The PVARA Managing Director and Delegated Authority

Beneath the Chairperson and the eight-member board, the Virtual Assets Act, 2026 creates a second leadership office: the Managing Director. Unlike the Chairperson, the Managing Director is not appointed by the Federal Government and does not sit as a voting board member in the ordinary course. The role is closer to that of a chief executive who runs the Authority day to day and can be handed specific powers the board decides to delegate.

Sections 3(1)(xviii), 10 and 12 of the Act, read together, define exactly what this office is, how it is appointed, what it does in board proceedings, and how far the board can push authority down to it.

What does the Act mean by “Managing Director”?

Section 3(1)(xviii) gives a short, formal definition: “‘Managing Director’ means the Managing Director of the Authority, appointed under this Act.” As with the Chairperson’s definition, this is self-referential — it confirms the term refers specifically to the office created and appointed under the Act’s own provisions, principally section 12, rather than importing any meaning from how the title is used at an ordinary company under the Companies Act, 2017.

Who appoints the Managing Director, and for how long?

The Authority itself appoints the Managing Director — not the Federal Government, which is the appointing body for the Chairperson under section 11. Section 12(1) states: “the Authority shall appoint a Managing Director for a term of three years, extendable for a further maximum of two term of three years only.” That gives a fixed three-year initial term, extendable twice, each extension also being three years — a maximum tenure of nine years across the original term and two extensions, if both extensions are granted in full.

This differs in two ways from the Chairperson’s appointment under section 11: the appointing body is the Authority’s own board rather than the Federal Government, and the term length is fixed by the statute itself at three years per term, rather than left to the appointing body’s discretion the way the Chairperson’s term length is.

Feature	Chairperson (section 11)	Managing Director (section 12)
Appointed by	Federal Government	The Authority (its own board)
Term length	Left to the Federal Government to determine	Fixed at three years per term by the statute
Maximum terms	Original appointment plus two re-appointments	Original term plus two extensions of three years each
Removal standard	Gross misconduct or incapacity, with show cause notice and hearing	Not separately specified in the sections reviewed

What qualifications must the Managing Director meet?

Section 12(2) sets a general integrity-and-competence standard, with the detail left to future rulemaking: “the Managing Director shall be a person of proven integrity and competence, and shall meet such qualifications, criteria, and requirements as may be prescribed by Regulations.” Unlike the Chairperson’s qualification standard in section 11(1), which names specific criteria directly in the statute (digital finance or technology expertise, three years’ relevant experience), the Managing Director’s detailed qualifications are deferred entirely to Regulations the Authority has not yet, as of the source documents reviewed, published in full.

Does the Managing Director vote on board decisions?

Not by default. Section 12(3) states: “the Managing Director shall act as Secretary of the Authority for its proceedings but shall not have voting rights unless specifically authorized.” This gives the Managing Director a defined administrative role — acting as Secretary for the Authority’s proceedings, which in practice means responsibility for the formal record and conduct of board business — while withholding voting rights unless the Authority specifically grants them.

This is a meaningful distinction from the eight board seats fixed under section 7: the Chairperson, the six ex-officio members and the two independent directors all vote as of right on Authority decisions, subject to the quorum rules in section 8. The Managing Director sits at the table in a secretarial capacity and only votes if separately authorised to do so — meaning the office can service board meetings without automatically shifting the balance of votes described in how PVARA’s board decides.

What powers can the board delegate to the Managing Director?

Whatever the Authority itself decides, on whatever terms it sets. Section 10 states simply: “the Authority may delegate any of its powers and functions to the Managing Director, subject to such terms, conditions, and limitations as it may deem appropriate.” This is a broad, open-ended delegation power — the Act does not list categories of powers that cannot be delegated, and does not require Regulations to define the scope of delegation in advance. The constraint is entirely at the Authority’s own discretion: it decides what to delegate and on what terms, case by case or through a standing policy.

In practice, this structure lets PVARA’s board retain formal ownership of licensing, Regulation-making, budget and policy decisions under section 7(3), while pushing operational execution — day-to-day supervision, correspondence with applicants, routine approvals — down to the Managing Director’s office under whatever delegation the board has approved. The Act gives no indication of what has actually been delegated as a matter of current practice; that is a question of PVARA’s internal delegation instrument, not something the primary legislation answers.

How does the Managing Director’s office fit alongside the Authority’s staff generally?

Section 13 gives the Authority a separate, broader power to appoint “such employees, officers, consultants, and technical or professional advisers as are necessary for the performance of its functions,” through a transparent and competitive process prescribed by Regulations. The Managing Director sits above that general staffing structure as the appointed office with a term fixed directly in the Act, a defined secretarial role in board proceedings, and the capacity to receive delegated authority under section 10 — distinguishing it from the wider body of officers and consultants appointed under the Authority’s general staffing power.

What should an applicant or licensee take from this structure?

Three points follow directly from the text, without inferring beyond it:

1. Day-to-day correspondence with PVARA may run through delegated authority rather than the full board. Given the breadth of section 10, an applicant’s licence conditions, ongoing-obligation queries or supervisory correspondence may in practice be handled under powers the board has delegated to the Managing Director, rather than requiring a full board sitting each time.
2. The Managing Director’s formal role in meetings is administrative unless the board says otherwise. Under section 12(3), do not assume the Managing Director’s presence at a board discussion carries a vote — it does not, unless the Authority has specifically authorised it for that individual.
3. The Managing Director’s own qualifications are not yet fixed in the primary legislation. Where a licensee or applicant needs certainty about who is empowered to make a particular decision under delegated authority, the safer step is to request confirmation of the specific delegation in writing, rather than assume its scope from section 10 alone.

Related reading

• PVARA Exchange License: Capital, Rules & Obligations 2026
• PVARA Transfer & Settlement License: Crypto Payments 2026
• The PVARA Licensing Gold Rush: Pakistan’s Crypto Frontier
• PVARA Custody License: Safeguard Customer Crypto 2026
• PVARA Management & Investment License: Crypto Funds 2026

About this analysis

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