Over the past year, Pakistan has started to shift away from old habits, such as paper-based records. Specific reforms show a pattern: financial regulations, corporate law, and land administration, each reformed to replace manual physical processes with digital ones. On the surface, these changes show mere technical regulatory updates. However, when viewed through a bigger lens, these represent a real shift in how ownership, transactions, and legal status will be recorded and proven in Pakistan.
These long-standing systems remained for an understandable reason. For decades, paper certificates and manually maintained registers were traditionally how things were done. An entire ecosystem of clerks, notaries, and informal verification grew and understood these regulatory systems. However, that exact reliance is what made forgery, duplication, and disputed ownership such persistent issues in Pakistani property, corporate, and financial markets. These three reforms, as will be discussed, although inherently different, are attempts to close that gap by using technology rather than more paperwork.
Here is the actual picture, and what it means for someone in Pakistan to own property, hold shares in a company, or be curious about how the country is finally approaching virtual assets (such as crypto).
A Regulator for Virtual Assets, Finally.
In the world, virtual assets have been the buzz since 2017-2020, with many people in Pakistan also making use of them. Nonetheless, virtual assets sat in an odd legal limbo in Pakistan: not quite banned, not regulated, and mostly left to informal exchanges and to the credence of “word-of-mouth”. According to Chainalysis’ 2025 Global Crypto Adoption Index, Pakistanis were the world’s third-largest market[1] for grassroots crypto adoption; conversely, at the time, almost entirely without any domestic legal framework to regulate the sector. The Virtual Assets Act, 2026, sought to remedy this issue; this created the Pakistan Virtual Assets Regulatory Authority (PVARA) as an autonomous federal body with exclusive jurisdiction over managing token offerings and virtual asset services within Pakistan.[2]
Simultaneously, traditional securities and derivatives stay with the State Bank of Pakistan (SBP), or the Securities and Exchange Commission of Pakistan (SECP), any future digital currency issued by the SBP, or by a foreign central bank stays out of PVARA’s ambit, and utility-based non-fungible tokens (NFTs), which are not used for payment or investment and not deriving value from an underlying security, are excluded too.[3] In the case of ambiguity in an issue and its ambit, the Act provides PVARA, SECP and SBP to evaluate a product jointly and classify it based on what it actually does, not its marketing.[4]
A two-fold process has been provided for setting up a virtual asset business in Pakistan. First, the requirement of a Non-Objection Certificate (NOC) from PVARA is required for promoters looking to set up a company, requiring a draft of the company’s constitutional documents and passing background checks on directors and controllers. Moreover, the NOC is only valid for a period of three months, with one possible three-month extension, which indicates the need for haste for anyone looking to set up a crypto exchange or custody service. Once a company has been incorporated, a second requirement follows, the license application carries real capital requirements to be attached: around Rs. 500 million to run an exchange and Rs. 200 million to offer custody services.[5] A barrier this large noticeably favours well-capitalised players over local startups, which means small domestic platforms would also face the same capital bar as a much larger entity aiming at a national or international market. This shows a risk of monopolising the current virtual asset sphere in Pakistan.
In the Act, importance has been given to experimental projects; PVARA has built a “regulatory sandbox” with a continuous application process rather than yearly windows. This provision allows for genuinely new blockchain-based products to be tested with real users for up to eighteen months under wider restrictions. To get into a sandbox regime at all, the project has to prove itself to PVARA; it needs to show that it’s doing something different with blockchain technology, bringing something beneficial and new to the market, and has a working prototype, not just an idea.[6] This effectively shows openness in Pakistani law to explore this market and an attempt to not limit creativity within it, which makes sense given how much potential virtual assets depict.
As for taxes in this area, there is no separate regime for Crypto Currency, virtual asset income and gains will remain regulated for taxes under the Income Tax Ordinance, and licensed platforms will still have to feed data into FBR’s monitoring systems.[7] For typical users, this means that any licensed Pakistani exchange used, will forward transaction data directly to FBR, prior to these updates, this market operated largely outside the tax system’s direct view.
Company’s Share Certificates Are going Digital, Whether You Like it or Not.
For those who hold shares in a Private Pakistani Company, it’s likely their ownership has, till now, existed as a paper in some file: susceptible to forgery, slow to transfer and easy to lose. Unlisted Companies incorporated after March 2025, have been required to issue shares only in electronic, book-entry form from day one, this will work directly through the SECP’s online portal (eZfile) which will work with the Central Depository System (CDC) to make accounts for founding shareholders.[8]
As for companies which existed prior to March 2025, more breathing space has been provided, however with an ultimatum. Under SRO 328(I)/2026, for the purposes of “day-to-day” business, the existing paper share registers have been allowed. However, for a company to effectively move around their share capital such as: transfers, gifting shares, new share issues, bonus shares, buybacks, and restructuring of capital, until every share has been converted from a physical share certificate to electronic, book-entry form, none of the operations as listed above can be practised.[9] Practically, the paper certificates have been left alone for routine operations, but any real transactions now force the company through digitization.
For the conversion process: the board would have to pass a resolution joining the depository system, the company’s share register has to be reconciled against every outstanding paper certificate, requirement for individual shareholders to open an account with the CDC (could be directly, or through a licensed brokerage), and lastly, the paper certificates would get surrendered, marked as “cancelled” and a digitized version would exist.[10]
For the ease of smaller companies, the SECP and CDC introduces a temporary relief package: the annual depository fee waived off, for the first year, for companies with modest paid-up capital (as per SRO 328 (I)/2026: up to Rs. 25 million), and conversion fees are waived until early 2027.[11] This relief provides a meaningful cushion for closely-held Pakistani companies which have never had to interact with the CDC, allowing a smooth transition into digitization. This is an absolute win for shareholders: a book-entry transfer happens instantly once processed, there is no longer need for executed transfer deeds to be lost, disputed or delayed.
Your Property Title Now has a Colour.
On 1st July 2026, an attempt at overhauling land records was made, and understandably the change remained unstable. The old “file” system, consisting of Transfer Letters or “Naqal Arazi Record”, relied upon by housing schemes for decades had many issues. The internal allotment and transfer letters held reliability only against a scheme’s own record-keeping ability. For that matter, disputes over double-sold plots and forged allotment letters were common, well-known problems for property buyers in Pakistani Housing Schemes. To cater to these issues, the Punjab Land Records Authority (PLRA) sought to digitize such records to fix exactly this.
To test the waters, the scheme was initiated in Sahiwal, Hafizabad, and Lodhran; this project fell under a World Bank-Funded initiative known as the “Punjab Urban Land Systems Enhancement (Pulse)” Project. The mandatory certificate system was initiated effectively in Sahiwal from 30th April 2026. On 22nd June 2026, a notification by the Board of Revenue gave effect to the regime in the rest of Punjab starting 1st July 2026, this suspended the traditional Fard.[12] The regime’s design was thorough, for a person to acquire a “Green” status on their property they would require: Biometric Identity Checks (through NADRA), confirmation of ownership chain, and officials would take physical field surveys which would use GPS-based measurements to confirm the property’s boundaries matching it to its legal description. Moreover, the verification is further backed by witness statements, and another government officer outside the land authority would have to sign-off.[13] On the other hand, a property may also attain the “Red” Status, which can occur if any dispute as to ownership, or possession is found during the verification. If a property does acquire the Red Status, it is reviewed by an Assistant Director (Operations), which may require the applicant to initiate a correction process. In the case where, after that review, the property has not corrected the dispute, it will not qualify for Green status and the Red Status will be confirmed with a Refusal Letter being issued alongside. Once a property is marked Red, it is effectively frozen and barred from all transactions thereby.[14] Additionally, before the certificate is issued and approved, it is displayed on the PLRA website with the option to raise a dispute, as to any objection to the determination of property status, within 15 days through the online portal. This means that a property may still face a fresh challenge despite clearing verification.[15]
As evident through the reporting on the rollout, the province wide roll-out did not go smoothly. Within about 10 Days of launch, the PLRA resumed issuing the old Fard, the reason being that many land records across Large Parts of Punjab simply were not digitized yet, so many citizens could not actually obtain the Green Certificate at all, despite its compulsion for transactions.[16] This move, which started as a practical workaround became a formal political matter on 27th August 2026, Lawmakers also raised concerns on the issue ranging from, allegedly, corruption within the Land Department[17] while others raised specific complaints that multiple people had appeared as registered owners of the same plot.[18]
Practically speaking, a few issues worth noting, the mandatory 15-day objection window has been provided with no evidentiary bar for filing an objection: which means any objection may automatically freeze a property’s transactional status the moment it is lodged, which makes this window theoretically open to any bad-faith or frivolous objections thereby. A few transitional questions which also remain unresolved: how would this system deal with transactions already pending before 1st July 2026, moreover, inheritance mutations pending on those dates, and the mechanism for overseas owners who act through Special Power of Attorney.
As of now, the traditional Fard remains the valid document for property transactions, whilst the Green/Red Property Certificate system remains on-hold for roughly Six Months. While this initiative does provide a smoother and more administrative platform for Property Transactions within Punjab, allowing an efficient way of maintaining and verifying ownership and property-based transactions, it still needs to be properly “phased” into the system, not just thrown in abruptly.
The Bigger Picture.
Despite these three reforms being in completely separate categories: financial regulations, corporate law, and land law, the pattern is obvious: Pakistan is trying to replace paper-based obsolete systems, often susceptible to being slow in process, forgeable, and hard to verify, with digital ones that may be faster, harder to fake, and easier to check in real time. What’s obvious is that these three efforts landed differently. While PVARA and CDC continue to operate functionally in their sectors, the Green/Red Certification Initiative went from piloting and province-wide launch to a six-month suspension just within two months of its launch, currently on hold without any certainty with what comes next.
However, this hiccup should not undercut the main goal. Duplicated or Disputed land ownership, Forged Share Allotments, and a whole unregulated crypto circuit were prevalent, longstanding issues relating to fraud and disputes in Pakistan, and it goes without saying the goal to dematerialize records into more regulated digital ones, surely has the potential to remedy these issues. The Green/Red Status certificate’s rickety release does not mean that digitalization is not the way to go, it just means that such a fundamental change needs to be eased into society gradually, and proportionately to how ready the current infrastructure is for such a change. For the practical legal dimension, evaluating these three reforms reveals that Pakistani Courts, for generations, have had a settled understanding of what a revenue record or a transfer deed actually proves in a dispute and have set guidelines/thresholds accordingly. These systems are yet to be tested in this sphere, but that would only be once they can actually move past the current infrastructure test.
[1] Chainalysis, ‘The 2025 Global Crypto Adoption Index’ (Chainalysis) https://www.chainalysis.com/blog/2025-global-crypto-adoption-index/ accessed 11 September 2026.
[2] Virtual Assets Act 2026 (Pakistan), s 2
[3] Virtual Assets Act 2026 (Pakistan), s 2(2).
[4] ibid s 17.
[5]Pakistan Virtual Asset Services Regulations 2026, reg 6 and sch I; Virtual Assets Act 2026 (Pakistan), s 19.
[6] Virtual Assets Act 2026 (Pakistan), s 35; PVARA Sandbox Guidelines 2026, ss 1-3, 9-10.
[7] Virtual Assets Act 2026 (Pakistan), s 66, read with Income Tax Ordinance 2001 (Pakistan).
[8] SRO 246(I)/2025 (Pakistan), 27 February 2025.
[9] SRO 328(1)/2026 (Pakistan), 19 February 2026.
[10] Companies Act 2017 (Pakistan), ss 70, 130, 183; Central Depositories Act 1997 (Pakistan), ss 3, 6
[11] SRO 328(1)/2026 (Pakistan), Annexure G
[12] Board of Revenue, Punjab (Land Revenue Branch), Notification No 976-2026/LR-IV (22 June 2026)
[13] Punjab Land Records Authority (Management of Land Records) Regulations 2025 (Notification No PLRA/BM/2810, 16 February 2026), regs 13, 15.
[14]ibid regs 5, 16(3)-(4), 17(1).
[15] ibid reg 18(1).
[16]https://pakobserver.net/green-property-certificate-scrapped-for-land-sale-purchase-in-punjab-heres-what-we-know/ accessed 11 September 2026.
[17]https://www.nation.com.pk/27-Aug-2026/punjab-suspends-green-certificate-six-months-amid-land-record-concerns accessed 11 September 2026.
[18] https://propakistani.pk/2026/08/28/punjab-suspends-digital-land-record-certificates-for-6-months/ accessed 11 September 2026.
