PVARA Real-Time Data Access: Section 48 Explained

Most of the Virtual Assets Act, 2026 describes obligations a licensee performs on request — filing a return, responding to an inspection, producing records when asked. Section 48 is different. It requires a Virtual Asset Service Provider (VASP) to build standing technical infrastructure that gives the Pakistan Virtual Asset Regulatory Authority (PVARA) ongoing access to its data, before any specific request is made. This article sets out what section 48 actually requires and what remains open until PVARA issues the Regulations the section itself anticipates.

What does section 48 of the Virtual Assets Act require?

Section 48(1) requires every Licensee to establish secure reporting channels, and — where required — secure automated interfaces, so that PVARA and any other agencies it notifies can access prescribed data for supervisory and enforcement purposes. This is a standing infrastructure obligation, not a one-off filing duty, and it applies for as long as the licence is held.

Section 48 states:

Licensees shall establish secure reporting channels, and where required secure automated interfaces, enabling the Authority and such other agencies as notified to access prescribed data for supervisory and enforcement purposes.

Two distinct obligations sit inside that single sentence. The first is a secure reporting channel — some mechanism for transmitting data to PVARA. The second, conditional on PVARA requiring it, is a secure automated interface — a system-to-system connection that lets the Authority pull prescribed data directly rather than waiting for the VASP to send it. The Act does not treat these as interchangeable; the automated interface is the higher-intensity requirement, and section 48(1) makes clear it applies only “where required,” meaning PVARA can impose it selectively rather than on every Licensee uniformly.

Who else can access a licensee’s data under section 48?

Section 48(1) is not limited to PVARA itself. It extends access to “such other agencies as notified” — meaning PVARA can designate additional bodies, such as the Financial Monitoring Unit (FMU) or another law enforcement or regulatory agency, to receive the same reporting-channel or interface access. The Act does not list these agencies by name in section 48; it leaves the designation to a future notification process.

In practice, this means a Licensee’s technical build cannot assume a single counterparty. A reporting channel or interface designed to serve only PVARA may need to be extended, or duplicated, if the Authority later notifies another agency as an additional recipient under this section.

What data must be made accessible under section 48?

Section 48(1) refers to “prescribed data” — meaning the specific datasets covered by this obligation are left to future Regulations under section 48(2), rather than named in the Act itself. This is consistent with the broader drafting pattern across the Act: operative duties are stated in the statute, and their technical scope is filled in by Regulations later.

• the Act does not currently list which data categories fall within “prescribed data” for section 48 purposes
• until Regulations issue, a Licensee cannot point to a fixed data schema and say its interface build is complete
• the safest working assumption is that “prescribed data” will draw on the same categories the Act already treats as supervisory-relevant elsewhere — records under the customer assets regime, transaction and customer due-diligence records under the anti-money laundering chapter, and periodic returns under the Licensee’s ongoing obligations — but this is our reading, not a statement in section 48 itself

What technical standards apply to the reporting channel or interface?

Section 48(2) gives PVARA the power to prescribe, by Regulations, the technical standards, security requirements and data specifications for both the reporting channels and the automated interfaces referred to in section 48(1).

Section 48(2) states:

The Authority shall prescribe, by Regulations, the technical standards, security requirements and data specifications for the reporting and interfaces referred to in sub-section (1).

At the time of writing, no such Regulations had been published. This leaves a Licensee with a present, binding obligation to build a secure channel under section 48(1), but no published specification for encryption standards, transmission protocols, uptime requirements, or data formats to build it against. The Authority’s technical standards under section 48(2) will govern how compliance is actually assessed once they issue.

Element	Statutory basis	Status
Secure reporting channel	Section 48(1)	Binding obligation now
Secure automated interface	Section 48(1), “where required”	Binding only if PVARA imposes it on a given Licensee
Scope of “prescribed data”	Section 48(2), by Regulations	Not yet published
Technical standards and security requirements	Section 48(2), by Regulations	Not yet published

How does section 48 relate to the licence application and NOC process?

Section 48 sits in Chapter 8 of the Act, alongside the anti-money laundering (AML), countering the financing of terrorism (CFT) and countering proliferation financing (CPF) obligations, rather than in the general prudential chapter. That placement signals its purpose: PVARA wants supervisory data access built for enforcement and AML/CFT purposes, not only for routine prudential monitoring.

The PVARA No Objection Certificate Regulations 2025 already require an applicant to describe its technology architecture and AML-relevant systems — including transaction monitoring, case management, and data storage and backup arrangements — as part of the no objection certificate application. Section 6 of that document asks an applicant to confirm whether these systems are fully operational, in testing, or under implementation. A reporting channel capable of satisfying section 48(1) sits naturally within that same technology description, even though the NOC Regulations do not name section 48 specifically.

How should a VASP prepare for section 48 before Regulations issue?

• treat the secure reporting channel as a build item now, since section 48(1) is a present obligation and not contingent on Regulations being published first
• design the reporting channel to be extensible, since section 48(1) allows PVARA to notify additional agencies as recipients beyond the Authority itself
• avoid assuming a fixed data schema; keep the underlying data model flexible until section 48(2) Regulations name the “prescribed data” categories precisely
• build with recognised security practice — encryption in transit and at rest, access logging, and resilience — rather than waiting for a named standard, since PVARA’s eventual technical requirements are likely to track prevailing international practice
• track PVARA’s publication schedule closely; a Licensee that has already built toward the general shape of section 48(1) will have less rework to do once section 48(2) Regulations narrow the specification

Section 48 asks a VASP to build for supervision as a standing condition of holding a licence, not as something assembled only when PVARA asks. A Virtual Asset Service Provider preparing a licence application should treat the reporting-channel build as part of its core technology case, alongside the AML systems the NOC process already requires it to describe, so the two do not have to be reconciled retrospectively once section 48(2) Regulations arrive.

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026 and the PVARA No Objection Certificate Regulations 2025, 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.