Not every token issuer poses the same risk to Pakistan’s financial system. A token with a handful of holders and a small reserve is a different regulatory problem from one circulating widely across borders with systemic reach. Section 33 of the Virtual Assets Act, 2026 builds that distinction directly into the law, creating a separate, more heavily supervised category: the Significant Issuer.
What is a Significant Issuer under the Act?
Section 33(1) states an Issuer shall be deemed a Significant Issuer if it meets thresholds and criteria prescribed by Regulations, having regard to size, scale, systemic importance, market impact, number of holders, and cross-border activity.
Section 33(1) states:
An Issuer shall be deemed a Significant Issuer if it meets the thresholds and criteria prescribed by Regulations, having regard to size, scale, systemic importance, market impact, number of holders, and cross-border activity.
Two things follow from this wording. First, Significant Issuer status is not a category an Issuer chooses to opt into or declares for itself — it is “deemed”, meaning the classification attaches automatically once the prescribed thresholds are met, regardless of the Issuer’s own preference. Second, the six factors listed — size, scale, systemic importance, market impact, number of holders, and cross-border activity — are the considerations Regulations must have regard to, but the Act does not itself set numeric thresholds for any of them. At the time of writing, no Regulations defining these thresholds had been published.
What are the six factors that decide Significant Issuer status?
Reading the six factors in section 33(1) together, they span three different kinds of measurement:
- size and scale — likely measured by the value of the reserve, the token’s market capitalisation, or transaction volume, though the Act does not specify a metric
- systemic importance and market impact — a qualitative assessment of how disruptive the Issuer’s failure or misconduct would be to Pakistan’s broader virtual asset market or financial system
- number of holders and cross-border activity — measures of reach, both in terms of how many people hold the token and how far its circulation extends beyond Pakistan’s borders
None of these six factors is stated to be individually decisive — the Act’s language, “having regard to,” suggests Regulations will likely weigh them together rather than triggering Significant Issuer status from any single factor crossing a line on its own, though this is an inference rather than a stated rule, since the Act does not describe how the factors interact.
What obligations apply once an Issuer is deemed significant?
Section 33(2) requires Significant Issuers to register with the Authority and comply with enhanced requirements covering reporting, disclosure, governance, and risk management, as prescribed in Regulations.
Section 33(2) states:
Significant Issuers shall be registered with the Authority and shall comply with enhanced requirements, including reporting, disclosure, governance, and risk management, as prescribed in Regulations.
The word “enhanced” signals that these obligations sit on top of, not instead of, whatever obligations already apply to the Issuer under sections 31 or 32 for its specific token type. A Fiat-Referenced Token issuer that becomes a Significant Issuer continues to meet the six section 31(1) issuance requirements, and additionally takes on the enhanced reporting, disclosure, governance and risk-management obligations Regulations prescribe for Significant Issuers specifically.
| Layer | Source | What it requires |
|---|---|---|
| Base issuance requirements | Section 31 (Fiat-Referenced) or Section 32 (Asset-Referenced) | Reserve backing, audited disclosures, AML/CFT/CPF compliance, insolvency protection |
| Significant Issuer registration | Section 33(2) | Separate registration with the Authority |
| Enhanced reporting | Section 33(2) | Beyond the standard periodic returns required of Licensees generally |
| Enhanced disclosure | Section 33(2) | Beyond the standard reserve attestation obligations under section 42(2) |
| Enhanced governance | Section 33(2) | Additional governance structure requirements, content not yet prescribed |
| Enhanced risk management | Section 33(2) | Additional risk-management standards, content not yet prescribed |
Does Significant Issuer status apply only to Fiat-Referenced and Asset-Referenced Tokens?
Section 33(1) refers to “an Issuer” generally, without limiting the concept to issuers of Fiat-Referenced or Asset-Referenced Tokens specifically. Chapter 5 of the Act, where section 33 sits, is headed “Fiat-Referenced and Asset-Referenced Tokens,” which suggests the immediate context is these two token types. However, the section 33(1) text itself does not use language expressly restricting Significant Issuer status to only those two categories, and the Issuer definition in section 3(1)(xiii) is not itself limited to stablecoin-style tokens. Our reading is that the Chapter 5 placement points toward Fiat-Referenced and Asset-Referenced Token issuers as the primary intended targets, but the Act’s wording does not conclusively rule out the concept applying more broadly once Regulations define the thresholds — this is a point worth confirming directly with the Authority rather than assuming either way.
How does an issuer know in advance whether it will cross the threshold?
It cannot know precisely, because the Act leaves the specific thresholds to Regulations that had not been published at the time of writing. What an Issuer can reasonably anticipate is the direction of travel: a token with a large or fast-growing holder base, meaningful reserve size, or significant cross-border circulation is more likely to be positioned near wherever the eventual thresholds are set, based on the six factors section 33(1) lists. An Issuer whose growth trajectory points toward any of these factors should build enhanced reporting, governance and risk-management capability ahead of formally crossing the threshold, rather than treating Significant Issuer status as a distant contingency to address only once notified.
What should a growing issuer do to prepare for possible Significant Issuer status?
- track growth against the six section 33(1) factors — size, scale, systemic importance, market impact, holder numbers, and cross-border activity — as an internal monitoring exercise, even without published numeric thresholds
- build governance structures now that could scale to an enhanced standard, rather than assuming a lighter-touch structure adequate for a small issuance will remain adequate indefinitely
- treat risk-management and reporting infrastructure as something to over-build relative to current size, given that Significant Issuer status is deemed automatically once thresholds are met, not applied for
- monitor for the publication of Regulations defining the specific thresholds, since these will be the first concrete signal of where the line actually sits
- consider cross-border circulation carefully in growth planning, since it is one of the six named factors and is often the dimension an Issuer can most directly influence through its own distribution decisions
Issuers planning a Fiat-Referenced or Asset-Referenced Token programme with ambitions beyond a small, domestic-only circulation should treat Significant Issuer status as a realistic medium-term outcome to design for, not an edge case, and should factor this into regulatory licensing planning from the outset rather than revisiting governance structures after growth has already outpaced them.
Related reading
- Stablecoin Issuance Under PVARA: Reserve Rules 2026
- Asset-Referenced Token Issuance Under PVARA: Gold 2026
- How Much Capital Do You Need for a VASP Licence in Pakistan? 2026
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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