Most of the Virtual Assets Act, 2026 is written around a specific transaction: licensing a Virtual Asset Service Provider (VASP) or an Issuer. Two provisions step outside that frame and give the Pakistan Virtual Assets Regulatory Authority (PVARA, “the Authority”) a broader job — governing how blockchain and distributed ledger technology (DLT) are adopted across Pakistan generally, whether or not a Virtual Asset is involved. This matters for anyone planning a blockchain-based product in Pakistan, licensed or not, because it signals where regulatory attention is likely to land next.
What blockchain mandate does the Act give PVARA, beyond licensing VASPs?
Section 9(1)(e) states that the Authority shall “promote, develop, govern, and regulate the adoption, deployment, and scalable use of blockchain technology and distributed ledger technology across Pakistan.” This sits among the Authority’s core objectives in section 9(1), alongside licensing and consumer protection, meaning blockchain governance is not a side function — it is one of the Authority’s stated purposes for existing.
Section 9(1)(e) states:
promote, develop, govern, and regulate the adoption, deployment, and scalable use of blockchain technology and distributed ledger technology across Pakistan.
The phrase “across Pakistan” is broader than “in the Virtual Asset market.” Read together with the Act’s definition of “Blockchain” or “Distributed Ledger Technology” or “DLT” in section 3(1)(iii) — “a technology that enables a distributed ledger, an information repository that records transactions or data across multiple nodes in a synchronized manner using cryptography to ensure integrity, tamper-resistance, immutability, and consensus among participants” — the mandate is technology-focused, not confined to whatever falls within the Act’s narrower “Virtual Asset” definition.
How does section 36 turn that objective into an active duty?
Section 36, titled “Oversight of blockchain technology adoption,” converts the section 9(1)(e) objective into two specific duties. Section 36(1) requires the Authority to issue Regulations, standards, directives, and guidelines on the adoption, deployment, and use of blockchain or distributed-ledger technology. Section 36(2) requires the Authority to consult with relevant regulators and ministries to ensure harmonisation of blockchain adoption across Pakistan.
Section 36 states:
(1) The Authority shall issue Regulations, standards, directives, and guidelines on the adoption, deployment, and use of blockchain or distributed-ledger technology. (2) The Authority shall consult with relevant regulators and ministries to ensure harmonization of blockchain adoption across Pakistan.
Both sub-sections use “shall,” not “may” — this is drafted as a mandatory duty on the Authority, not a discretionary power it can choose to leave unused. At the time of writing, no such Regulations, standards, directives or guidelines under section 36(1) had been published, and the Act does not itself set a deadline by which they must appear.
Does this mean PVARA regulates all blockchain use, even outside Virtual Assets?
Section 5(3) points toward yes, at least as a matter of primary jurisdiction. It states that “the regulation and supervision of Virtual Assets, Virtual Asset Service Providers, tokenization of real-world assets, and blockchain technology shall vest primarily in the Authority under this Act, in coordination with other relevant regulators where applicable.”
This is a wider claim than the licensing chapters of the Act make on their own. Licensing under Chapter 3 turns on whether an activity meets the definitions of “Virtual Asset Service” in section 18 and Schedule I, or “Virtual Asset” in section 3(1)(xxxi). A blockchain deployment that does not meet either definition — a private, permissioned ledger used for internal supply-chain records, for example, with no tradeable token and no payment or investment function — would fall outside licensing under Chapter 3 as drafted. Section 5(3), however, still names “blockchain technology” generally as vesting primarily in the Authority, subject to coordination with other regulators. Where the precise boundary sits between a blockchain deployment requiring a licence and one that falls under the broader section 5(3) and section 9(1)(e) governance mandate without triggering licensing is not spelled out in the Act, and is a question worth raising directly with the Authority for any specific project.
| Provision | What it establishes |
|---|---|
| Section 9(1)(e) | Blockchain adoption as a core objective of the Authority |
| Section 36(1) | Mandatory duty to issue blockchain Regulations, standards, directives and guidelines |
| Section 36(2) | Mandatory duty to consult other regulators and ministries for harmonisation |
| Section 5(3) | Blockchain technology vests primarily in the Authority, alongside Virtual Assets |
| Section 3(1)(iii) | Statutory definition of “Blockchain” or “DLT” |
Which other regulators is PVARA required to coordinate with on blockchain policy?
Section 36(2) requires consultation with “relevant regulators and ministries” but does not name them. The Act’s own composition of the Authority under section 7(1) offers the clearest signal of who those bodies are likely to be, since it already seats several of them at the Authority’s own table: the Secretary of the Ministry of Finance, the Secretary of the Ministry of Law and Justice, the Governor of the State Bank of Pakistan, the Chairperson of the Securities and Exchange Commission of Pakistan, the Chairman of the National AML-CFT Authority, and the Chairperson of the Pakistan Digital Authority.
- the State Bank of Pakistan, given its role in payments infrastructure and monetary policy
- the Securities and Exchange Commission of Pakistan, given its jurisdiction over securities and financial instruments under section 2(2)(b) of the Act
- the Pakistan Digital Authority, given its general digital-policy remit
- the Ministry of Law and Justice and the Ministry of Finance, both already represented in the Authority’s own composition
None of this list is stated in section 36 itself — it is drawn by inference from section 7(1)’s composition of the Authority, and should be treated as a reasonable expectation rather than a confirmed list of consultees for any specific blockchain Regulation.
Does the blockchain mandate extend to the Strategic Digital Wallet Company?
Related but distinct. Section 38 empowers the Federal Government to establish a Strategic Digital Wallet Company (“SDWC”), a wholly government-owned company to design, develop, operate and secure wallet infrastructure enabling the Government of Pakistan and designated public bodies to manage, transfer and record Virtual Assets in furtherance of strategic reserve objectives. Section 38(2) confirms the SDWC operates exclusively for government and designated public bodies, and “shall not provide services to the private persons.”
The SDWC is a piece of state blockchain infrastructure sitting alongside, not instead of, PVARA’s general section 36 oversight mandate. The Act does not state that PVARA supervises the SDWC directly, and the source documents do not describe the relationship between the two in further detail — this is a structural gap worth flagging rather than resolving by assumption.
What does the blockchain mandate mean for a foreign firm planning market entry?
- a blockchain product that avoids the Act’s Virtual Asset definition entirely may still sit within the Authority’s broader section 9(1)(e) and section 5(3) governance interest, even if it does not require a licence under Chapter 3
- section 36(1) Regulations, once published, are the document to watch for firms building blockchain infrastructure in Pakistan without necessarily issuing a Virtual Asset
- the mandatory “shall consult” language in section 36(2) means blockchain policy is likely to be shaped through inter-agency coordination, not PVARA acting alone — firms engaging with the Authority on a novel blockchain use case should expect other regulators’ priorities to surface in the process
- entities already exploring regulatory licensing for a Virtual Asset Service should treat section 36 Regulations, once issued, as a second compliance surface distinct from their VASP licence conditions
Pakistan’s Virtual Assets Act positions blockchain governance as a standing national mandate, not an incidental by-product of licensing crypto exchanges. Firms treating PVARA purely as a licensing gate for tokens and exchanges are reading only part of the statute; section 9(1)(e), section 36 and section 5(3) together point to a regulator with a broader, technology-level interest that is likely to expand once its blockchain-specific Regulations are published.
Related reading
- PVARA Exchange License: Capital, Rules & Obligations 2026
- PVARA Transfer & Settlement License: Crypto Payments 2026
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.
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