flexibility for ordinary virtual asset services. Section 30(1) does not carry that same flexibility language — it states plainly that only Pakistani-registered legal entities meeting prescribed criteria “shall be permitted”, which reads as a firmer precondition than a case-by-case discretion.

What does section 30(2) leave to Regulations?

Section 30(2) gives the Authority power to prescribe the conditions, disclosure requirements, approval processes and ongoing obligations applicable to Initial Virtual Asset Offerings. None of this detail is set out in section 30 itself.

Section 30(2) states:

The Authority may prescribe, by Regulations, the conditions, disclosure requirements, approval processes and ongoing obligations applicable to Initial Virtual Asset Offerings.

At the time of writing, these Regulations had not been published. What is settled by the Act itself is the eligibility gate in section 30(1); what remains open is the mechanics — how an offering is approved, what must be disclosed to investors, and what continuing obligations attach to the Issuer after funds are raised. A project planning an offering can confirm today whether it meets the section 30(1) eligibility gate, but cannot yet build a complete compliance process for the offering itself without the Regulations.

What does section 51 prohibit, and who does it catch?

Section 51 makes it unlawful to conduct or purport to conduct an Initial Virtual Asset Offering in or from Pakistan except in accordance with the Act and its Regulations. This prohibition applies regardless of whether the offering is dressed up under a different label.

Section 51 states:

No Person shall conduct or purport to conduct an Initial Virtual Asset Offering in or from Pakistan, except in accordance with this Act and the Rules or Regulations made thereunder.

The word “purport” is doing real work here. It is not only a completed, successful offering that section 51 prohibits — attempting to conduct one, or holding out that one is being conducted, without meeting the Act’s requirements, falls within the prohibition. Combined with the “in or from Pakistan” language, this reaches both a Pakistan-based project raising funds domestically and a foreign project directing an offering at persons in Pakistan.

What happens to someone who breaches section 51?

Section 54(2) makes a section 51 breach a criminal offence, carrying imprisonment for up to three years, a fine of up to twenty-five million Rupees, or both.

Section 54(2) states:

Whoever conducts an Initial Virtual Asset Offering in contravention of this Act, Rules and Regulations shall be punishable with imprisonment for a term up to three years, or with fine up to twenty-five million Rupees or with both.

This penalty sits below the maximum for unlicensed Virtual Asset Services generally — section 54(1) sets a five-year imprisonment ceiling and a fifty-million-Rupee fine ceiling for providing an unlicensed Virtual Asset Service — but it is still a criminal, not merely administrative, consequence. Section 55 extends liability to a body corporate’s officers where the offence is committed “with the consent, connivance or neglect” of a director, manager, secretary or similar officer, meaning individuals responsible for a non-compliant offering carry personal exposure alongside the corporate entity.

Provision	What it addresses
Section 3(1)(xiv)	Defines what counts as an Initial Virtual Asset Offering
Section 30(1)	Restricts eligibility to Pakistani-registered entities meeting prescribed criteria
Section 30(2)	Delegates conditions, disclosure, approval and ongoing obligations to Regulations
Section 51	Prohibits conducting or purporting to conduct an offering outside the Act’s terms
Section 54(2)	Sets the criminal penalty for breaching section 51

Does section 30’s Pakistan-registration requirement mean a foreign project cannot raise funds from Pakistani investors at all?

The Act does not say a foreign project can never reach Pakistani investors — it says the entity conducting an Initial Virtual Asset Offering must itself be a legal entity registered in Pakistan meeting the prescribed criteria. A foreign issuer intending to run an offering that reaches persons in Pakistan would, on the wording of section 30(1) and section 2(1)(b)’s scope-of-application language covering an Issuer offering a Virtual Asset “in or from Pakistan”, need to establish and register the relevant entity in Pakistan before conducting the offering through it, rather than running the offering directly from an unregistered foreign entity into the Pakistani market.

This reading is consistent with the SECP registration step that already sits ahead of full VASP licensing under the Act’s general structure, and with the NOC process under section 19, which requires a Person intending to incorporate a company with the primary objective of engaging in Virtual Asset Services to obtain a No-Objection Certificate before incorporation.

What should a project planning an offering check before proceeding?

• confirm the entity intending to conduct the offering is, or will be, a legal entity registered in Pakistan, since section 30(1) treats this as a precondition rather than an option
• treat any eligibility criteria eventually published in Regulations as a second, additional gate on top of registration, not a formality
• avoid describing or marketing anything as an offering, or structuring a raise that functions as one, ahead of meeting section 30’s requirements, given that section 51 catches attempts and holding-out as well as completed offerings
• build disclosure and approval-process capability now around the general direction the Act signals — public offering, defined consideration, ongoing obligations — while treating the specific mechanics as provisional until Regulations are published
• confirm the entity’s Issuer status separately under section 3(1)(xiii), since only an Issuer can conduct an Initial Virtual Asset Offering in the first place

Projects sequencing their market entry around a token offering should treat section 30 registration as an early-stage milestone, built into the timeline before any public offering activity begins, rather than a step to resolve once fundraising is already underway.

Related reading

• [The 10 PVARA License Categories Explained

  2026 Guide](https://www.coinconnect.site/blog/coinconnect-insights-1/pvara-license-categories-explained-23)

• SECP Registration for Crypto Companies in Pakistan 2026
• Crypto Company Pakistan: Why NOC Comes Before SECP

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026, 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.