The Ten Key Individual Positions Under the Act

Section 3(1)(xv) of the Virtual Assets Act, 2026 is a hiring plan disguised as a definition. It lists ten positions, and anyone occupying one of them in relation to a Licensee is a Key Individual.

For an incoming business this is one of the most concrete provisions in the Act. Most of the framework tells you what to do. This one tells you who you need.

Who counts as a Key Individual?

A Key Individual is any natural person who occupies or performs one or more of ten listed positions in relation to a Licensee. Section 3(1)(xv) captures them “whether on a full-time, part-time, acting or outsourced basis” — so the obligation attaches to the function being performed, not to the employment arrangement.

That opening qualifier does more work than the list itself, and we return to it below.

What are the ten positions?

Section 3(1)(xv)(a) to (j) lists them:

#	Position
(a)	Director, executive or non-executive, registered under the Companies Act, 2017
(b)	Managing Director
(c)	Chief financial officer
(d)	Chief operating officer
(e)	Head of internal audit
(f)	Head of compliance
(g)	Money-laundering reporting officer (MLRO), or equivalent AML, CFT or CPF compliance officer designated under the AML/CFT/CPF Regulations issued under the Anti-Money Laundering Act, 2010
(h)	Head of risk management
(i)	Head of information-security and cyber-security
(j)	Any other position the Authority declares to be a Key Individual by written notice to the Licensee

Nine named roles, and one open category.

Why does “part-time, acting or outsourced” matter so much?

Because it closes the gap most businesses would otherwise use, deliberately or not.

The natural way to staff a new market entry is to appoint people thinly: a fractional compliance officer, an interim head of risk while you recruit, an outsourced internal audit function, a group CFO covering the local entity alongside three others. Section 3(1)(xv) treats every one of those people as a Key Individual.

Three consequences follow:

1. An interim appointment is not a lighter obligation. Someone acting as head of compliance for six weeks occupies the position.
2. Outsourcing does not transfer the status. Engaging a firm to provide internal audit does not remove the individual performing it from the definition.
3. Group roles count locally. A regional executive performing the CFO function for the Pakistani Licensee is performing a listed position in relation to that Licensee.

The practical effect is that you cannot reduce your Key Individual population by changing contracts. You reduce it only by genuinely not having someone perform the function — which, for these roles, is not an option.

What does limb (j) actually do?

It gives the Authority a named power to extend the list to a specific Licensee, and it is drafted with two limits worth noticing.

First, it operates “by written notice to the Licensee”. That is not a general power exercised through Regulations affecting the whole market; it is directed at a particular firm. Second, it applies to a “position” rather than a person.

Our reading is that this exists so the Authority can respond to business models the list does not anticipate — a head of custody at a custodian, or a treasury function at a stablecoin issuer, where the risk concentrates somewhere the nine named roles do not reach. The Act does not say what standard governs the exercise of that power, and no guidance on it has been issued that we are aware of. Verify the current position with PVARA before assuming your structure is settled.

How does this interact with fit and proper?

Directly, and this is the point at which the definition stops being administrative and starts affecting your timeline.

Key Individual status is the gateway concept. Being on this list is what makes a person subject to the fit and proper assessment. Every additional Key Individual is therefore an additional person to screen, document and evidence.

Combined with the residency and incorporation requirements that sit alongside them in any licence application, the staffing question becomes one of the longest lead-time items in a market entry. Recruiting a qualified MLRO who satisfies the Anti-Money Laundering Act, 2010 framework is not a two-week exercise in any market, and Pakistan’s pool of candidates with virtual asset experience is genuinely thin.

This is why the resident director and senior hiring conversation belongs at the front of an entry plan rather than after the SECP registration is complete.

Can one person hold several of these positions?

The Act does not prohibit it, and the definition is drafted to accommodate it — a Key Individual is someone occupying “one or more” of the listed positions.

But two cautions apply. The AML framework referenced in limb (g) carries its own expectations about the independence of the MLRO function, and combining internal audit with the functions it audits is a governance problem in any regime. The Act’s silence is not permission.

Where a business is minded to combine roles, the honest approach is to put the proposed structure to the Authority rather than to assume that what is not prohibited is accepted.

What should a business do now?

• Map your ten roles against real people, including outsourced and interim ones. Anyone performing a listed function is in scope regardless of contract type.
• Start the MLRO search first. It is the hardest to fill and the most consequential to get wrong.
• Do not assume the list is closed. Limb (j) means the Authority can add to it for your firm specifically.
• Screen early. Every Key Individual is a fit and proper file, and those files take time to assemble.

For a business planning market entry, the useful way to read section 3(1)(xv) is as a recruitment brief with statutory force. It tells you exactly which nine hires are non-negotiable before you can operate, and warns you that a tenth may be added.

What does “in relation to a Licensee” actually cover?

This is the phrase that decides scope, and it is doing quiet work.

Section 3(1)(xv) does not say a Key Individual is someone employed by a Licensee. It says someone who occupies or performs a listed position “in relation to a Licensee”. Employment is not the connecting factor; the relationship to the licensed entity is.

Read alongside the “part-time, acting or outsourced” qualifier, the natural reading is that the test is functional throughout. Three structures commonly used by international groups are worth testing against it:

Structure	Likely position
Group CFO in Dubai also acting as CFO of the Pakistani entity	Performing a listed position in relation to the Licensee
Outsourced internal audit provided by a firm	The individual performing it occupies the position
Non-executive director appointed to the local board	Named expressly in limb (a)

Limb (a) is narrower than the others in one respect worth noting: it refers to a director “registered under the Companies Act, 2017”. That ties the director limb to the local corporate registration rather than to a group board seat, which is consistent with the SECP registration requirement sitting upstream of licensing.

We should be careful about how far to push this. The Act does not define “in relation to”, and we are not aware of guidance on how the Authority applies it to shared group roles. Our reading is functional rather than contractual, for the same reason the outsourcing qualifier exists — but a group planning to share senior functions across jurisdictions should put the proposed structure to the Authority rather than rely on that reading.

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026 as passed by the National Assembly, 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.