PVARA's Sixty-Day Window to Decide an NOC Application

An applicant preparing a No Objection Certificate application for the Pakistan Virtual Asset Regulatory Authority (“PVARA” or “the Authority”) wants one number above almost everything else: how long the decision takes. The PVARA No Objection Certificate Regulations 2025 answer that directly, in Part 5, regulation 17 — a sixty calendar day decision window, applied after the Authority has completed its assessment of the application.

This article works through what that sixty-day window covers, what an NOC actually authorises once granted, and what the Regulations require if the Authority refuses the application instead.

How long does PVARA have to decide an NOC application?

Sixty calendar days, running from the conclusion of the Authority’s assessment of the application. Regulation 17.1 of the NOC Regulations states:

“Following assessment, the Authority shall (within a period not exceeding 60 calendar days): (a) issue the NOC to… or (b) refuse NOC.”

The phrase “following assessment” matters. The Regulations set out a separate assessment stage at regulation 16, covering fitness and propriety of Key Individuals and Controllers, the adequacy of the applicant’s AML/CFT framework, governance arrangements, financial soundness, technology architecture, and the applicant’s ML/TF risk profile — and the Authority may conduct interviews, inspections, or request additional information as part of that assessment under regulations 16.2 and 16.3. The sixty-day clock in regulation 17.1 attaches to the decision the Authority makes once that assessment work is done, rather than to the full span of time from the moment an applicant first submits Form A1 under regulation 15.1. The Regulations do not state a separate outer limit for how long the assessment stage itself may run, so the total time from first submission to a final NOC decision is not fixed by a single number in the Regulations as published.

What does an NOC actually authorise?

An NOC does four specific things, all set out in regulation 17.1(a). It is not simply a green light to start operating — it is a bundle of four distinct permissions, each tied to a different stage of an applicant’s path toward a full VASP licence.

Regulation 17.1(a) provides that, on a decision to grant, the Authority shall issue the NOC to:

“(i) the applicant to register the foreign chapter, already providing AML-Registered Services in Pakistan, in accordance with the No Objection Certificate Regulations on the goAML portal; (ii) incorporate a local entity in Pakistan for the purpose of applying for a full VASP Licence under Section 17 of the Ordinance; (iii) to provide ‘AML-Registered Services’ (limited to Exchange, Broker-Dealer, Custody and Derivative Services) upon completion of goAML registration, in advance of obtaining a full VASP Licence; and (iv) submit licensing application within three months of promulgation of VASP licensing regulations.”

Laid out plainly, the four things an NOC authorises are:

#	What the NOC authorises
(i)	Registering the applicant’s foreign entity — already providing AML-Registered Services in Pakistan — on the FMU’s goAML portal
(ii)	Incorporating a local entity in Pakistan, for the purpose of applying for a full VASP Licence under section 17 of the Ordinance
(iii)	Providing “AML-Registered Services” — limited to Exchange, Broker-Dealer, Custody and Derivatives Services only — once goAML registration is complete, and before a full VASP licence is obtained
(iv)	Submitting the full licensing application, within three months of the promulgation of VASP licensing regulations

Read together, these four items describe a phased pathway rather than a single approval: register on goAML, incorporate locally, begin a narrow slice of permitted services under AML registration, and then move on to the full licensing application once the corresponding regulations are promulgated. This structure is confirmed elsewhere in the Regulations — regulation 2.2 describes an NOC as constituting “(i) approval for the Applicant’s AML Registration on the goAML portal; and (ii) permission for the Applicant to proceed with incorporation of its local entity in Pakistan,” and regulation 2.3 designates the same four service categories — Broker-Dealer, Custody, Exchange and Virtual Asset Derivative Services — as the “AML Registered Services” an NOC holder may provide ahead of full licensing.

Which services can an NOC holder actually provide before full licensing?

Only four, and only after completing goAML registration: Broker-Dealer Services, Custody Services, Exchange Services, and Virtual Asset Derivative Services. Regulation 2.3 designates these specifically as non-financial businesses and professions for the purposes of AML Registration on the goAML portal, and together labels them the “AML Registered Services.” The Regulations are explicit that this is a limited carve-out, not a general licence to operate: “all other Virtual Asset Services defined under the Ordinance not otherwise constituted as an AML Registered Service may only be provided following the grant of a full license under Section 17, unless otherwise agreed with PVARA.” An applicant whose intended business falls outside those four categories — advisory services, lending and borrowing, or management and investment services, for example — does not gain authority to provide that service from the NOC itself; it remains gated behind the full VASP licence.

What happens if PVARA refuses the NOC application?

The Authority must give written reasons. Regulation 17.2 states: “Where an application is refused, the Authority shall provide written reasons for its decision.” The Regulations do not set out a separate right of reconsideration or resubmission specific to a refused NOC application within Part 5 itself, and readers should not assume one exists beyond whatever general appeal rights apply under the wider statutory framework governing PVARA decisions.

What conditions come attached to an NOC?

Regulation 17.3 confirms that the conditions referenced in regulation 17.1 — goAML registration, incorporation of the local entity, and the commitment to apply for a full licence — form the substance of what an NOC requires of its holder: “The conditions referenced here include goAML registration, incorporation and the commitment to apply for a full license under the Ordinance.” In practice, an NOC is not an unconditional approval that sits quietly in a drawer. Regulation 18.1(f), in the Ongoing Obligations part of the Regulations, reinforces this by requiring a registered applicant to “apply for and progress diligently toward a full VASP License within the time period required by the Authority” — meaning the conditions attached at the point of grant continue to apply, and to be monitored, through the period the NOC holder operates under AML registration.

Does the Authority’s assessment stage affect how the sixty-day window is used?

It shapes what the Authority is deciding on, even though it sits outside the sixty-day figure itself. Regulation 16.1 lists what the assessment covers — fitness and propriety of Key Individuals and Controllers, the adequacy and operational readiness of the AML/CFT framework for AML-Registered Services, governance and internal controls, financial soundness, the adequacy of technology architecture and monitoring systems, and the applicant’s inherent and residual ML/TF risk profile. Regulations 16.2 and 16.3 give the Authority latitude to interview Key Individuals and to conduct inspections or request further information as part of forming that assessment. None of this latitude is bounded by a stated time limit in the Regulations as published, which is why the sixty-day figure in regulation 17.1 should be understood as the decision window that follows assessment, not as a guarantee of how long the entire NOC process, from first submission to final decision, will take in a given case.

How does the NOC decision fit into the wider path to a full VASP licence?

The NOC decision is the gateway, not the destination. Once granted, regulation 15.3 of the Regulations sets out what the successful applicant must do next: register the foreign entity already providing AML Registered Services in Pakistan on the goAML portal, incorporate a local company as required under section 15(1) of the Ordinance, and submit the licensing application, in the form the Authority prescribes, within three months of the issuance of the VASP licensing regulations. Regulation 15.4 confirms that the grant of the NOC “shall satisfy the pre-incorporation regulatory clearance required under Section 15 of the Ordinance and shall permit the Applicant to provide AML-Registered Services in accordance with these Regulations” — tying the sixty-day decision covered here directly into the corporate setup steps that follow it.

About this analysis

This analysis was prepared by the CoinConnect research desk from the PVARA No Objection Certificate Regulations 2025, principally regulation 17.1 through 17.3, read alongside regulations 2.2, 2.3, 15.3, 15.4, 16.1 to 16.3 and 18.1(f) for context, as published. Where the Regulations do not state an outer time limit for the assessment stage that precedes the sixty-day decision window, or do not set out a separate reconsideration process for a refused application, 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.