Getting a No-Objection Certificate and incorporating a company is only the first half of Pakistan’s virtual asset licensing process. The second gate is the licence application itself, governed by section 19(4) of the Virtual Assets Act 2026. It is a short provision, but it settles three things that matter to any applicant: when the application can be filed, what happens to the fee if things go wrong, and how far PVARA’s document requests can reach.
When can a virtual asset business file a full licence application?
Only after incorporation, not before. Section 19(4) states: “An application for a license, following incorporation of the company, shall be made to the Authority in such form and manner as may be prescribed.” The phrase “following incorporation of the company” is doing real work here — it fixes the licence application as the second of two sequential steps, coming after the pre-incorporation No-Objection Certificate required under section 19(1) to (3), not alongside it or before it.
This means a virtual asset service provider (VASP) cannot shortcut the process by filing for incorporation and a licence at the same time. The company has to exist first, with the ownership and governance structure that PVARA already reviewed and cleared at NOC stage, before the licence application itself is submitted.
What fee accompanies the application, and can it be refunded?
Section 19(4)(a) sets out the fee rule:
“the prescribed fee, which shall be non-refundable unless otherwise determined by the Authority”
The default position is that the licence application fee is lost regardless of outcome — a refusal does not entitle the applicant to a refund. The Act does not fix the fee amount itself; that is left to PVARA’s own prescribed schedule. What the Act does fix is the presumption of non-refundability, with a single carve-out: the Authority may determine otherwise, on terms the Act does not specify.
| Scenario | Default position under s.19(4)(a) |
|---|---|
| Application granted | Fee paid, non-refundable |
| Application refused | Fee paid, non-refundable, unless PVARA determines otherwise |
| Application withdrawn by applicant | Fee paid, non-refundable, unless PVARA determines otherwise |
In practice, our reading is that applicants should budget the licence application fee as a sunk cost from the outset, rather than treating it as contingent on a favourable outcome. The “unless otherwise determined” exception exists, but the Act gives PVARA discretion over when to apply it rather than setting out qualifying circumstances, and that discretion should not be relied on when pricing a market entry into Pakistan.
What information and documents can PVARA require?
Section 19(4)(b) is broad by design: the application “shall be accompanied by… such information and documents as may be prescribed or required by the Authority.” Two separate powers sit inside that clause. “Prescribed” documents are the standing requirements PVARA sets out in its own form and regulations. “Required” documents are whatever PVARA additionally asks for on a case-by-case basis during its review. The Act does not cap or itemise either category within section 19 itself.
The Act does, however, make clear elsewhere what a licence review is likely to test once the application is in. Section 20 requires PVARA to determine whether every Controller, Sponsor, chief executive officer and director is fit and proper, and extends that same standard to all Key Individuals — meaning documentation supporting fit and proper assessment for these individuals sits alongside whatever PVARA prescribes for the application form itself. Section 22 separately lists what a licensee must maintain on an ongoing basis once licensed — minimum paid-up capital, periodic returns, risk-management and compliance systems — and it is a reasonable inference, though not stated outright in section 19, that an applicant’s ability to meet these ongoing obligations is part of what a complete application needs to demonstrate.
A related instrument, PVARA’s No Objection Certificate Regulations 2025, sets out a detailed application form for the earlier NOC and AML-registration stage, covering governance, controllers, technology and financial resources in granular detail. Whether that same document list carries over unchanged to the section 19(4) licence application is not confirmed anywhere in the source material reviewed for this analysis — the Regulations address a distinct, earlier stage under the predecessor Ordinance’s numbering, and this analysis does not assume the two forms are identical. Until PVARA publishes licensing regulations specific to section 19(4), the precise document list for the licence application itself should be treated as unconfirmed and checked directly with the Authority.
How does the licence application differ from the NOC application?
The two applications sit at different points in the process and test different things.
- Timing. The No-Objection Certificate is filed before incorporation. The licence application is filed after incorporation.
- Purpose. The NOC clears the corporate structure to be created. The licence authorises the incorporated company to actually provide virtual asset services.
- Legal effect. An NOC is not itself a licence and does not authorise any commercial activity. A granted licence, under section 21(3), specifies the virtual asset services the holder is permitted to undertake.
- Fee treatment. Both applications carry a prescribed fee. Section 19(4)(a) states explicitly that the licence application fee is non-refundable by default; the Act does not state the same rule in equivalent terms for the NOC fee under section 19(2).
Treating the two as a single event risks under-preparing for the second, heavier review. The NOC assesses whether the proposed structure should be allowed to exist. The licence application assesses whether the company that now exists should be allowed to operate.
What happens to the application after it is filed?
Section 21(1) gives PVARA two outcomes: grant the licence, on such terms and conditions as it considers appropriate, or refuse it, providing written reasons. Section 21(2) adds a further option — a provisional or limited-scope licence, granted case by case, which is addressed in a separate analysis of its own. None of this decision-making is described in section 19(4) itself; it sits in the following section, and an applicant should not assume that submitting a complete application guarantees a specific timeline or outcome, since the Act does not fix a decision deadline for the licence stage in the way PVARA’s own Regulations have done for the earlier NOC stage.
For a foreign exchange operating into Pakistan or a domestic team preparing its first application, the practical takeaway is to treat the fee as committed on submission, prepare fit and proper documentation for every Key Individual and Controller well before filing, and confirm the current prescribed document list with PVARA directly rather than working from the NOC-stage form by assumption.
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 section 19(4), with cross-references to sections 20, 21 and 22 — and from PVARA’s No Objection Certificate Regulations 2025, 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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