A poster advertising a token, a sponsored post from an influencer, a landing page collecting sign-ups for a launch — under Pakistani law, each of these counts as “marketing material” for a virtual asset. Section 43(2) of the Virtual Assets Act, 2026 attaches a specific duty to every one of them: the material must contain a risk disclosure. That duty sits alongside, but is separate from, the licensing gate in section 43(1), which restricts advertising of a virtual asset to cases where the issuer already holds a valid licence or registration.
What the risk disclosure must actually say, however, is not fixed by the Act itself. Section 43(2) hands that job to the Pakistan Virtual Asset Regulatory Authority (PVARA), the body established under the Act to license and supervise virtual asset service providers and issuers. Until PVARA issues the Regulations the section contemplates, anyone approving a crypto marketing campaign in Pakistan is working against a duty whose exact content has not yet been written down.
Does section 43(2) itself specify what a risk disclosure must contain?
No. Section 43(2) states:
“All marketing materials shall contain risk disclosures and shall comply with such conditions, standards and limitations, in such form and manner, as may be prescribed by the Authority.”
The provision creates the obligation and assigns PVARA the power to fill in its content — it does not itself list required wording, warning phrases, minimum font size or placement on the page. Anyone reading section 43(2) looking for a template will not find one there; the template is something PVARA is empowered, but not yet shown, to have issued.
Is there anything elsewhere in the Act that hints at what the disclosure regime will look like?
Yes, one useful cross-reference. Section 42(4) requires PVARA to prescribe, “by Regulations, mandatory risk disclosures, periodic reporting requirements and disclosure templates applicable to Issuers and Licensees.” That provision sits in the chapter dealing with issuer obligations rather than marketing conduct, but it points to the same underlying instrument: a set of disclosure templates that PVARA is required to produce, which will plausibly cover both an issuer’s ongoing disclosures and the risk-warning content that section 43(2) requires inside marketing material. In practice, we would expect a single disclosure framework to govern both, rather than two unconnected sets of PVARA-issued wording.
Section 42(1) and 42(2) add further context: an issuer offering a virtual asset to the public must publish a whitepaper “in such form and manner as may be prescribed by Regulations,” and must make ongoing disclosures of material information, “including reserve attestations,” at a frequency PVARA sets. None of this tells a marketer what to print on an advertisement today, but it shows that PVARA’s disclosure powers under the Act are consistently structured the same way: a duty stated in the Act, filled in later by Regulations.
Why does the disclosure duty attach to the marketing material rather than only to the issuer?
Section 43(2) reads “all marketing materials,” not “all issuers.” That is a deliberate structural choice consistent with the rest of section 43. Section 43(1) already gates the right to advertise a virtual asset to cases where the issuer is licensed; section 43(2) then imposes a separate, ongoing content standard on the material itself, wherever it appears and whoever places it. Read together, the two subsections suggest that an agency, a platform or an individual promoter handling a client’s marketing material carries a duty to check the material’s content, not merely to confirm the issuer’s licensing status once and move on.
This distinction matters for anyone running a market entry campaign into Pakistan. A licensed issuer’s marketing material can still fall short of section 43(2) if the risk disclosure is missing, generic, or buried where a reasonable reader would not see it. Licensing status under section 43(1) and disclosure adequacy under section 43(2) are two different tests, and a campaign has to pass both.
What happens if a marketing material carries no risk disclosure at all?
Section 43 does not carry its own standalone penalty clause, so exposure for a missing disclosure runs through the Act’s general enforcement provisions rather than a dedicated fine. Section 59(1) allows PVARA to impose administrative sanctions on any person found to have contravened the Act — a written reprimand or public censure, a directive to cease or remedy the conduct, a financial penalty up to the prescribed maximum, or suspension or revocation of a licence. Where the underlying material also relates to an unlicensed virtual asset service, section 61 gives PVARA power to direct the removal of the material itself, reaching hosting providers, app stores, search engines and advertising networks directly, not only the advertiser.
Our reading is that a defective disclosure on an otherwise properly licensed issuer’s material is more likely to draw a directive to fix the material than an immediate takedown, given the graduated sanctions list in section 59(1). But the Act gives PVARA the discretion to move straight to the harsher end of that list where it judges the omission serious enough, and nothing in the text guarantees a warning first.
What should a marketer include in a risk disclosure until PVARA’s Regulations are published?
Until the section 43(2) and section 42(4) Regulations are issued, no one can point to a definitive, PVARA-approved checklist. What can be done responsibly in the meantime is to build a disclosure that is unlikely to look thin against whatever standard eventually arrives, by drawing on the disclosure themes the Act already signals elsewhere:
- State plainly that the value of a virtual asset can fall to zero. This is the baseline warning implied by every capital-markets-style disclosure regime and is unlikely to be absent from PVARA’s eventual template.
- Name the issuer and its licensing or registration status, so a reader can independently verify the claim against the register PVARA is required to maintain and publish under section 21(4).
- Disclose whether the asset is a stablecoin-style token claiming a stable value, given the Act’s separate reserve-backing and redemption regime for fiat-referenced and asset-referenced tokens, and flag that redemption is not guaranteed to be instantaneous.
- Avoid return projections or comparisons to regulated financial products such as bank deposits, given the Act’s own definition of a virtual asset excludes securities and other regulated instruments precisely to keep the two categories distinct.
- Include a way for the recipient to check the material’s currency, since a disclosure written before the Regulations exist may need updating once PVARA issues its templates.
| Disclosure element | Basis for including it now | Status |
|---|---|---|
| Issuer’s name and licence status | Section 43(1) gate; section 21(4) public register | Reasonably certain |
| Capital-at-risk warning | Consistent with disclosure norms in comparable regimes | Reasonably certain |
| Reserve or redemption terms, if stable-value asset | Sections 31 and 32 reserve-backing regime | Likely relevant |
| Exact wording, font size, placement | Section 43(2) “form and manner” | Not yet prescribed |
| Mandatory template text | Section 42(4) disclosure templates | Not yet prescribed |
How should this shape a market entry plan today?
Anyone sequencing a Pakistan launch should treat the risk-disclosure duty as a live compliance item from day one of marketing, not an afterthought to be bolted on once PVARA’s form-and-manner Regulations appear. A campaign built on the assumption that a generic “cryptocurrency investments carry risk” line will satisfy section 43(2) is taking on avoidable exposure, given how directly section 61 lets PVARA reach the platforms carrying the material. Building disclosure review into the same sign-off process as the underlying licensing framework work — rather than leaving it to the marketing team alone — keeps the two section 43 tests moving together instead of one running ahead of the other.
Related reading
- PVARA Exchange License: Capital, Rules & Obligations 2026
- PVARA Transfer & Settlement License: Crypto Payments 2026
- PVARA Licensing Process: NOC to Full Licence, Step by Step
- The PVARA Licensing Gold Rush: Pakistan’s Crypto Frontier
About this analysis
This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act, 2026 as passed by the National Assembly, 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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