A no-objection certificate (NOC) from PVARA is often described loosely as a “green light” or a “first approval.” Regulation 15.4 of the PVARA No Objection Certificate Regulations 2025 says something more specific than either phrase, and the difference matters to anyone timing a Pakistan market entry.
This piece explains, in the Regulations’ own terms, exactly what an NOC does and does not satisfy — and flags a wording inconsistency in the source text worth checking before it is relied on.
What does a PVARA NOC legally satisfy?
An NOC satisfies the pre-incorporation regulatory clearance step and permits the Applicant to provide a defined set of AML-Registered Services — it does not, by itself, constitute a full VASP licence. Regulation 15.4 states this directly:
“The Authority’s grant of the NOC shall satisfy the pre-incorporation regulatory clearance required under Section 15 of the Act and shall permit the Applicant to provide AML-Registered Services in accordance with these Regulations.”
Two distinct legal effects follow from a single approval: a clearance function, which lets the Applicant move to the next stage of the process, and a permission function, which lets it begin trading in a narrow band of services while that next stage is under way.
Does the NOC itself grant a licence to operate?
No — not a general one. Regulation 2.2 defines the NOC’s constitutive effect in two parts: it “shall constitute (i) approval for the Applicant’s AML Registration on the goAML portal; and (ii) permission for the Applicant to proceed with incorporation of its local entity in Pakistan.” Neither of those two effects is a licence to provide virtual asset services generally. The first is an administrative approval tied to Financial Monitoring Unit (FMU) registration; the second is permission to take the next procedural step — incorporating a company — rather than authorisation of any business activity in itself.
| What the NOC does | What the NOC does not do |
|---|---|
| Constitutes pre-incorporation regulatory clearance | Grant a full VASP licence |
| Approves AML Registration on the goAML portal | Authorise every Schedule I virtual asset service |
| Permits proceeding with local incorporation | Substitute for the licensing application that must still follow |
| Permits AML-Registered Services once goAML registration is complete | Remove the three-month deadline to file for a full licence |
What is “AML Registration” and why is it distinct from a VASP licence?
AML Registration is the goAML portal registration PVARA approves through the NOC, and it operates as a separate regulatory status from a full licence under the Act. Regulation 2.3 designates a specific, limited set of virtual asset services as “AML Registered Services” — Broker-Dealer Services, Custody Services, Exchange Services, and Virtual Asset Derivative Services — and describes them as “non-financial businesses and professions” for FMU goAML registration purposes. 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.”
In practice, our reading is that AML Registration functions as a supervised interim status: it puts the Applicant inside PVARA’s anti-money laundering and counter-terrorist financing oversight and inside FMU’s reporting system before the company has met the fuller set of prudential, governance and capital requirements a full licence carries.
Which services can an NOC holder actually provide before full licensing?
Only the four AML-Registered Services named in Regulation 2.3: Broker-Dealer, Custody, Exchange, and Virtual Asset Derivative Services. Regulation 2.3 is explicit that “all other Virtual Asset Services defined under the Ordinance not otherwise constituted as an AML Registered Service may only be provided following the grant of a full license under Section 17, unless otherwise agreed with PVARA.” Advisory services, lending and borrowing, virtual asset management and investment services, transfer and settlement services, issuance services, and mining-related services all fall outside the four named categories and therefore outside what an NOC alone permits.
This scope limit is why Regulation 15.4’s second clause reads as a permission, not a blanket authorisation — the NOC “shall permit the Applicant to provide AML-Registered Services in accordance with these Regulations,” a phrase anchored to the defined term rather than to virtual asset services generally.
Why do the Regulations describe the NOC as “pre-incorporation clearance”?
Because of where it sits in the sequence the Regulations set up. Section 19(1) of the Virtual Assets Act 2026 requires any person intending to incorporate a company with the primary objective of engaging in virtual asset services to “first apply to the Authority for a No-Objection Certificate before commencing the process of such incorporation.” The NOC exists specifically to clear that pre-incorporation gate — PVARA reviewing an Applicant’s suitability before a Pakistani company is even formed, rather than after. Describing the NOC’s effect as “pre-incorporation regulatory clearance” in Regulation 15.4 reflects that ordering directly: clearance comes first, incorporation follows, and the full licensing application comes after that.
Is there any inconsistency in how the Regulations describe the NOC’s legal basis?
Yes, and it is worth flagging rather than glossing over. Regulation 2.2 states that the NOC is “required under Section 15 of the Ordinance.” Regulation 15.4 states that the NOC “shall satisfy the pre-incorporation regulatory clearance required under Section 15 of the Act.” The same numbered provision — section 15 — is attributed in one place to “the Ordinance” and in another, a few pages later in the same document, to “the Act.” The Virtual Assets Act 2026, as passed by the National Assembly, uses different section numbers for its licensing provisions: the pre-incorporation NOC requirement sits at section 19 in the Act text reviewed for this analysis, not section 15. Section 15 of the Act, as passed, concerns the Pakistan Virtual Asset Regulatory Authority Fund — an unrelated provision.
Our reading is that both Regulation references were drafted against the predecessor Virtual Assets Ordinance, 2025, and were not fully updated when the Act superseded it — section 74 of the Act itself confirms that Ordinance-era actions carry over to “the corresponding provisions of this Act,” which implies renumbering happened without every cross-reference in subordinate instruments being corrected. An Applicant relying on either citation should verify the current section number directly with PVARA rather than treating “Section 15” as settled by either version of this text.
Why does the phased NOC-to-licence structure exist at all?
Because the Regulations’ own stated objectives point to a deliberate trade-off between market access and supervisory readiness, not an administrative accident. Regulation 3.1(g) lists as an explicit objective “to facilitate a phased regulatory pathway whereby AML-Registered Services may be provided once registration has been completed and the NOC has been issued, and prior to full licensing under the Ordinance.” Read against Regulation 3.1(f) — “prevent unregistered and non-compliant VASPs from operating in Pakistan” — the two objectives sit together deliberately: the phased pathway lets a foreign entity already active in Pakistan bring its AML-Registered Services under PVARA and FMU oversight quickly, rather than leaving it unregulated for the months a full licensing review would otherwise take, while the fuller prudential, governance and capital review that only a full licence involves is completed in parallel.
An Applicant should treat this as the underlying logic behind every limit discussed above: the NOC’s narrow service scope, the three-month filing deadline, and the fitness-and-propriety review that can be repeated at the licensing stage are not separate rules by accident — they are the mechanism through which PVARA extends limited market access without extending the full trust a licence represents.
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 and 15.4 — read alongside section 19 of the Virtual Assets Act 2026 as passed by the National Assembly. Where the two source documents cite the same provision under different instrument names, that inconsistency is stated in the text above rather than resolved by assumption.
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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