Building the regulator before the rules

Dr Sardar Mohazzam
May 10, 2026

The market is already there. The regulator must now catch up with proper architecture




Building the regulator before the rules

Ali is a 26-year-old graphic designer in Lahore. His clients are located in Toronto, Dubai and California. When he completes a project, he does not wait two weeks for a wire transfer or surrender 10-12 percent in bank fees. His client sends USDT (a US dollar-backed digital currency) directly to his mobile wallet. Within the hour, he converts it to rupees through a peer-to-peer platform. The money lands in his U-paisa account, ready to pay rent, school fees and groceries. The cost of transaction is less than two percent.

Ali is not exceptional. He is one of millions of Pakistani freelancers and overseas workers who have quietly built their financial lives around digital assets. They are not motivated by speculation, but by necessity. Pakistan is currently the world’s third-largest crypto-adopting nation. The Alis of this country built that ranking without a single regulation to guide or protect them.

Pakistan Virtual Assets Regulatory Authority has been created to capture and formalise this opportunity. PVARA carries a genuine promise: to bring Ali’s transaction and the estimated $10 billion in similar informal crypto flows that move through Pakistan annually into a regulated, taxable and protected system that works for ordinary Pakistanis. Constituted under the Virtual Assets Act, 2026, it is backed by an Rs 800 million budget and led by young, energetic leaders. For PVARA getting the architecture right is among the most consequential economic policy tasks of the decade.

Chainalysis remarkably places Pakistan’s on-chain crypto value received at over $100 billion for the financial year ending June 2025. The gap reflects informal P2P flows, VPN-routed activity and USDT used for import settlement rather than retail trading. A 2025 CoinLaw survey identifies approximately 18.2 million verified users. The case is compelling: roughly 18 million verified users, growing at nearly three times year-over-year, driven by real economic need and entirely unregulated until now.

PVARA’s most structurally complex challenge is not technical; it is jurisdictional. The SBP governor and SECP chairman both sit on its 11-member governing board, acknowledging that virtual assets straddle monetary policy, securities law and an entirely new asset class. But board representation is not the same as operational clarity. A freelancer who receives USDT, converts to Bitcoin, holds a tokenised bond and remits via stablecoin in a single transaction chain has simultaneously engaged the SBP, the SECP, the FBR and the PVARA.

Without a formal jurisdictional map, a published MoU assigning primary regulatory responsibility by asset class and activity type, each institution hesitates and the regulated entity retreats to the informal channels all four are trying to eliminate. Pakistan’s banking sector, recently permitted to open accounts for licensed VASPs after a seven-year prohibition, is already signalling that it will not commit compliance infrastructure to a space where three supervisors can each claim authority and none accepts final accountability.

Pakistan receives $38.3 billion in formal annual remittances. Capturing even a fraction of informal crypto flows into the tax and regulatory net is a more immediate and politically defensible win than announcing sovereign Bitcoin reserves or mining megawatts. The global stable-coin architecture is consolidating around the US dollar. Tether processed over $1 trillion in monthly on-chain volume at its June 2025 peak.

America’s GENIUS Act is now encoding dollar primacy into stable-coin law. This is not a contest Pakistan can or should enter. Its sovereign opportunity is narrower and more achievable: formalising the estimated $10 billion in informal crypto remittance flows are already moving, already in stable-coins, already belonging to Pakistani workers abroad into PVARA-licensed, SBP-supervised channels.

Three imperatives stand above all others. First, establish a permanent HR framework with market-competitive pay before finalising a single licensing regulation — an institution staffed by rotating deputationists cannot build the technical memory that digital asset supervision demands.

Second, publish a binding inter-agency MoU between the PVARA, the SBP, the SECP and the FBR with a clear jurisdictional perimeter; without it, every bank, exchange and fin-tech startup will navigate three sets of conflicting signals. Third, make remittances the flagship use case, not mining, not Bitcoin reserves: because it aligns regulatory and commercial incentives; it is immediately measurable; and it is where Pakistani workers need the state to show up most urgently.

PVARA’s chairman is among the youngest heads of a regulatory authority in Pakistan. Youth brings the right instincts for this market. What must accompany it is the patience for institution-building which entails jurisdictional maps, HR regulations and inter-agency protocols to determine whether this authority outlasts its founding moment. The market is already there. The regulator must now catch up with proper architecture.

The writer, a policy expert and researcher of digital assets, is a former

managing director of the National Energy Efficiency and Conservation
Authority

Pakistan receives $38.3 billion in formal annual remittances. Capturing even a

fraction of informal crypto flows in the tax and regulatory net is a more immediate and politically defensible win than announcing sovereign Bitcoin reserves or mining megawatts.

Building the regulator before the rules