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It depends on whether it carries on business in or from Pakistan, in which case the Virtual Assets Act requires a Pakistani company holding a PVARA licence. Where the exchange is incorporated does not decide this. Targeting, soliciting or onboarding people here, through marketing, payment rails or rupee pricing, does. PVARA offers an NOC route to licensing and a sandbox for new products.

When virtual assets are transferred or settled for customers, which is its own PVARA licence category wherever the routing sits. The rupee leg is a separate State Bank matter. Collection and payout run through banks and SBP-authorised providers, and any rupee conversion is also governed by Pakistan’s Foreign Exchange Act, which the Virtual Assets Act does not override.

Yes, if the balance is not e-money, meaning stored value issued against funds and accepted as payment by parties other than the issuer. A balance usable only on the platform generally falls outside that. One that can be sent to other users or spent elsewhere does not. A wallet holding virtual assets is custody, a separate PVARA category.

Where the platform starts acting as the lender. Lending is for a licensed NBFC, and SECP’s rules require the NBFC’s name and licensing status on the app and a Key Fact Statement before disbursement. The test is applied to the product: whose name the borrower sees and whose terms apply, rather than what the contract says.

Foreign exchange comes first. Sending rupees abroad runs through authorised dealers, whatever the technology. Pakistan’s Foreign Exchange Act applies alongside the Virtual Assets Act, so foreign exchange approvals are separate from PVARA licensing. Whether a payment-systems licence is also needed depends on who collects and pays out the rupees.

It depends on what the token is and what it gives the holder. The Virtual Assets Act excludes securities within SECP’s jurisdiction, but its definition of a virtual asset appears to reach regulated assets issued on blockchain. PVARA classifies by substance and consults SECP or SBP where needed, so a token with investment-type rights should be assessed under both regimes.