The Virtual Assets Appellate Tribunal: Who Sits On It

Every regulator that can suspend a licence, freeze an account or refuse an application needs a body that can be asked to check that decision. Under the Virtual Assets Act 2026, that body is the Virtual Assets Appellate Tribunal, created by section 62 in Chapter 11 of the Act.

The Tribunal is not a court in the ordinary sense — it is a specialist forum staffed by people with regulatory, technical and financial backgrounds, and its decisions carry the force of a civil court’s decree. This article covers who sits on it, how long they serve, and what its existence means for a person or company that disagrees with an order of the Pakistan Virtual Asset Regulatory Authority (“PVARA” or “the Authority”). The mechanics of actually filing an appeal are covered separately.

What is the Virtual Assets Appellate Tribunal?

The Virtual Assets Appellate Tribunal is the body established under section 62 of the Virtual Assets Act 2026 to hear disputes arising under the Act, its Rules or its Regulations. Section 3(1)(xxx) of the Act defines “Tribunal” simply as “a Tribunal constituted under this Act” — the substantive detail sits in section 62 itself.

Section 62(1) states:

“A Virtual Assets Appellate Tribunal shall be established and no court shall take cognizance of a legal dispute under this Act or the Rules or Regulations made thereunder to which the jurisdiction of the Virtual Assets Appellate Tribunal extends.”

In practice, this means that for disputes falling within its remit, the Tribunal is not one option among several — it is the forum. An aggrieved party cannot go straight to a civil court and expect that court to hear the case; the Act removes that court’s jurisdiction over matters the Tribunal is empowered to decide.

Who sits on the Tribunal?

The Tribunal has three members: a presiding officer and two other members, one a technical expert and one a financial expert. Section 62(2) sets the qualifications for each of them, and all three must additionally have at least ten years of relevant professional experience.

Section 62(2) of the Act provides:

“The Virtual Assets Appellate Tribunal shall consist of a presiding officer, who shall be a person who is a retired Judge of a High Court, or an advocate having not less than ten years’ practice and experience in the relevant field, and two members, one being a technical expert and the other being a financial expert, who shall be Persons of ability, integrity, and have special knowledge and professional experience of not less than ten years in the fields of law, technology, finance, or economics.”

Breaking that down:

• The presiding officer must be either a retired High Court judge, or an advocate with at least ten years’ practice and experience in the relevant field.
• The technical member must have at least ten years of special knowledge and professional experience in law, technology, finance or economics — the Act does not narrow “technical expert” to any single discipline within that list.
• The financial member is held to the same ten-year standard, oriented toward financial expertise.

All three are additionally required to be “Persons of ability, integrity” — a general suitability requirement the Act does not further define, similar in spirit to the fit and proper standard PVARA applies to Key Individuals at licensed firms, though the Act does not say the two tests are the same.

How are Tribunal members appointed, and how long do they serve?

The presiding officer and the two members are appointed by the Federal Government, not by PVARA itself — a structural separation between the regulator whose orders are being appealed and the body appointing the people who hear those appeals. Section 62(3) sets the term of office:

“The presiding officer and members of the Virtual Assets Appellate Tribunal shall be appointed by the Federal Government, in the manner Prescribed by, and hold office for a period of three years and shall be eligible for re-appointment for a similar term or terms and shall cease to hold office on attaining the age of sixty years or the expiry of the term, whichever is earlier.”

So the base term is three years, renewable for further three-year terms, but subject to a hard retirement age of sixty. A presiding officer or member who turns sixty partway through a term ceases to hold office at that point, regardless of how much of the term remains — the Act sets whichever of the two limits, age or term expiry, arrives first.

What governs the detailed terms and conditions of appointment?

Section 62(4) states that “the terms, conditions, and appointment of the Virtual Assets Appellate Tribunal presiding officer and other members shall be in the manner Prescribed by the Federal Government.” This defers the operational detail — the appointment process, remuneration, removal procedure and similar matters — to Rules the Federal Government issues separately. As of this analysis, the Act itself does not set out that detail, and readers should check PVARA’s and the Federal Government’s published Rules before relying on any assumption about how the appointment process runs in practice.

Does the Tribunal remove ordinary courts from the picture entirely?

Not entirely, and not automatically. Section 62(1) only excludes the jurisdiction of ordinary courts over disputes “to which the jurisdiction of the Virtual Assets Appellate Tribunal extends” — meaning the ouster applies to the category of disputes the Act actually assigns to the Tribunal, not to every matter that happens to touch a virtual asset or a licensed virtual asset service provider. Section 63 is the provision that actually defines that scope — it gives any VASP, licence holder, or other aggrieved person a right to appeal an order of the Authority to the Tribunal. Beyond that category of appeals, the Act does not spell out an exhaustive list of what else falls within the Tribunal’s jurisdiction, and that is a point on which further guidance or case law may be needed before the boundary is entirely settled.

Once a matter is within the Tribunal’s jurisdiction, section 64(3) of the Act treats the Tribunal as a civil court for the purpose of deciding the appeal, with powers under the Code of Civil Procedure, 1908, and section 64(5) makes its determinations enforceable as decrees of a civil court. The next stage after that — a further appeal to the Supreme Court of Pakistan — sits in section 65.

Where does the Tribunal sit in the wider appeals process?

The Tribunal is the first stop for anyone contesting an order made by PVARA under the Act — whether that order refuses a no objection certificate, varies or revokes a licensing approval, or imposes an administrative sanction. A separate analysis covers how to actually bring that appeal — the filing window, the documents required, and the three-month deadline the Tribunal is held to when deciding a case — and a further analysis covers the final route to the Supreme Court of Pakistan for anyone still aggrieved after the Tribunal has ruled.

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act 2026, read as published, focusing on section 3(1)(xxx) and section 62(1)–(4). Where the Act defers detail to Rules the Federal Government has not yet published — including the precise appointment procedure under section 62(4) and the outer boundary of the Tribunal’s jurisdiction beyond section 63 — 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.