An unlicensed virtual asset service does not need to be prosecuted or sanctioned before the Pakistan Virtual Asset Regulatory Authority can act against its visibility in Pakistan. Section 61 of the Virtual Assets Act 2026 gives the Authority a direct takedown power — the ability to remove, block, or direct the removal or blocking of websites, apps, advertisements and payment links that promote or relate to unlicensed activity.
This power reaches beyond the operator of the unlicensed service itself. It can be directed at telecommunication authorities, hosting providers, app stores, search engines, advertising networks, domain registrars and payment providers — anyone in the chain that makes the unlicensed material accessible. That breadth is deliberate: an unlicensed offshore operator may be outside PVARA’s direct reach, but the intermediaries that carry its website, app or payments into Pakistan generally are not.
For a licensed virtual asset service provider, section 61 also matters defensively — it is the mechanism that keeps unlicensed competitors from operating visibly in the same market a licensee has paid to enter lawfully.
What material can PVARA remove or block under section 61?
The Authority may remove, block, or direct the removal or blocking of any online material — the Act gives websites, apps, advertisements and payment links as examples — if, on reasonable grounds, it promotes, operates, or relates to an unlicensed virtual asset service or otherwise contravenes the Act, its Rules, or its Regulations. Section 61(1) sets this test.
The phrase “on reasonable grounds” sets the evidentiary bar the Authority must meet before acting — not proof beyond doubt, and not the “satisfied” standard used for administrative sanctions under section 59, but a reasonable-grounds threshold the Act does not further define. The list of material types — websites, apps, ads, payment links — is introduced with “e.g.”, meaning it is illustrative rather than exhaustive; other forms of online material relating to unlicensed activity would fall within the same power if they meet the same test.
Who can PVARA direct to act on a blocking order?
Section 61(2) lists the categories of person a blocking direction may be issued to:
| Category | Role in the chain |
|---|---|
| Telecommunication authorities | Network-level access controls |
| Virtual Asset Service Providers | Licensed entities that might otherwise carry unlicensed material or activity |
| Intermediaries | General technical or facilitation role |
| Hosting providers | Host the website or app infrastructure |
| App stores | Distribute mobile applications |
| Search engines | Index and surface the material |
| Advertising networks | Carry promotional material for the unlicensed service |
| Registrars | Control domain-name registration |
| Payment providers | Process payments connected to the unlicensed service |
| Any other person facilitating such material | A residual, catch-all category |
This list covers essentially every point at which an unlicensed service touches the Pakistani market — from the domain that resolves to its website, through the app store that distributes its mobile app, to the payment rail that moves money into or out of it. The final category, “any person facilitating such material”, means the list is not closed.
What must a blocking order contain?
All orders or directions issued under section 61 must be in writing, must state reasons and the statutory basis for the action, and must be communicated to the affected person. Section 61(3) sets these three requirements together — form, substance, and delivery. A blocking direction cannot be issued informally, and it cannot omit the reasoning or the section of the Act relied on.
“All orders or directions shall be in writing, stating reasons and statutory basis, and communicated to the affected person.”
This requirement gives the recipient of a direction — whether the operator of the material itself, or an intermediary such as a hosting provider or payment processor directed to act on it — the information needed to understand why the order was made and, where relevant, to exercise the representation right described below.
Can PVARA require evidence to be preserved?
Yes. The Authority may require preservation of copies, logs, or transactional data for evidentiary purposes. Section 61(4) gives the Authority this separate power, distinct from the blocking or removal direction itself. In practice, this means a person directed to block or remove material may also be required to retain records relating to it — the underlying content, access logs, or transaction records — rather than simply deleting everything once the blocking action is complete, preserving the evidentiary trail for any later investigation, administrative sanction, or prosecution.
Can a person affected by a blocking order object to it?
Yes, within a fixed and short window. A person aggrieved by an order under section 61 may submit a representation within ten days of the order, and the Authority must respond in writing within fifteen days. Section 61(5) sets out this two-step timeline — a short window to object, followed by a defined period within which the Authority must reply.
The Act does not specify what form the Authority’s written response must take beyond requiring that it be in writing, and it does not state what happens to the blocking order itself while the ten-day representation period and the Authority’s fifteen-day response are running — whether the block remains in effect throughout, or whether it is suspended pending the Authority’s reply. Given the emergency and prevention-focused purpose of section 61, our reading is that the block most likely remains in place during this window rather than being automatically lifted, but the Act’s text does not settle this directly, and it is worth verifying against any Regulations PVARA has issued to operationalise section 61.
How does section 61 relate to the criminal offence of unlicensed activity?
Section 61 is a separate, direct power aimed at the visibility and accessibility of unlicensed material — it does not itself require a criminal conviction, an investigation under sections 56 and 57, or a finding under the administrative sanctions regime at section 59. A wilful provider of an unlicensed virtual asset service separately faces criminal liability under section 54(1) — imprisonment up to five years, a fine up to fifty million Rupees, or both — but section 61 does not require that liability to be established first. The Authority can act to block or remove the material on reasonable grounds, independently of whether or when a criminal case against the operator concludes.
This makes section 61 the Act’s fastest tool for limiting an unlicensed operator’s reach into Pakistan, in the same way section 60’s emergency powers are its fastest tool for containing risk at a licensed entity — both operate ahead of, and independently from, the slower investigation, sanction and trial processes elsewhere in the enforcement chapter.
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 as passed by the National Assembly — principally sections 54, 59, 60 and 61 — read as published. Where the Act does not settle a procedural detail, such as the status of a blocking order during the representation period, 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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