The Three Things You Must Do After Receiving an NOC

Receiving a no-objection certificate (NOC) from PVARA is not the finish line. Regulation 15.3 of the PVARA No Objection Certificate Regulations 2025 lists exactly three things a successful Applicant must do once the NOC is issued, and none of them is optional.

This piece sets out each of the three, why the sequence runs in that order, and the three-month deadline that follows once VASP licensing Regulations are actually promulgated.

What three things does an Applicant have to do once PVARA issues an NOC?

Register the foreign entity already providing AML-Registered Services in Pakistan on the goAML portal; incorporate a local company; and submit the licensing application within three months of the VASP licensing Regulations being issued. Regulation 15.3 states this directly:

“Upon issuance of the NOC, the successful Applicant shall: (a) Register the foreign entity already providing AML Registered Services in Pakistan on the goAML portal; (b) Incorporate a local company as required under Section 15(1) of the Ordinance; and (c) Submit the licensing application, in the form prescribed by the Authority, within three months of the issuance of the VASP licensing regulations.”

Regulation 17.1, which governs PVARA’s decision on the NOC application itself, restates the same three steps as conditions attached to the grant — confirming that an NOC is issued together with these obligations, not as a standalone approval an Applicant can sit on indefinitely.

Step	What it requires
1. goAML registration	The foreign entity already providing AML-Registered Services registers as the FMU reporting entity
2. Local incorporation	A Pakistani company is incorporated to hold the eventual full licence
3. Licensing application	Filed within three months of PVARA’s VASP licensing Regulations being issued

Why does the NOC only cover a foreign entity’s registration, not the new Pakistani company?

Because of how the two-stage structure is built. Regulation 11.4 confirms this sequencing: “Following issuance of NOC by the Authority, the foreign Applicant (the applicants whose foreign chapter is already providing VASP services in Pakistan) shall register on the FMU goAML platform as the reporting entity for AML-Registered Services.” The foreign entity is the one already active in Pakistan at the point the NOC is granted, so it is the entity that registers first and carries reporting duties in the interim period before a local licensee exists.

Regulation 11.5 marks the handover point: once the Applicant incorporates its local entity and that entity is granted a licence, the local entity — not the foreign one — assumes the role of reporting entity on goAML and must maintain active reporting credentials at all times. The foreign entity’s registration is a bridge, not a permanent arrangement; our reading is that an Applicant should not treat the initial goAML registration as satisfying its longer-term obligations once the local entity is licensed.

How is the local company incorporation linked to the NOC?

Regulation 2.2 states that PVARA’s issuance of the NOC constitutes “permission for the Applicant to proceed with incorporation of its local entity in Pakistan” — meaning incorporation is not something an Applicant can start before the NOC is granted, at least not for the purpose these Regulations govern. Regulation 15.3(b) then makes incorporation a positive duty following NOC issuance, tying it to what it describes as “Section 15(1) of the Ordinance.”

Here a genuine ambiguity in the source material needs to be flagged rather than smoothed over. The NOC Regulations were issued under, and repeatedly cite, “the Virtual Assets Ordinance, 2025.” The Virtual Assets Act 2026, as passed by the National Assembly, is the successor instrument — section 74 of the Act confirms that anything validly done under the Ordinance is deemed done under “the corresponding provisions of this Act,” which necessarily implies the section numbering changed between the two instruments. The Act’s own licensing provisions on applying to incorporate with the primary objective of virtual asset services sit at section 19, not section 15, in the Act text reviewed for this analysis. In practice, this means an Applicant should treat “Section 15(1) of the Ordinance” as a reference to the pre-incorporation licensing step generally, and confirm the current, correct Act citation directly with PVARA rather than relying on the NOC Regulations’ Ordinance-era numbering.

What is the three-month deadline for the licensing application, and when does it start?

Three months, and the clock starts from “the issuance of the VASP licensing regulations” — not from the date the NOC itself was granted, and not from the date of local incorporation. Regulation 15.3(c) is explicit on the trigger event: “Submit the licensing application, in the form prescribed by the Authority, within three months of the issuance of the VASP licensing regulations.” Regulation 17.1(a)(iv) restates the same deadline using slightly different wording — “within three months of promulgation of VASP licensing regulations” — but the trigger is consistent across both: promulgation of a separate set of Regulations, not the NOC decision.

This matters because an Applicant that has already registered on goAML and incorporated locally could still be sitting well inside the three-month window if PVARA has not yet promulgated the licensing Regulations referred to here. Where those Regulations have not been issued at the time this analysis is prepared, that gap is stated rather than assumed — an Applicant should track the promulgation date directly with PVARA, since it is the date that starts the clock, not any date within the Applicant’s own control.

What can an Applicant do with an NOC before it has a full licence?

Provide AML-Registered Services once goAML registration is complete, and nothing beyond that scope. Regulation 2.3 designates four service categories as AML-Registered Services: Broker-Dealer Services, Custody Services, Exchange Services, and Virtual Asset Derivative Services. The same regulation confirms that “where an Applicant is granted AML Registration, the Applicant may provide AML-Registered Services prior to obtaining a license under Section 17 of the Ordinance, subject to the conditions imposed by the Authority.” Every other virtual asset service defined under the Act — advisory services, lending and borrowing, virtual asset management and investment services, transfer and settlement, issuance services, and mining-related services among them — “may only be provided following the grant of a full license under Section 17, unless otherwise agreed with PVARA,” per the same regulation.

An NOC holder offering, say, advisory or lending services on the strength of its NOC alone would be operating outside what Regulation 2.3 actually permits. The permitted window is narrow and service-specific, not a general licence to trade.

What happens if an Applicant does not progress toward a full licence?

Regulation 18.1(f) makes diligent progress toward a full VASP licence an ongoing obligation in its own right, not a one-off deadline: a registered Applicant must “apply for and progress diligently toward a full VASP License within the time period required by the Authority.” Regulation 19.1(e) then makes failure on that front an explicit ground for revocation — PVARA may revoke an Applicant’s NOC, including its AML Registration status, for “failure to apply for or progress toward obtaining a full VASP License within the prescribed period.” Regulation 19.2 notes that revocation is applied proportionately, “taking into account the severity and impact of the breach,” so a short delay and an indefinite failure to file are unlikely to be treated identically — but the Regulations give PVARA the power to revoke on this ground regardless of how far along the Applicant’s other compliance work has come.

About this analysis

This analysis was prepared by the CoinConnect research desk from the PVARA No Objection Certificate Regulations 2025 — principally Regulations 2.2, 2.3, 11.4, 11.5, 15.3, 17.1, 18.1 and 19.1 — read alongside section 74 of the Virtual Assets Act 2026, as published. Where the Regulations’ own references to Ordinance-era section numbers could not be confirmed against the Act’s current numbering, that is stated in the text above rather than assumed.

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.