Written by Malik Abbas, CEO of CoinConnect
TL;DR
- On 15 June 2026 PVARA published its draft Pakistan Virtual Asset Services Regulations, 2026 — and for the first time, Schedule I sets a minimum paid-up capital figure for every license category.
- Capital ranges from PKR 2.5 crore (~$90,000) for an Advisory license to PKR 1 billion (~$3.6 million) for an Exchange, stablecoin, or tokenised-asset issuer.
- Paid-up capital is not a fee. It is share capital you inject and hold inside your Pakistani company — separate from liquidity buffers and 100% token reserves.
- Regulation 7(5) lets PVARA grant a restricted license with reduced capital, in exchange for customer caps and product limits — the lean route for testing the market.
- These are draft figures open to a 7-day public consultation, so the numbers could move before they are finalized.
Table of Contents
- What are PVARA's capital requirements? (quick answer)
- The Schedule I capital table — every category
- What "minimum paid-up capital" actually means
- Capital by category: which figure applies to you
- The reduced-capital route: Regulation 7(5)
- Beyond paid-up capital: liquidity, reserves and add-ons
- What it costs if you stack multiple licenses
- How Pakistan compares with the UAE and Hong Kong
- Capital mistakes that delay or sink an application
- FAQ
What are PVARA's capital requirements? (quick answer)
PVARA capital requirements are the minimum paid-up share capital a company must inject and maintain to hold a Virtual Asset Service Provider (VASP) license in Pakistan. Under Schedule I of the draft Virtual Asset Services Regulations, 2026, the figure ranges from PKR 25 million (~$90,000) for advisory services to PKR 1 billion (~$3.6 million) for an exchange, set per license category.
That is the headline. The detail is where market-entry decisions are actually made — so let us go through it properly.
For most of 2025 and early 2026, the single most common question we received from global exchanges was simple: "What will it cost in capital?" Until yesterday, nobody could answer with a number, because PVARA had not published one. The draft regulations change that. This is the first English-language breakdown of those figures, written for the people who have to sign off on the budget.
Conversions in this guide use an indicative rate of PKR 278 = USD 1 (June 2026). Always confirm the live rate when modelling.
The Schedule I capital table — every category
The draft regulations create ten license categories (Regulation 4). Schedule I assigns a minimum paid-up capital figure to each. Here is the complete table, reproduced from the draft.
Numbers | License category | Minimum paid-up capital (PKR) | In crore | Approx. USD |
|---|---|---|---|---|
| 1 | Advisory Services | 25,000,000 | 2.5 crore | ~$90,000 |
| 2 | Broker-Dealer Services | 100,000,000 | 10 crore | ~$360,000 |
| 3 | Custody Services | 200,000,000 | 20 crore | ~$720,000 |
| 4 | Exchange Services | 1,000,000,000 | 100 crore | ~$3.6 million |
| 5 | Lending & Borrowing Services | 500,000,000 | 50 crore | ~$1.8 million |
| 6 | Virtual Asset Derivatives Services | 500,000,000 | 50 crore | ~$1.8 million |
| 7 | Management & Investment Services | 200,000,000 | 20 crore | ~$720,000 |
| 8 | Transfer & Settlement Services | 200,000,000 | 20 crore | ~$720,000 |
| 9 | Fiat-Referenced Token (stablecoin) Issuance | 1,000,000,000 | 100 crore | ~$3.6 million |
| 10 | Asset-Referenced Token (e.g. tokenised gold) Issuance | 1,000,000,000 | 100 crore | ~$3.6 million |
The anchoring obligation is Regulation 31(1):
"A Licensee shall, at all times, maintain minimum paid-up capital in accordance with Schedule-I to these Regulations and any applicable conditions of its License."
Note the phrase "at all times." This is not a one-off entry ticket. Your company must hold this capital continuously for the life of the license — a point we return to under ongoing prudential requirements.
What "minimum paid-up capital" actually means
This is the most misunderstood line item in the whole framework, so it is worth being precise.
Paid-up capital is share capital that shareholders have actually paid into the company. It is recorded on the balance sheet as equity, sits in the company's Pakistani bank account, and funds the business. It is not an application fee paid to the regulator, and it is not money that disappears. It remains your company's money — it simply has to be genuinely there.
The draft application form (Form II) requires applicants to attest to this directly, asking for confirmation that the company will "meet, and maintain on an ongoing basis, the minimum paid-up capital" under Schedule I and Regulation 31, and to provide "evidence of paid-up capital injected and maintained in the Applicant's bank account(s) in Pakistan."
Three consequences follow for a foreign exchange:
- You must first incorporate a Pakistani company. Regulation 5(1) is explicit that a VASP must be "a company incorporated under the Companies Act, 2017 … for the purpose of providing Virtual Asset Services." An offshore entity cannot hold the license, and therefore cannot hold the capital. Our corporate setup team handles this SECP step before any PVARA filing.
- The capital must be injected and verifiable in a Pakistani bank account — which means solving crypto banking access early, not late.
- It is separate from the application fee. As of June 2026 PVARA has not published a fee figure; Regulation 7(1) references a "non-refundable processing fee set out in Schedule II," but the draft leaves that schedule unquantified.
Capital by category: which figure applies to you
The right number depends entirely on what you actually do. A few practical reads of the table:
The lower tier — PKR 2.5 to 10 crore
Advisory (PKR 2.5 crore / ~$90,000) is the lowest barrier. If your Pakistan play is research, market intelligence or personalized recommendations — and you do not touch customer assets — this is the entry point. Broker-Dealer (PKR 10 crore / ~$360,000) covers dealing and arranging trades.
The mid tier — PKR 20 crore
Custody, Management & Investment, and Transfer & Settlement all sit at PKR 200 million (~$720,000). This tier matters enormously for remittance and payments businesses: a stablecoin-based cross-border payments suite is built primarily on a Transfer & Settlement license, not an exchange license. Firms often assume they need the PKR 1 billion exchange figure when their actual activity sits two tiers lower. Getting this classification right is the difference between a $720,000 and a $3.6 million capital plan.
The top tier — PKR 1 billion
Exchange Services and both token-issuance categories (stablecoins and asset-referenced tokens) require PKR 1 billion (~$3.6 million). This is the figure that gets quoted in headlines, and for a genuine order-matching exchange it is unavoidable at full scale. If you are weighing the full exchange route, our PVARA licensing service models the capital plan against your launch timeline.
The reduced-capital route: Regulation 7(5)
Here is the provision most foreign applicants miss — and the one that makes Pakistan viable for a lean market test.
Schedule I carries an express carve-out:
"The Authority may, under regulation 7(5), grant a restricted license with proportionate prudential requirements (including reduced minimum paid-up capital) subject to customer caps, product restrictions, and enhanced safeguards."
Regulation 7(5) itself provides:
"The Authority may grant a limited scope License where necessary to advance the primary objectives of the Act. The Authority shall specify the scope, duration, conditions, and exit criteria in such limited License."
In plain terms: you can apply for a restricted license with lower capital in exchange for accepting limits — caps on customer numbers, transaction volumes, product types or distribution channels. For token issuers, Regulation 34(11) creates a parallel restricted route with caps on outstanding supply and holder numbers.
This is the structurally sensible path for an exchange or issuer that wants to prove demand before committing PKR 1 billion. The draft does not publish the reduced figure — it is set case by case — but the legal door is explicitly open. We walk through the mechanics in our PVARA Sandbox walkthrough.
One caution: Regulation 7(6) states that "participation in a regulatory sandbox does not create an entitlement to a License." A restricted license is a real test, not a guaranteed graduation.
Beyond paid-up capital: liquidity, reserves and add-ons
Paid-up capital is the floor, not the ceiling. The draft imposes three further capital-adjacent obligations that belong in any honest budget.
1. Liquid financial resources (Regulation 32). Separate from share capital, you must hold a liquidity buffer:
"A Licensee shall maintain at all times adequate liquid financial resources to meet its obligations as they fall due, including during periods of stress."
2. 100% reserves for token issuers (Regulation 34). If you issue a stablecoin or asset-referenced token, reserves are non-negotiable:
"Reserve assets … shall be maintained at a level equal to one hundred percent (100%) of the Issuer's outstanding redemption liabilities at all times, and shall be held as a segregated reserve."
This sits on top of the PKR 1 billion paid-up capital — a critical modelling point for any stablecoin business.
3. Risk-based add-ons (Regulation 35). PVARA can require more. It may "require a Licensee to hold and maintain additional paid-up capital, liquid financial resources, insurance, or reserve assets," having regard to the size, complexity and geographic exposure of the business. Such add-ons must be reasoned and proportionate, but they are a real possibility for larger or cross-border operators.
What it costs if you stack multiple licenses
Many exchanges want more than one activity — say, exchange plus custody plus transfer. The draft does not simply add every figure together mechanically. Regulation 31(2) gives PVARA discretion to "specify … the methodology for determining the applicable minimum paid-up capital and any additional prudential add-ons" for multi-category licensees.
In practice, plan for the highest applicable category as your baseline, with the Authority empowered to layer add-ons for the additional risk each activity introduces. For a combined exchange-and-custody model, that means budgeting from PKR 1 billion upward — not PKR 1 billion plus PKR 200 million as a fixed sum. The exact methodology will be confirmed in licensing, so build a buffer into the financial model.
How Pakistan compares with the UAE and Hong Kong
For executives benchmarking jurisdictions, context helps. Pakistan's PKR 1 billion (~$3.6 million) exchange capital sits broadly in line with established regimes — Dubai's VARA and Hong Kong's SFC both impose substantial paid-up capital and ongoing liquid-capital requirements on licensed exchanges, typically in the low single-digit millions of US dollars plus liquidity buffers.
Where Pakistan currently differs is market maturity and cost base: a far lower operating cost, a large under-served user base, and — for now — no published license fee. The trade-off is regulatory newness. These are draft regulations under consultation, so the framework will keep evolving where the UAE and Hong Kong are settled. Pakistan is an emerging crypto market, and the capital bar reflects a regulator trying to signal seriousness without closing the door to entrants.
Capital mistakes that delay or sink an application
From the applications we see, the avoidable errors cluster around capital:
- Confusing capital with fees. Treating PKR 1 billion as money "spent" rather than equity held inside your own company leads to wildly wrong budgets and stalled board approvals.
- Misclassifying the activity. Applying for an exchange license when a Transfer & Settlement or Broker-Dealer license fits the actual business — and over-capitalizing by millions of dollars as a result.
- Forgetting the "at all times" rule. Injecting capital for the application, then letting it fall — a breach of Regulation 31 that can trigger suspension.
- Ignoring reserves. Token issuers budgeting paid-up capital but not the separate 100% segregated reserve under Regulation 34.
- Leaving banking to the end. Capital must sit verifiably in a Pakistani account; without banking access secured early, the whole timeline slips. See our note on crypto banking in Pakistan.
Get the classification and the capital plan right at the start, and the rest of the VASP licensing process becomes far more predictable.
Frequently asked questions
Under Schedule I of the draft Pakistan Virtual Asset Services Regulations, 2026, an Exchange Services licence requires minimum paid-up capital of PKR 1 billion (~$3.6 million). This is share capital held inside a Pakistani company, not a fee. A reduced figure may be available under a restricted licence (Regulation 7(5)).
No. Paid-up capital is equity your shareholders inject and the company holds on an ongoing basis. The license fee is a separate, non-refundable processing charge referenced in Regulation 7(1). As of June 2026, PVARA has not published the fee figure in the draft regulations.
The Advisory Services license has the lowest minimum paid-up capital at PKR 25 million (~$90,000), provided the firm gives recommendations only and does not hold customer assets.
A Fiat-Referenced Token (stablecoin) Issuance license requires PKR 1 billion (~$3.6 million) in paid-up capital — plus a separate 100% segregated reserve backing all outstanding tokens at all times, under Regulation 34.
Yes. Regulation 7(5) allows PVARA to grant a restricted, limited-scope license with reduced minimum paid-up capital, in exchange for customer caps, product restrictions and enhanced safeguards. The reduced amount is set case by case.
Not yet. They appear in the draft regulations published on 15 June 2026 for a 7-day public consultation. The figures could change before the regulations are finalised, so confirm the current position before committing capital.
No. Regulation 5(1) requires the licensee to be a company incorporated in Pakistan, and Form II requires the paid-up capital to be injected and verifiable in the company's Pakistani bank account. The capital cannot sit in an offshore parent.
Ready to model your PVARA capital plan against the right licence category? CoinConnect maps your business model to the correct Schedule I tier — so you budget for the licence you actually need, not the one the headlines quote. Book a free 30-minute discovery call →
Last reviewed: June 2026. Based on the draft Pakistan Virtual Asset Services Regulations, 2026, published for public consultation. Figures are subject to change pending finalisation.
External sources: PVARA · SECP · State Bank of Pakistan · FBR