The Ten Virtual Asset Services in Schedule I

Schedule I is the shortest consequential part of the Virtual Assets Act, 2026 and the part most operators need first. It answers the only question that matters at the outset: does what I do require a licence?

Section 18 makes Schedule I the operative list. Anything in it is a Virtual Asset Service. Anything that is a Virtual Asset Service, provided as a business in or from Pakistan, requires a licence under section 50.

This article works through all ten categories using the statutory descriptions, and identifies the three exemptions written into the Schedule itself.

What is Schedule I to the Virtual Assets Act 2026?

Schedule I is the statutory list of virtual asset services requiring a licence in Pakistan. Section 18 provides that Virtual Asset Services comprise all services specified in Schedule I, plus any other service notified by the Federal Government and subsequently included in Schedule I. There are currently ten categories.

The list is expandable without fresh primary legislation. Section 18(b) permits the Federal Government to notify a new service, which is then added to the Schedule.

#	Category	One-line trigger
1	Advisory Services	Personalised recommendations to a specific customer
2	Broker-Dealer Services	Arranging, soliciting, dealing, market-making, placement
3	Custody and Administration Services	Safekeeping assets or private keys for customers
4	Exchange Services	Converting, matching, or running an order book
5	Lending and Borrowing Services	Facilitating or providing virtual asset loans
6	Virtual Asset Derivatives Services	Offering, executing, clearing or arranging derivatives
7	Management and Investment Services	Fiduciary management, discretionary staking
8	Transfer and Settlement Services	Moving assets between parties or wallets for customers
9	Issuance Services	Creating, issuing and administering virtual assets
10	Mining-related Services	Mining services to third parties involving customer assets

Which categories cover trading and market access?

Four categories cover trading and market access: Advisory Services, Broker-Dealer Services, Exchange Services and Virtual Asset Derivatives Services. A single trading venue will typically trigger several of these at once, and the licence under section 21(3) specifies which services the holder may undertake.

1. Advisory Services means the provision of personalised recommendations, on a professional basis, to a customer, either upon request or at the initiative of the provider, relating to one or more actions or transactions involving virtual assets.

The Schedule defines “personalised” precisely:

“The term ‘personalised’ refers to recommendations that are addressed to a specific customer and take into account (or are presented as taking into account) that customer’s individual circumstances, objectives, risk profile or financial situation. General market information, research reports or non-individualised suggestions do not constitute personalised recommendations.”

— Virtual Assets Act, 2026, Schedule I, item 1

Note “or are presented as taking into account”. A recommendation marketed as tailored is caught even if the tailoring is superficial.

2. Broker-Dealer Services means any of five activities: arranging or facilitating orders for the purchase and sale of virtual assets between two parties; soliciting or accepting orders and receiving consideration in fiat or virtual assets; trading virtual assets on the provider’s own account; market-making using customer assets; or providing placement or distribution services for issuers acting as intermediaries.

This category carries the Act’s clearest exemption, discussed below.

4. Exchange Services means any of: exchanging virtual assets for fiat currency; exchanging one or more types of virtual assets; matching orders between buyers and sellers and executing those conversions; or maintaining an order book for those purposes.

Maintaining an order book is a standalone trigger. A venue that matches but does not hold assets is still within the category.

6. Virtual Asset Derivatives Services means the offering, facilitation, execution, clearing, trading or arranging of transactions in derivatives, including futures, options, swaps and contracts for difference.

Which categories cover holding and moving assets?

Three categories cover the handling of customer assets: Custody and Administration Services, Transfer and Settlement Services, and Management and Investment Services. Each turns on whether the provider holds, controls or directs assets belonging to someone else.

3. Custody and Administration Services means the safekeeping or administration, on behalf of customers and pursuant to their instructions, of virtual assets, or of private cryptographic keys or other means of access that allow the customer to transfer or dispose of virtual assets independently.

The exclusion attached to this item is the most commercially significant in the Schedule and is dealt with in the next section.

7. Virtual Asset Management and Investment Services means acting in a fiduciary or agency capacity for the purpose of managing or administering another person’s virtual assets, including:

• Portfolio or discretionary investment management involving virtual assets
• Responsibility for staking on behalf of customers to earn validator or network rewards, provided that such staking is performed on a discretionary basis or forms part of a broader investment management mandate

The staking limb is conditional. Staking is not automatically a licensed activity — it is licensed where it is discretionary or sits inside an investment management mandate. Non-discretionary staking that the customer directs falls outside this wording, though it may engage custody if the provider controls the keys.

8. Virtual Asset Transfer and Settlement Services includes transfer, transmission or settlement of virtual assets between parties, or from one wallet, address or location to another, on behalf of customers, excluding exchange execution.

The exclusion of exchange execution prevents a venue from being licensed twice for the same act. The conversion is Exchange Services; the movement of assets for a customer outside that conversion is Transfer and Settlement.

Which categories cover lending, issuance and mining?

Three categories cover the remaining activity types: Lending and Borrowing Services, Issuance Services, and Mining-related Services. The last of these is the only category in the Schedule that is expressly narrowed by a section of the Act itself.

5. Lending and Borrowing Services means the facilitation, arrangement, intermediation or direct provision, as principal, of lending or borrowing arrangements involving virtual assets, where one or more lenders transfer, lend or make available virtual assets or rights to them to one or more borrowers, subject to a contractual obligation for the borrower to return equivalent virtual assets, together with any agreed interest, fees or rewards, at a specified time or upon demand.

The category catches both the intermediary and the principal. A platform that merely matches lenders and borrowers is within it, as is a business lending its own book.

9. Virtual Assets Issuance Services covers creation, issuance, initial offering, administration and ongoing management of virtual assets, including supply control, reserve management (if any), redemption, governance and required disclosures.

This category should be read alongside the definition of Issuer at section 3(1)(xiii), which turns on retaining primary control over initial supply, reserve assets or on-chain governance. The Explanation to that definition states that a person is not an Issuer solely because it markets, advertises, promotes, facilitates secondary-market trading, or provides technical development or maintenance services without control over issuance, supply or reserve assets.

10. Mining-related Virtual Asset Services includes activities where mining operations provide services to third parties involving customer virtual assets or funds. Pure mining for own account is excluded.

Section 37(2) restates this in the body of the Act: pure mining, by itself, does not constitute a virtual asset service requiring a licence under section 18 and Schedule I, but mining operations involving customer assets or funds shall be treated as virtual asset services and require licensing.

Section 37(3) adds a separate obligation that is not a licence. PVARA may establish a registration or declaration framework for mining operators exceeding thresholds of scale, energy use or hash rate, as set by Regulations. A miner may therefore be registrable while remaining unlicensable. Those thresholds have not been published.

What exemptions are written into Schedule I?

Three exemptions appear within the Schedule’s own definitions rather than in the general exclusions at section 2(2). Each is drafted conjunctively — every condition must hold — and each fails the moment customer assets or customer orders enter the arrangement.

The proprietary trading exemption (item 2). A person that deals solely on its own account, does not execute orders on behalf of customers, and does not hold or control customer assets is not regarded as carrying on broker-dealer services.

All three limbs must be satisfied. A proprietary trading firm that executes a single customer order, or takes control of a single customer’s assets, is outside the exemption.

The self-custody software exemption (item 3). Custody and Administration Services exclude “the mere provision of software, hardware or infrastructure that enables a customer to retain exclusive control over their own private keys.”

The word is exclusive. Any retained means of access — a recovery mechanism the provider can trigger, a co-signing key, an administrative override — is likely to defeat the exemption, because the customer no longer holds exclusive control.

The pure mining exemption (item 10 and section 37(2)). Mining for one’s own account is excluded. Providing mining services to third parties involving customer assets or funds is not.

Two further carve-outs sit nearby and are worth knowing even though they are not in the Schedule:

• The Issuer Explanation at section 3(1)(xiii), which protects marketers, promoters, secondary-market facilitators and technical service providers who lack control over issuance, supply or reserve assets.
• The six exclusions at section 2(2), covering closed-loop tokens, SBP- and SECP-regulated instruments, central bank digital currencies and certain non-fungible tokens.

How should you classify your own business?

The classification exercise turns on function, not label. Section 9(1)(f) empowers PVARA to assess, determine and classify any virtual asset, service, activity, offering, issuer or service provider based on its substantive features, underlying function, method of use or economic effect, irrespective of the nomenclature, structure or designation assigned to it.

That provision closes off structuring around terminology. It also means a self-classification that relies on how a product is described rather than what it does carries real risk.

In practice, the questions that resolve most cases are:

• Do you hold, or can you technically access, any customer virtual asset or private key? (Item 3)
• Do you accept orders, instructions or consideration from a third party? (Items 2, 4)
• Do you convert between assets, or between an asset and fiat, or match orders? (Item 4)
• Do you make recommendations that account for a specific person’s circumstances? (Item 1)
• Do you control initial supply, reserve assets or on-chain governance of a token? (Item 9)
• Do you exercise discretion over someone else’s assets? (Item 7)

Where the answer is genuinely unclear, section 35 provides a route. PVARA may operate a regulatory sandbox for controlled testing of innovative virtual asset products or services, and section 35(3) allows it to issue guidance, no-objection statements or no-action communications in accordance with Regulations.

One caution on the Schedule text itself. The description of item 6, Virtual Asset Derivatives Services, is incomplete in the published text available to us — it ends mid-clause after listing futures, options, swaps and contracts for difference. Anyone relying on the precise boundary of that category should check the Gazette text directly.

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 Schedule I and sections 18, 37 and 9(1)(f), 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.