Licensing

Who Sits on PVARA's Board and How It Decides

Sections 7 and 8 set out who sits on PVARA's governing body, how long they serve, and the quorum needed to make a valid decision. Here is the full breakdown.

Every licensing decision, every Regulation, every enforcement policy that PVARA issues traces back to a body defined in two short sections of the Virtual Assets Act, 2026. Sections 7 and 8 set out who that body is, how long its members serve, and what it takes for a meeting to produce a binding decision. For a business tracking how PVARA actually functions as an institution — not just what it regulates — this is the governance layer worth understanding precisely.

Who sits on the Authority under section 7?

Section 7(1) lists the Authority’s membership across eight lettered paragraphs, (a) through (h):

Seat Member
(a) Chairperson — appointed by the Federal Government
(b) The Secretary, Ministry of Finance
(c) The Secretary, Ministry of Law and Justice
(d) The Governor, State Bank of Pakistan
(e) The Chairperson, Securities and Exchange Commission of Pakistan
(f) The Chairman, National AML-CFT Authority
(g) The Chairperson, Pakistan Digital Authority
(h) Two independent directors, appointed by the Federal Government in the manner Prescribed

Read carefully, paragraph (h) supplies two people, not one. So while section 7(1) is structured as eight lettered items, the Authority as a body comprises nine individuals in total: the Chairperson, five ex-officio office-holders in paragraphs (b) through (g), and two independent directors under paragraph (h). Six of those nine seats — (b) through (g) — are ex-officio, meaning they are filled automatically by whoever holds the named public office at the time, rather than through a separate appointment process for the Authority specifically.

That mix is deliberate. It ties PVARA’s governing body directly to the State Bank of Pakistan, the Securities and Exchange Commission of Pakistan, the national AML-CFT authority, the Ministry of Finance, the Ministry of Law and Justice and the Pakistan Digital Authority, so that decisions affecting virtual asset service providers are made with those institutions represented in the room, not consulted separately afterward.

How long does a member serve?

Section 7(2) provides that “the members of the Authority, other than ex-officio members, shall hold office for a term of three years and shall be eligible for one further term of three years.” That rule applies to the Chairperson and the two independent directors — the members who are not simply filling a role by virtue of another office — giving them a maximum tenure of six years across two terms.

Ex-officio members have no fixed term under this section at all: their seat on the Authority runs for as long as they hold the underlying office (Secretary of Finance, Governor of the State Bank, and so on), and ends automatically when that underlying appointment ends. The Act does not need to separately term-limit these seats because they are tied to positions with their own succession rules.

What can the Authority decide on its own?

Section 7(3) gives the Authority real institutional independence on strategy and money: it “shall determine its own policy and strategic direction and approve its budget and Regulations.” This is a meaningful grant — it means the Authority’s Regulations, the instrument that fills in most of the operational detail the Act itself leaves open, are approved by this same nine-member body rather than requiring separate Federal Government sign-off on each one.

How often must the Authority meet, and who can call a meeting?

Section 8(1) sets a floor and a trigger mechanism: the Authority “may meet any time on requisition of the Chairperson or at requisition of at least fifty percent of the members,” and — the mandatory floor — “the Authority shall meet at least twice a year.” Below that minimum, a meeting can be called at any time either by the Chairperson alone or by any bloc representing half or more of the total membership.

What is the quorum, and does it matter who is in the room?

This is where section 8 gets specific in a way that matters for anyone whose business depends on a particular meeting actually producing a valid decision. Section 8(2) provides:

“The quorum of the Authority’s meeting shall be at fifty percent of the total membership with the mandatory presence of the (a) (b) and (d) as mentioned in section 7.”

Two conditions have to be satisfied together, not one or the other. First, at least half of the total membership must be present — on a nine-member Authority, that is a minimum of five people. Second, regardless of how many people that numerical half represents, three specific seats must be among them: (a) the Chairperson, (b) the Secretary, Ministry of Finance, and (d) the Governor, State Bank of Pakistan. A meeting attended by five members that does not include all three of those named seats does not meet quorum under the text, even though the headcount threshold is satisfied.

This is a deliberate design choice. It means no PVARA decision can be validly taken without the Chairperson, the Finance Ministry and the State Bank all being represented — the three institutions with the most direct stake in monetary policy, public finance and the Authority’s own leadership.

Who presides, and how are decisions actually made?

Section 8(3) provides that a meeting “shall be presided over by the Chairperson,” and where the Chairperson is absent, “a member nominated by the Chairperson shall preside over the meeting.” That nomination power sits with the Chairperson personally, not with the Authority as a body — there is no fallback mechanism in the text for who presides if the Chairperson is absent and has not made a nomination.

Section 8(4) then sets the decision rule: “all decisions in the meeting shall be made with majority of the present members.” This is a simple majority of whoever is actually in the room and counted for quorum — not a majority of the full nine-member Authority, and not a supermajority for any category of decision. A five-member quorum meeting, with the three mandatory seats present, can validly approve a Regulation, a budget, or a policy direction on a bare majority of those five.

Why does this level of detail matter to a licensee or applicant?

Because it tells you where real decision-making power sits, and what it takes to move a stalled matter forward. A few practical implications:

  • The Chairperson’s presence, or a properly nominated substitute, is not optional for quorum in the way most of the other seats are. Combined with the Finance Ministry and State Bank seats, this means three specific offices effectively hold a structural veto over any Authority meeting proceeding to a valid decision at all.
  • Regulations — the instrument that fills in most operational detail the Act itself leaves open, from capital requirements to reserve custodian standards — are approved by this same body under section 7(3). Delays in convening a quorate meeting can mean delays in the Regulations a business is waiting on.
  • The two independent directors are the only seats appointed specifically for sector expertise rather than by virtue of another government office. Section 7(1)(h) requires them to have “proven expertise and a strong track record possessing expertise relevant to Virtual Asset markets, digital technology, digital finance.” Who fills those two seats is worth watching as a signal of the Authority’s technical direction.
  • The minimum twice-a-year meeting cadence in section 8(1) is a floor, not a target. A business tracking when Regulations or policy changes are likely to emerge should not assume PVARA convenes only twice annually — the Chairperson or half the membership can call additional meetings at any time.

How does the Board relate to day-to-day licensing decisions?

Section 10 allows the Authority to delegate its powers and functions to the Managing Director, “subject to such terms, conditions, and limitations as it may deem appropriate.” In practice, this means routine licensing and supervisory decisions are unlikely to require a full nine-member Authority meeting each time — the Board-level quorum and voting rules in section 8 matter most for policy, Regulations, budget and other matters the Authority chooses to retain rather than delegate. Anyone submitting an NOC application or full licence application should expect day-to-day processing to run through delegated authority, with the full Board reserved for the matters section 7(3) assigns to it directly.

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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