VASP Minimum Capital in Pakistan: What the Act Requires

Every foreign exchange, custodian and broker looking at Pakistan asks the same question in the first meeting: how much capital do we need to put in? It is the question the finance committee needs answered before anything else moves.

The honest answer, read from the primary law as passed, is that the number does not yet exist in a public instrument. The Virtual Assets Act, 2026 creates a hard, continuing obligation to hold minimum capital — and then delegates the amount to Regulations that have not been published at the time of writing.

That is not a reason to wait. It is a reason to understand exactly what the statute binds you to, what the No Objection Certificate application already asks you to prove, and how to build a capital story that survives whatever figure lands.

What is the minimum capital for a VASP licence in Pakistan?

No specific figure is set in the Virtual Assets Act, 2026. Section 25 requires every Licensee to hold minimum paid-up capital, liquid assets and financial resources “not less than such amounts as may be prescribed” — meaning prescribed by Rules or Regulations. Until those Regulations are published, the amount is not fixed in public law.

Under section 3(1)(xxiii) of the Act, “Prescribed” means prescribed by Rules or Regulations made under the Act. Rules are made by the Federal Government under section 67; Regulations are made by the Authority, in consultation with the Division concerned, under section 68. So the capital number will arrive through one of those two channels, not through the Act itself.

Anyone quoting you a hard rupee or dollar figure for a PVARA licence today is either citing a draft, citing a comparable jurisdiction, or guessing. Ask which. Our own working note on PVARA capital requirements takes the same position.

What does section 25 of the Virtual Assets Act 2026 actually say?

Section 25 imposes a continuing, three-part financial resources duty and gives the Authority four levers over it: a floor, an uplift for riskier firms, add-on requirements such as liquidity and margin, and exemptions for low-risk or limited-scope licensees.

The operative language is short:

A Licensee shall, at all times, maintain such minimum paid-up capital, liquid assets and financial resources not less than such amounts as may be prescribed.

Three points deserve attention. First, the obligation is “at all times” — it is not a one-off gate at licensing. Second, it covers three distinct things: paid-up capital, liquid assets, and financial resources generally. Third, it sits alongside section 22(a), which lists among a Licensee’s ongoing obligations the duty to “maintain the prescribed minimum paid-up capital and financial resources”.

The remaining sub-sections give the Authority discretion:

Provision	What it allows
s.25(2)	Higher financial-resource requirements having regard to a Licensee’s category, size, complexity or risk profile
s.25(3)	Additional liquidity, margin, risk-based capital or reserve requirements by Regulations
s.25(4)	Conditional or risk-based exemptions for limited-scope or low-risk Licensees, in the manner prescribed

In practice this is a tiered regime in embryo. A custodian holding customer keys and an advisory-only firm should not expect the same number, and section 25(2) is the hook that lets the Authority differentiate. If you are still deciding which of the ten licence categories in Schedule I to apply for, that choice will drive your capital exposure.

Which capital figures are left to Regulations?

Almost all of them. The Act fixes the duty and the assessment factors; the Regulations will fix the amounts, the eligible instruments, the calculation method and the reporting frequency. The only quantified reserve obligation in the Act itself relates to token issuance, not to service provider capital.

Left to Regulations or Rules under the Act:

• the minimum paid-up capital amount, per licence category
• what counts as “liquid assets” and eligible financial resources
• any margin or risk-based capital add-on under section 25(3)
• the conditions for exemption under section 25(4)
• the definition of High-Quality Liquid Assets, which section 3(1)(x) leaves entirely to Regulations
• the intervals for cryptographic proof-of-reserves under section 27(1)
• fees, which section 9(2)(j) allows the Authority to levy as prescribed by Rules

That last item matters for budgeting. Section 19(4)(a) makes the licence application fee non-refundable unless the Authority determines otherwise, and section 22(f) requires payment of supervision, renewal and other fees on an ongoing basis. Fees are a separate line from capital, and both feed the Authority’s Fund under section 14(2)(h).

What must an applicant evidence at the NOC stage today?

Form A1 of the PVARA No Objection Certificate Regulations 2025 already requires a full financial submission at Section 8 — audited accounts or pro forma financials, the amount of paid-up capital with documentary evidence, external auditor details, and a narrative on the source of initial funding traced to Controllers and beneficial owners.

Section 8.2 of Form A1 is drafted conditionally. It asks the applicant to:

Provide details of how the Applicant meets any applicable minimum capital requirement, including: Amount of paid-up capital; Evidence of capital (bank statements, subscription agreements, etc.)

Read that phrase — “any applicable minimum capital requirement” — carefully. It anticipates a figure that may not yet apply to you. Our reading is that the Authority is, at this stage, testing whether the capital is real, traceable and adequate for your stated business model, rather than measuring it against a published threshold.

The full Section 8 package is:

Form A1 item	What is required
8.1	Latest audited financial statements, or management accounts / pro forma financials if newly incorporated
8.2	Amount of paid-up capital plus evidence — bank statements, subscription agreements
8.3	External auditor: firm name, address, contact person, email and phone
8.4	Description of how initial capital and funding were sourced, referencing Controllers and UBOs

Regulation 16.1(d) then lists “financial soundness of the Applicant” among the matters assessed for the NOC — and expressly contemplates that the same matters may be evaluated or re-evaluated at the subsequent licensing stage. So the financial file you build for the NOC is not a throwaway; it is the first draft of your licensing submission.

Does the capital duty apply before you hold a licence?

Section 25 binds a “Licensee”, defined in section 3(1)(xvi) of the Act as a person who holds a licence. On its face the statutory capital floor attaches on grant of the licence, not on grant of the NOC — but the Authority assesses financial soundness at NOC stage and may impose conditions.

This matters because of the phased pathway in the No Objection Certificate Regulations. Regulation 2.3 designates Broker-Dealer, Custody, Exchange and Virtual Asset Derivative Services as “AML Registered Services”, and provides that an applicant granted AML Registration “may provide AML-Registered Services prior to obtaining a license”, subject to conditions imposed by the Authority.

In practice, that creates a window in which a firm is operating under an NOC without a statutory capital floor biting. Do not read that as a free pass. Regulation 17.1 attaches conditions to the NOC, Regulation 18.1(f) requires the holder to progress diligently toward a full licence, and Regulation 19.1 permits revocation for breach. Thin capitalisation during that window is a supervisory conversation waiting to happen. We set out how the routes compare in our note on sandbox versus NOC versus full licence.

How is capital tested beyond the balance sheet?

Through three separate lenses: the entity’s own resources, the traceable source of wealth and funds of every Controller and beneficial owner, and the personal financial soundness of each Key Individual. A well-capitalised entity funded from an unexplained source will still fail.

Form A2 of the No Objection Certificate Regulations requires each Controller — anyone holding 20% or more of voting power or share capital under Regulation 7.1 — and each beneficial owner to give a full Source of Wealth narrative and a Source of Funds explanation for the specific money used to acquire ownership, with documentary evidence. Where funds originate offshore, the form requires “full details of jurisdiction, bank, and transfer pathway”.

Form A3 runs the same test at the individual level. Section 6 of that form asks every Key Individual whether they have been declared bankrupt or insolvent, entered debt restructuring, defaulted on a loan, or been subject to tax enforcement or penalties. Regulation 6.1 makes financial soundness an express limb of the fit and proper standard, and Regulation 6.3(c) disqualifies anyone subject to undischarged bankruptcy or insolvency proceedings. Our Form A3 walkthrough covers the disclosure traps.

Two further capital-adjacent obligations sit in the Act itself. Section 24 requires customer assets to be held in segregated accounts and, notwithstanding any other law, excludes them from the Licensee’s estate on insolvency — so customer assets are never your capital. Section 27 requires cryptographic proof-of-reserves reconciled against customer liabilities at prescribed intervals, plus an annual audit by a firm of Chartered Accountants approved by the Division concerned, verifying that segregation. That audit requirement is why Form A1 asks for your auditor at Section 8.3.

Are token reserves the same thing as capital?

No. Reserve backing for Fiat-Referenced and Asset-Referenced Tokens is a separate obligation on Issuers under sections 31 and 32 of the Act, and reserve assets do not substitute for a service provider’s own capital under section 25.

Section 31(1)(a) requires an Issuer of a Fiat-Referenced Token to hold “Hundred percent reserve backing, with High-Quality Liquid Assets (HQLA) or other assets as prescribed”, held as a segregated reserve. Section 3(1)(xxvi) defines a Segregated Reserve as a pool kept separate from the Issuer’s own assets, held under custody with an independent custodian or regulated financial institution approved by the Authority, “so that the Issuer or its creditors cannot claim the assets”.

For Asset-Referenced Tokens, section 32(2) requires full backing by the underlying assets at all times and prohibits backing by, or deriving value from, other Virtual Assets. We cover both in our analyses of stablecoin issuance and tokenised gold.

Can a smaller firm get a lower requirement?

Potentially, through three routes in the Act: risk-based exemptions under section 25(4), a provisional or limited-scope licence under section 21(2), or the regulatory sandbox under section 35. Each is discretionary and each is subject to conditions prescribed by the Authority.

The PVARA Sandbox Guidelines 2026 do not set a capital figure either. They list “Financial Strength” among the key evaluation criteria, requiring a “Demonstration of financial capacity to undertake the proposed business model”, and the self-assessment checklist at Annexure-A treats “Adequate financial and human resources to run a pilot” as a positive readiness indicator, with “Lack of technical or financial readiness” as a negative one. The undertaking at Annexure-B separately requires participants to obtain insurance coverage indemnifying clients against losses from fraud or gross negligence.

Note that the Sandbox Guidelines are drafted against the Virtual Assets Ordinance, 2025 and cite its section numbering. Section 74 of the Act preserves things done under the lapsed Ordinance. Our reading is that the sandbox provisions now sit at section 35 of the Act, but applicants should confirm the current position with the Authority. We discuss the practical trade-offs in our note on the sandbox and reduced capital.

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026, the PVARA No Objection Certificate Regulations and the PVARA Sandbox Guidelines 2026, 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.