JOINT STAFF WORKING DOCUMENT The EU Special Incentive Arrangement for Sustainable Development and Good Governance ('GSP+') assessment of Pakistan covering the period 2018 - 2019 Accompanying the document Joint Report to the European Parliament and the Council Report on the Generalised Scheme of Preferences covering the period 2018-2019
Date: 2020-02-10
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: EU market, Pakistan, common commercial policy, development aid, generalised preferences, human rights, international convention, sustainable development, tariff preference

EN 

  EN 

   EUROPEAN COMMISSION HIGH REPRESENTATIVE OF THE UNION FOR FOREIGN AFFAIRS AND SECURITY POLICY Brussels, 10.2.2020  SWD(2020) 22 final  JOINT STAFF WORKING DOCUMENT  The EU Special Incentive Arrangement for Sustainable Development and Good Governance ('GSP+') assessment of Pakistan covering the period 2018 - 2019 Accompanying the document Joint Report to the European Parliament and the Council Report on the Generalised Scheme of Preferences covering the period 2018-2019 {JOIN(2020) 3 final} - {SWD(2020) 16 final} - {SWD(2020) 17 final} - {SWD(2020) 18 final} - {SWD(2020) 19 final} - {SWD(2020) 20 final} - {SWD(2020) 21 final} - {SWD(2020) 23 final} - {SWD(2020) 24 final} - {SWD(2020) 25 final}  
 
 
Pakistan  

1. Summary Assessment 

Pakistan was granted GSP+ in 2014 and has shown commitment to maintaining ratifications 
and  meeting  reporting  obligations  to  the  United  Nations  Treaty  Bodies  for  the  27  UN 
Conventions. 

A new Government came into office in August 2018 on an agenda of economic growth, job 
creation,  and  fighting  corruption  and  climate  change.  The  Government  has  shown  a  keen 
interest  in  maintaining  GSP+  for  its  economic  and  trade  benefits,  notably  at  the  time  of 
requesting  and  implementing  an  International  Monetary  Fund  (IMF)  loan  programme.  It  is 
also interested in the GSP+ arrangement as an incentive to sustainable development and good 
governance.    

When  it  comes  to  effective  implementation,  Pakistan  is  making  some  progress  on  adopting 
laws  on  the  protection  of  women  and  children  rights;  elimination  of  honour  killings; 
protection of transgender persons; protection of the environment; and good governance. In the 
fight on drugs, Pakistan leads a UN initiative on education and was removed from the list of 
cannabis  resin  production  countries.  The  launch  of  a  national  Child  Labour  Survey  is 
important and implementation of the National Action Plan on Human Rights has started. The 
jurisdiction  over  civilians  of  military  courts  ended  as  the  Parliament  did  not  approve  its 
extension in March 2019.  

However,  salient  draft  legislation  on  enforced  disappearances  and  labour  rights  has  not 
progressed. An Anti-Torture Bill (2019) was submitted in the parliament but decision-making 
is  delayed.  The  trend  is  negative  when  it  comes  to  space  for  civil  society  and  voices  of 
dissent, with a high level of impunity for perpetrators of crimes against journalists. The broad 
and vague grounds for cancellation of the registration of 20 (of which 17 appealed) out of 144 
international non-governmental organisations (INGOs) remains a serious concern. The drive 
against  corruption  is  high  on  the  agenda  of  the  government  and  while  the  National 
Accountability Bureau is claiming to work independently, it is being widely criticised by the 
opposition political parties for being mostly active against their leaderships. 

Positive are the institutional and capacity development of the Ministry of Human Rights, the 
Treaty Implementation Cells (TICs), and Human Rights provincial departments, as well as the 
cooperation  with  stakeholders.  The  Ministry  of  Human  Rights  has  begun  to  establish  the 
Human  Rights  Information  Management  System  (HRIMS)  in  cooperation  with  United 
Nations  Development  Programme  (UNDP)  and  in  consultation  with  the  Office  of  the  High 
Commissioner of Human Rights (OHCHR). This will strengthen the data collection for Treaty 
Bodies and GSP+ reporting. The Ministry of Human Rights’ intention to establish a National 
Mechanism for Reporting and Follow up (NMRF) and to implement the OHCHR guidelines 
for  Treaty  Reporting  Monitoring  and  follow  up  mechanisms  are  positive  steps.  A  public 
announcement to this effect would be welcome.  

With  support  from  the  EU,  the  Ministry  of  Human  Rights  is  leading  a  national  awareness 
raising  campaign  on  women's  and  children's  rights.  However,  to  be  effective  it  will  require 
sustained political focus combined with the necessary resources.  

1 

 
 
 
Of concern is the status of the National Commission for Human Rights (NCHR). The tenure 
of the Commissioners expired in May 2019 and new commissioners are yet to be appointed1, 
which is hampering the operation of the institution. 

Other challenges to the implementation and enforcement of the UN Treaty Body Obligations 
include: (i) the devolved provincial powers (18th amendment to the Constitution of Pakistan); 
(ii)  limited  institutional  coordination  andlack  of  institutional  capacity,  scarce  human  and 
financial resources; and (iii) overriding army and security (counter-terrorism) concerns.  

Priorities 

A GSP+ monitoring mission took place in October 2018 and concluded with priority areas for 
action. These include, among others, actions in the area of freedom of expression, prevention 
of torture; reducing the scope for the death penalty and simplifying the procedure for granting 
mercy  petitions;  domestic  violence;  forced,  bonded,  and  child  labour;  labour  inspection; 
freedom  of  association;  anti-money-laundering; 
the 
establishment  of  a  Truth  and  Reconciliation  Committee  for  victims  of  enforced 
disappearances.  

interfaith  dialogue  policy;  and 

Human Rights 

The enactment of the Transgender Persons (Protection of Rights) Act in 2018, represents 
an  important  milestone  in  defending  the  rights  of  transgender  people  as  equal  citizens.  The 
Act  acknowledges  the  right  of  transgender  people  to  self-identify  according  to  their  self-
perceived  gender  identity  and  forbids  discrimination  in  employment,  housing,  education, 
health,  and  harassment.  The  Federal  Government  has  finalised  the  Domestic  Violence 
(Prevention  and  Protection)  Bill,  2019.  Senate  passed  the  Child  Marriage  Restraint  Bill, 
2019.  The  passing  of the  Zainab  Alert,  Response  and  Recovery  Act,  2019  in  response  to 
continual reporting of sexual assault incidents against children is another positive step.  

The  National  Commission  for  Human  Rights  has  formulated  Policy  Guidelines  for  the 
protection  of  human  rights  defenders.  These  have  been  endorsed  by  the  parliament.  The 
Federal Government has drafted the Journalist Welfare and Protection Bill in 2019 and has 
active  consultations  and  discussions  on  addressing  enforced  disappearance  and  secret 
detention. Passing and enacting the Bill would be a strong signal of Pakistan’s commitment to 
international  standards  and  human  rights.  A  hot  line  for  journalists  under  threat  has  been 
installed so journalists can inform the government of any potential or actual threat.  

Concerning cooperation with the UN, the invitation to Pakistan of the Special Rapporteur 
on the Right to Food is a positive step. Moreover, the capacity building activities carried out 
in the past  years with the Office of the High Commissioner of Human Rights (OHCHR), to 
the  benefit  of  both  National  Commission  on  Human  Rights  (NCHR)  and  National 
Commission on the Status of Women (NCSW) and the legislature are welcome developments. 
This should be sustained and expanded to the police and the judiciary.     

There has been a serious deterioration of media freedom in Pakistan, a trendthat began in the 
lead  up  to  the  general  election  in  2018..  A  draft  proposal  by  the  government  to  establish 
media  tribunals  has  not  been  pursued.  Materialisation  of  these  tribunals  would  be  a 
worrisome development. National security is widely used as a  pretext for cracking down on 
freedom of expression. The increasing pressure by security forces, with the tacit approval of 

1 At time of writing (October 2019). 

2 

 
 
                                                 
the government, on those with dissenting views, including media representatives and human 
rights  defenders,  is  worrying.  Critical  opinions  of  the  armed  forces  are  especially  taboo,  as 
well as topics considered to be of high security and strategic interest, e.g. the China-Pakistan 
Economic Corridor (CPEC). Intimidation tactics are diverse, sometimes extending to family 
members and in the case of media often lead to self-censorship by journalists and publishers 
to be able to continue to function.  

The  regulatory  framework  for  INGOs  registration  continues  to  be  broad  and  vague,  with 
reasons for rejection of registration not clearly provided to the concerned INGOs and remains 
a  matter  of  concern.  This  impacts  civil  space  more  generally,  also  having  an  impact  on  the 
(I)NGOs allowed to remain in the country. Seventeen INGOs filed appeals before the Special 
Committee  headed  by  the  Minister  for  Interior  and  with  Secretaries  of  the  Ministries  of 
Interior,  Foreign  Affairs,  Economic  Affairs  Division,  Additional  Secretaries  of  Interior  and 
Law and Justice Division as members. Some appeals are now in the court of law.  

Proper  investigation  and  prosecution  of  cases  of  intimidation,  abduction,  and  killing  of 
human  rights  defenders,  lawyers,  and  journalists  is  necessary.  The  Federal  and  Provincial 
governments  have  taken  actions  to  sensitise  police  and  other  law  enforcement  agencies  to 
accord  top  priority  to  such  cases  but  no  details  have  been  provided  on  actual  cases  of 
investigation  or  prosecution  as  of  yet.  In  an  attempt  to  address  the  issue  of  the  misuse  of 
Blasphemy  law,  the  procedure  to  file  a  case  against  blasphemy  was  reviewed.  Now  only  a 
District Police Chief shall investigate in order to establish a blasphemy case. The impact this 
reform has on addressing miscarriages of justice for those accused of blasphemy remains to 
be demonstrated.   

The  definition  of  most  serious  crimes  for  which  death  sentences  may  be  imposed  is  not 
aligned  with  international  standards  and  the  International  Covenant  on  Civil  and  Political 
Rights (ICCPR). Pakistan has started examining the existing provisions of the Penal Code and 
the Criminal Procedural Code to determine if the scope of the death penalty can be narrowed 
down in line with the ICCPR. Although the implicit justification for resuming executions has 
been  to  deter  terrorism,  most  of  those  executed  were  convicted  for  non-terrorism  related 
crimes. A reinstatement of the moratorium on executions is not considered, but the number of 
executions  continues  to  decrease2.  The  government  has  also  carried  out  a  review  of  the 
procedural constraints and flaws in the system of mercy petitions.  The option of enhancing 
the  duration  of  the  life  sentence  is  also  under  consideration.  Pakistan  has  promulgated 
‘Pakistan  Penal  Code  (Amendment)  Ordinance  2019’  on  July  12,  2019,  dealing  with 
exclusion of punishment of death for people extradited to Pakistan.  

Pakistan’s legislation falls short of a law specifically defining torture and fails to explicitly 
criminalise torture as required under the Convention Against Torture (CAT). A draft Torture 
and Custodial Death Bill (2019) has been presented to the Senate.  

In  the  second  cycle  of  the  Universal  Periodic  Review  in  2012,  Pakistan  accepted  the 
recommendation  to  criminalise  enforced  disappearances.  The  Human  Rights  Committee 
repeated the recommendation in 2017. The previous National Commission on Human Rights 
published  a  report  on  enforced  disappearances  in  February  2019,  recommending  the 
establishment of a Truth and Reconciliation Commission to enquire transparently into the 
cases  of  enforced  disappearances.  To  date  there  have  been  no  prosecutions  for  enforced 
disappearance  or  extrajudicial  killing.  Despite  the  publicly  expressed  position  of  elected 

2 From 66 in 2017 to 13 in 2019 (January-September) 

3 

 
 
                                                 
representatives  of  the  government  and  active  consultations  and  discussions  on  the  matter, 
there is no progress in this area. 

Labour Rights 

Pakistan  hasa  very  weak  labour  inspectorate  system  and  systematic  disregard  exists  of 
freedom of association and collective bargaining 

All provinces and Federal Capital have initiated Child Labour Surveys and a national report 
is  expected.  In  addition,  Provincial  Governments  have  enforced  different  laws  to  ensure 
proper investigations and prosecutions of child and forced labour incidences.  

Provincial  laws  on  minimum  age  of  work  and  hazardous  occupations  exist.  However,  there 
are  no  plans  for  adopting  a  comprehensive  child  labour  law3,  which  should  cover  child 
domestic  workers  and  prohibition  for  children  under  18  to  engage  in  hazardous  work, 
including  in  brick  kilns.  Enforcement  of  provincial  laws  and  proper  investigations  and 
prosecutions  of  child  and  forced  labour  remains  a  concern.  In  2018-2019,  inspections  in 
Punjab  and  Khyber  Pakhtunkhwa  led  to  several  hundred  arrests  and  prosecutions.  On  the 
other hand, in the Khyber Pakhtunkhwa the enforcement of the law prohibiting debt bondage 
in the formal sector is based entirely on a complaint system4. In 2018, only one complaint was 
received. 

Concerns over the capacity of the labour inspection system, and the low number of labour 
inspectors persist. According to the authorities, the provincial governments regularly carry out 
inspections and take appropriate legal actions on the incidences of violation of law. However, 
while the number of provincial inspectors is increasing, it remains low relative to the number 
of enterprises.  

Following  discussion,  the  Government  of  the  Punjab  reversed  its  prior  decision  to  abolish 
Labour Inspections in the province and committed to launch a third party inspection in future. 
Modalities  for  this  are  under  consideration.  If  carried  out,  such  a  decision  would  be  a 
worrisome development. Pakistan ratified the Convention on Labour Inspection, 1947 (No 81) 
in  1953.  The  Government  of  Pakistan  states  that  the  Labour  Department  of  the  Punjab 
Government categorically stated that the ILO conventions are being fully adhered to in letter 
and spirit and dispelled the impression of abolition in Punjab.  

Another  priority  area  is  the  adoption  and  implementation  of  the  Occupational  Safety  and 
Health  Risk  (OSH)  legislation.  The  Federal  and  Provincial  Governments  are  working  on 
Bills  on  OSH  to  improve  the  legislation,  without  concrete  outcomes.  A  new  model  OSH 
legislation, developed by the Federal government, is still not adopted in all provinces.   

The  ILO  supervisory  bodies  have  repeatedly  requested  Pakistan  to  align  labour  legislation 
with the fundamental Convention 87 on freedom of association and to extend its applicability 
to  Export  Processing  Zones  (EPZs)  and  Special  Economic  Zones  (SEZs).  In  addition, 
Pakistan needs to bring its legislation in line with the Convention 98 to ensure, among others, 
that all categories of workers enjoy the rights under the Convention. It is noted that law in the 
EPZs  prohibits  trade  unions  and  strikes5.  The  Ministry  of  Industries  has  initiated  a 
consultative process with the Ministries of Commerce, Human Resources Development, and 
Human Rights for amendment in the draft Employment of Service Control Rule 2009 with the 

3 https://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID:3327224:NO 
4  According  to  The  Khyber  Pakhtunkhwa  Bonded  Labour  System  (Abolition)  Act,  2015,  Section  3;  bonded 
labour is absolutely prohibited in the province. 
5 https://epza.gov.pk/production-oriented-labour-laws/  

4 

 
 
                                                 
idea  to  implement  the  remaining  provisions  and  bring  them  in  line  with  our  international 
obligation under the various ILO Conventions. 

Environment 

Pakistan's  efforts  to  implement  the  environmental  conventions  have  improved.  Climate 
change is a priority for the Government. With legislative measures largely in place, Pakistan 
now looks towards strengthening institutions to achieve a sustained level  of implementation 
of  the  conventions.  Besides,  Pakistan  has  actively  participated  in  regional  initiatives  such 
SAWEN  (South  Asia  Wildlife  Enforcement  Network  -  a  regional  initiative  for  wildlife). 
There  is  a  growing  awareness  with  regard  to  the  effective  implementation  of  these 
conventions  among  civil  society  organisations.  The  Ministry  of  Climate  Change  and  other 
departments including Forest departments, as well as Pakistan Customs, have improved their 
vigilance to combat illegal trafficking of wildlife.  

Good Governance 

In  the  area  of  drug  control,  Pakistan  continues  to  face  a  multitude  of  challenges.  Pakistan’s 
Anti-Narcotics  Force  has  taken  stricter  measures  to  apprehend  drug  traffickers,  especially 
around  education  institutions,  and  making  significant  seizures.  Further  efforts  are  needed  to 
seal the routes for smuggling and enhance cooperation within the region.   

Efforts to strengthen the anti-corruption framework include enhancing capacity. As for the 
Accountability  drive,  the  Government  must  give  more  confidence  and  autonomy  to  the 
National Accountability Bureau, which should follow Accountability for All in its actions. At 
present,  it  is  widely  being  criticised  for  partiality  by  mostly  taking  up  cases  against  the 
opposition parties.  

Several strategic deficiencies have been identified in the regime for the prevention of money 
laundering  and  terrorist  financing,  leading  to  Pakistan’s  inclusion  on  the  grey  list  of  the 
Financial  Action  Task  Force  (FATF)  in  2018  and  consequently  on  the  EU  list  of  high  risk 
third countries6. Pakistan has made a high-level political commitment in June 2018 to address 
these  deficiencies  by  the  implementation  of  an  FATF  Action  Plan.  The  FATF  plenary  in 
October  2019  granted  an  extension  period  for  the  implementation  of  outstanding  FATF 
commitments of Pakistan until February 2020. 

Status of ratification and reporting 

Pakistan  maintains  ratification  of  relevant  international  conventions.  Pakistan  has  improved 
its reporting compliance. Reports are due for three environmental conventions (Convention on 
Biological  Diversity  (CBD),  United  Nations  Framework  Convention  on  Climate  Change 
(UNFCC), and Stockholm Convention on Persistent Organic Pollutants.  

Several  treaty  bodies  have  adopted  written  follow  up  procedures  as  part  of  the  review  and 
engagement  process.  Pakistan  has  followed  up  its  reporting  obligations  for  Convention 
against  Torture  (CAT)  and  Convention  on  the  Elimination  of  All  Forms  of  Racial 
Discrimination  (CERD) in  May 2019 and November 2018, respectively  and has fulfilled its 
outstanding  follow  up  reporting  obligations  for  the  Covenant  on  Civil  and  Political  Rights 
(CCPR) and the International Covenant on Economic Social and Cultural Rights (ICESCR). 

6 see Commission Delegated Regulation (EU) 2018/1467 of 27 July 2018 amending Delegated Regulation (EU) 
2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards 
adding Pakistan to the table in point I of the Annex 

5 

 
 
                                                 
2.  Recent Developments 

The opportunities and obligations deriving from the EU's engagement with Pakistan in GSP+ 
form an integral part of EU-Pakistan relations. The new EU-Pakistan Strategic Engagement 
Plan (SEP), signed on 25 June 2019, provides an overall framework of bilateral engagement 
and  prominently  addresses  GSP+  in  the  chapters  of  Democracy,  Rule  of  Law,  Good 
Governance,  and  Human  Rights,  as  well  as  Trade  and  Investment,  demonstrating  the 
crosscutting relevance of the scheme.  

In the same vein, the annual EU-Pakistan Joint Commission, together with its relevant Sub-
Groups  on  Human  Rights  and  on  Trade,  are  platforms  to  exchange  views  on  priorities  and 
issues  of  common  interest,  and  serve  as  an  important  mechanism  to  oversee  and  push  for 
progress  in  GSP+  implementation.  The  latest  such  consultations  took  place  in  November 
2019,  when  Pakistan  showed  willingness  to  pursue  reforms.  The  EU  welcomes  active 
engagement with relevant interlocutors in the Government in this regard.  

EU – Pakistan Bilateral Development Cooperation 

Pakistan is a major development partner of the European Union (EU). For the 2014-2020 
period,  the  amount  available  for  bilateral  cooperation  with  Pakistan  is  € 603  million, 
complemented  with  a  bilateral  investment  allocation  of  €  15  million.  EU-Pakistan 
cooperation priorities focus on: 

 

rural development (54% of the budget);  

  education and vocational training (31%); and  

  good governance, rule of law and human rights (15%). 

This  is  complemented  by  regional  and  thematic  programmes  related  to  human  rights, 
migration  and  displacement,  and  security.  EU  Development  Cooperation  supports 
Pakistan’s trade capacity and its compliance with core international conventions, notably 
on human rights. 

3. EU – Pakistan Trade and GSP 

According to the World Bank, Pakistan's economic growth is expected to decelerate in 2019 
and 2020, with a projected annual growth of around 3%. This follows a period of recovery in 
the period 2016-2018, which culminated in a 5.8% annual GDP growth in 2018.  

From 2008 to 2018, EU imports from Pakistan almost doubled from € 3.6 to € 6.8 billion. The 
growth of imports was particularly fast following the award of GSP+ to Pakistan in January 
2014, with a 30% increase of between 2014 and 2016. The growth of Pakistan exports to the 
EU have since slowed down, but the country continues to enjoy a trade surplus with the EU 
(€1.2  billion  in  2018).  The  EU  is  Pakistan's  first  export  destination  absorbing  over  a  third 
(34%)  of  Pakistan's  total  exports  to  the  world  in  2018,  followed  by  the  USA  (16%),  China 
(8%) and Afghanistan (5%). The EU is Pakistan's third largest source of imports, after China 
(23%) and the UAE (14%), accounting for around 9% of the total in 2018. 

6 

 
 
 
 
 
 
Pakistan  takes  part  in  economic  integration  efforts  within  the  South  Asian  Association  for 
Regional Cooperation (SAARC) and has trade agreements with China, Indonesia, Malaysia, 
and Sri Lanka. 

Figures 1-3 below describe Pakistan’s utilisation of GSP+ in the context of the EU's overall 
imports from Pakistan7. 

Figure 1: Imports to the EU 2016-2018 – GSP+ utilization rate 

Figure 2: Imports to the EU 2016-2018 by regime 

7 GSP-statistics only cover goods imported in the EU market, i.e. goods released for free circulation in the EU. 
The GSP statistics do not cover other EU-imports, like goods imported for the customs inward processing 
procedure or re-imports after the customs outward processing procedure 

7 

Pakistan - imports to the EU 2016-2018 (M€)201620172018trend 2016-2018Total imports6205.76592.86739.58.6%GSP+ eligible5783.36114.66097.85.4%GSP+ preferential5522.75877.75885.16.6%Utilisation rate95.5%96.1%96.5%1.1% 
 
 
 
 
 
 
 
                                                 
 
Figure 3: Product Diversification of GSP+ Preferential Imports, 2018 

Pakistan GSP imports to EU  

S-11b apparel and clothing

S-11a wool, etc.

S-08b leather

S20 furniture and toys

S-04b food preparations

S12a footwear

S8a raw hides and skins

0%

10%

20%

30%

40%

50%

60%

70%

80%

4. Compliance with GSP+ Obligations 

4.1  UN Human Rights Conventions  

Pakistan  has  made  noticeable  achievements  since  2014  as  a  GSP+  beneficiary.  Legal  and 
institutional  progress  has  taken  place  in  a  number  of  areas  covered,  and  the  country's 
reporting to the UN monitoring bodies has significantly improved. Notwithstanding positive 
measures  e.g.  in  women’s  rights,  children  rights,  and  transgender  persons'  rights, 
implementation remains generally slow with little impact.   

its 
The  Government  of  Pakistan  stated 
commitment  to  maintain  its  GSP+  eligibility. 
However,  political  will  needs  to  be  coupled  
for 
in 
with  determined  action 
reform, 
particular 
fundamental 
the  areas  of 
in 
freedoms,  as  well  as  labour  rights.  The 
deteriorating 
of 
expression,  including  the  misuse  of  cyber 
laws,  the  intimidation  of  media  practitioners, 
and  laws  discriminating  against  religious 
minorities remain elements of high concern.  

situation 

freedom 

of 

and 

for  Human  Rights 
the 

The  implementation  of  the  National  Action 
the 
Plan 
operationalisation 
National 
of 
Commission  on  Human  Rights  (NCHR) 
remains  incomplete.  The  previous  NCHR 
concluded its term in May 2019, and the new 
procedure  to  appoint  the  new  Commissioner 
is  delayed,  which  has  implications  on  the 
EU's cooperation on human rights. Moreover, 

8 

Promotion  of  Human  Rights  in 
Pakistan 

and 

assistance 

compliance  with  human 

This  is  the  main  European  Union  project 
supporting  Pakistan’s  efforts  to  improve 
its 
rights 
commitments.  The  aim  is  to  provide 
technical 
capacity 
development to key government ministries 
at  federal  and  provincial 
level,  with 
special focus on the criminal justice chain, 
to  strengthen  the  capacity  to  implement 
Pakistan's  own  human  rights  agenda,  and 
to raise public awareness, knowledge, and 
understanding of rights and how to protect 
them.  The  project  also  supports  Pakistan 
to  comply  with  its  obligations  under 
GSP+.  It  started  in  early  2019  for  a 
duration  of  36  months  and  with  a  budget 
of € 9.6 million. 

 
 
 
 
 
the constitution of the National Commission on the Rights of the Child also remains pending. 

The  federal  and  provincial  Treaty  Implementation  Cells  (TICs)  established  in  2015  by  the 
Government  of  Pakistan  are  dedicated  mechanisms  to  oversee  GSP+  implementation  across 
the country. Supervised by the Attorney-General including through regular visits, the system 
of  TICs  constitutes  the  national  framework  for  reporting  and  follow  up.  The  province  of 
Punjab has made important headway in monitoring and coordinating GSP+ implementation, 
while  other  TICs  continue  to  have  capacity  challenges.  The  TIC  in  Punjab  launched  a  web 
portal  in  September  2019,  to  inform  comprehensively  about  Human  Rights  obligations  in 
Pakistan  and  the  progress  made  under  GSP+.  This  is  a  significant  first  step  towards 
implementation of the right to information.   

With  support  from  the  EU,  the  Ministry  of  Human  Rights  is  leading  a  national  awareness 
raising  campaign  on  women's  and  children's  rights.  However,  to  be  effective  it  will  require 
sustained political focus combined with the necessary resources for follow up.  

The  main  challenge  for  the  next  monitoring  period  will  be  to  ensure  the  acceleration  of 
progress  across  the  whole  spectrum  of  GSP+  coverage,  supported  by  improved  and  reliable 
data and statistics.        

International  Convention  on  the  Elimination  of  All  Forms  of  Racial 
Discrimination (CERD) 

Despite the fact that the Constitution and laws of Pakistan do not provide a unified definition 
of racial discrimination, but only cover a narrow definition of religious minorities, the Penal 
Code provides sufficient guarantees for the protection of citizens. Due to a heavy backlog and 
other  structural  issues  in  the  judicial  system,  justice  delivery  remains  slow.  The 
implementation  of  the  Penal  Code  is  far  from  effective  as  exemplified  by  international 
rankings8.  Reports  relay  that  religious  minorities  in  Pakistan  continue  to  face  attacks  from 
extremist groups and society at large9. Misuse of the country’s strict blasphemy laws results 
in the suppression of rights for non-Muslims, Shias, and Ahmadis. 

In  2018  and  2019,  the  Government  has  taken  some  positive  steps  to  promote  religious 
freedom  and  combat  religiously  motivated  violence  and  hate  speech.  The  provinces  were 
directed  to  take  stringent  action  against  hate  speech.  Although  the  blasphemy  laws  remain 
unchanged, the Supreme Court 2018 judgment and subsequent release of Asia Bibi, and her 
safe departure from Pakistan were positive developments, although her lengthy imprisonment 
on  death  row  is  a  telling  evidence  of  the  worrying  state  of  the  criminal  justice  system,  as 
stated  by  the  Supreme  Court  in  its  judgment.  Following  her  release,  an  inter-ministerial 
committee on religious tolerance has been established and an action plan has been presented 
to the ministry of interior, which is yet to give its approval.  

The  EU’s  Special  Envoy  for  Freedom  of  Religion  or  Belief  outside  the  EU,  Mr.  Ján  Figeľ, 
visited  Pakistan  twice  during  the  reporting  period  and  delivered  messages  on  freedom  of 
religion or belief and interfaith harmony. During the second visit in May 2018, the EU also 
organised  a  roundtable,  which  presented  its  recommendations  to  the  Council  of  Islamic 
Ideology  (CII)10  and  the  Ministry  of  Religious  Affairs  and  Interfaith  Harmony.  Despite 
efforts,  the  interfaith  harmony  policy  could  not  yet  be  finalised.  The  consultation  with 

8 https://worldjusticeproject.org/our-work/wjp-rule-law-index/special-reports/rule-law-pakistan 
9 Reported by the Human Rights Commission of Pakistan in its 2018 report.  
10 CII is a constitutional body responsible for giving legal advice on religious affairs to the Government and the 
Parliament.  

9 

 
 
 
 
                                                 
provinces  has  been  ongoing  since  2015/2016  but  not  finalised  due  to  lack  of  consensus 
amongst the stakeholders.    

Despite legislation against forced marriages, there are still reports of forced conversions of 
Hindu women to Islam (including kidnapping), mostly among lower caste minor girls (mainly 
in Sindh). The Sindh Child Marriage Restraint Act 2013 has not been enforced effectively and 
the state’s response to forced marriages has been mixed.  

International Covenant on Civil and Political Rights (CCPR) 

Federally  Administered  Tribal  Areas  (FATA)  is  undergoing  a  substantial  reform  process 
towards democratisation. The jurisdictions of the Khyber Pakhtunkhwa (KP) High Court and 
the  Pakistan  Supreme  Court  were  extended  to  FATA  in  May  2018.  On  1  June  2018,  the 
President  of  Pakistan  promulgated  the  25th  amendment  of  the  Constitution  of  Pakistan  in 
order to  merge  FATA  and the province of Khyber Pakhtunkhwa  (KP).  In an unprecedented 
move, the Government and opposition in the National Assembly unanimously passed the 26th 
Constitutional  Amendment  Bill,  2019,  giving  more  representation  to  the  inhabitants  of 
former FATA  in the lower house of the federal Parliament and in the Khyber Pakhtunkhwa 
Assembly.  This  has  been  a  landmark  achievement  for  the  people  of  the  erstwhile  FATA. 
However, in August 2019, the government passed the Khyber Pakhtunkhwa Action (in Aid of 
civil  power)  Ordinance  2019,  which  strengthens  the  role  of  the  military  in  the  merged 
districts.  The  law,  which  would  give  armed  forces  power  to  detain  without  a  reason  and 
without  producing  the  accused  at  a  court  of  law,  is  of  serious  concern.  The  Peshawar  High 
Court  found  it  in  violation  of  the  constitution  in  October  2019;  however,  this  decision  has 
been suspended by the Supreme Court. 

Opposition  parties  continue  to  question  the  legitimacy  of  the  new  government  and  the 
transparency and fairness of the general elections in July 2018. The EU Election Observation 
Mission  made  a  critical  assessment  of  the  general  conduct  of  the  electoral  process,  the 
suppression  of  media  freedom,  and  civil  society  in  general,  and  noted  interference  of  the 
military in favour of a given party.  

During  the  reporting  period,  the  right  to  freedom  of  expression  continued  to  be  restricted 
despite the commitment of Pakistan in  its statement on the outcome  report of the Universal 
Periodic Review to ‘review and align the legislation with freedom of religion and belief and 
freedom  of  expression,  as  stipulated  in  the  International  Covenant  on  Civil  and  Political 
Rights (ICCPR).’ The Human Rights Commission of Pakistan observed that under the usual 
pretext  of  ‘national  security  concerns’,  the  restrictions  on  media  coverage  were  stepped  up, 
journalists  increasingly  took  to  self-censorship  to  evade  intimidation  and  threats,  cable 
operators  were  prohibited  from  broadcasting  certain  networks,  and  the  distribution  of  a 
national newspaper was severely curtailed.  

As for the death penalty, figures submitted by the Federal Ombudsman to the Supreme Court 
indicated that the number of executions is consistently decreasing since 2016. There are 4,688 
persons  on  death  row  and  511  have  been  executed  since  December  2014.  In  2019,  13 
prisoners  were  executed  which  shows  a  continued  decline  in  executions  in  recent  years;  in 
2018 the number of executed was 15, while in 2017 it was 66. A Justice Project Pakistan 2018 
report  found  that  a  special  appeal  bench,  formed  by  the  Supreme  Court  to  adjudicate  upon 
murder appeals,  had overturned 467 death  sentences in  546 appeals  (85%), since December 
2014. Furthermore, Pakistan has promulgated ‘Pakistan Penal Code (Amendment) Ordinance 
2019’ on July  12, 2019, excluding death  penalty for people extradited to Pakistan. Pakistan 

10 

 
 
 
 
 
 
 
has also started examining the existing provisions of the Penal Code and Criminal Procedural 
Code to determine if the scope of the death penalty can be narrowed to bring it in line with 
Article 6 of the ICCPR. 

After  the  ICCPR  review  in  July  2018,  the  Human  Rights  Committee  issued  22 
recommendations, which urged Pakistan to take steps to ensure that the rights in the covenant 
are in full effect; review and repeal certain sections of the Anti-Terrorism Act, 1997; limit the 
scope of the death penalty; and ensure that no person under 18 years of age when an offence 
occurred, or with any disability, was subjected to the death penalty.  

The  situation  pertaining  to  the  slow  registration  of  International  Non-governmental 
organisations  (INGOs)  and  rejection  on  vague  and  broad  grounds  remains  a  point  of 
concern since 2016. The current registration policy has led to a considerably restricted space 
for both  INGOs  and NGOs. (I)NGOs working in areas of human rights  and governance are 
particularly  affected,  with  decisions  denying  their  registration  on  security  grounds.  Many 
NGOs operating in ex-FATA or Baluchistan are facing difficulties due to the Government of 
Pakistan's  interpretation  and  application  of  the  Financial  Action  Task  Force  (FATF) 
requirements for measures countering terrorism financing and money laundering.   

International  Covenant  on  Economic,  Social  and  Cultural  Rights 
(CESCR) 

Pakistan  continues  to  face  difficulties  with  the  realisation  of  the  economic  and  social  rights 
enshrined in the International Covenant on Economic, Social and Cultural Rights (CESCR). 
The ability to succeed will largely depend on generating economic growth and channelling the 
revenues from this growth into investing in the welfare of the people, as well reprioritisation 
of  existing  budgets.  The  ruling  party  has  promised  to  create  10  million  jobs  and  build  5 
million  houses  for  the  poor  during  its  5  years  tenure.  When  it  comes  to  the  UN  tables  of 
poverty  and  malnutrition,  the  figures  are  sobering.  For  example,  half  of  the  children  are 
affected by stunting. 

A High Powered Committee was constituted in 2011 under the Chairmanship of the Minister 
for  Law  &  Justice.  The  Committee  was  mandated  to  look  into  the  issues  arising  out  of  the 
implementation  of the devolution  of powers from  federal  to  provincial  level,  because of the 
18th Amendment of the Constitution of Pakistan. With devolution, provincial governments are 
confronted with the bottlenecks in realising of social, cultural and economic rights, and with 
capacity issues.  

In  March  2019,  the  Prime  Minister  launched  the  Ehsaas  program,  a  wide  ranging  social 
protection and poverty alleviation program outlining four pillars and 115 policy areas to be 
implemented  through  20  Federal  Ministries,  six  Federal  Agencies  involved  in  poverty 
alleviation and social protection, and provincial governments, Azad Jammu and Kashmir and 
Gilgit-Baltistan.  The  four  pillars  include:  (1)  addressing  ‘elite  capture’  and  making  the 
government system work to create equality; (2) safety nets for disadvantaged segments of the 
population;  (3)  jobs  and  livelihoods;  and  (4)  human  capital  development.  The  EU  is  not 
directly supporting the Ehsaas initiative, but is cooperating with Pakistan to increase its social 
spending  (on  social  safety  nets)  under  its  Public  Finance  Management  (PFM)  Programme 
which  also  complements  ongoing  IMF  facility  for  Pakistan.  The  newly  created  Division  of 
Poverty Alleviation and Safety Nets is the coordinating agency of the  Ehsaas program. The 
first  Programme  called  Mazdoor-Ka-Ehsaas  (Programme  for  Labourers)  was  announced  by 
the  Prime  Minister  on  Labour  Day,  May  1,  2019  and  has  two  areas  of  policy  focus:  social 

11 

 
 
 
in 

the 

informal  sector  and  welfare  of  overseas  Pakistanis.  However, 
protection 
implementation  will  be  challenging,  especially  in  the  context  of  the  current  financial  and 
economic crisis. 

Convention on the Elimination of All Forms of Discrimination Against 
Women (CEDAW) 

The Government continued to give high priority to the situation for women and girls. This has 
resulted  in  new  legislation  and  policies  to  tackle  persistent  problems  and  in  some  instances 
seems  to  have  resulted in  improvements on the  ground. A  Federal Domestic  Violence Bill 
2019 was finalised by the Ministry of Human Rights and submitted for Cabinet approval.  

Women's  rights  in  Pakistan  fall  in  the  provincial  domain.  Punjab,  for  instance,  passed  the 
Punjab Protection of Women against Violence Act 2016. Its implementation has started. The 
Social Welfare and Bait-ul-Maal Department has established a first state-of-the-art Violence 
against  Women  Centre  (VAWC)  in  Multan  in  March  2017.  Punjab  also  established  its 
Commission on the Status of Women, mandated to monitor the mechanism and institutional 
procedure  for  redress  of  violation  of  women’s  rights.  Since  August  2017,  the  Commission 
registered  1057  complaints  through  its  Helpline;  of  these,  535  complaints  were  resolved, 
while 495 complaints were being processed. However, in 2019 the Violence against Women 
Centre  (VAWC)  faced  serious  funding  shortcuts  that  hamper  its  functionality.  Similarly, 
Baluchistan  has  introduced  a  set  of  legislation  and  policies  for  the  provision  of  rights  to 
women. The Provincial Commission on the Status of Women Bill 2017 was passed; the Law 
on Protection against Harassment of Women at  Workplace (Rules 2018) has been enforced; 
and Women Crisis Centres at Divisional level have been set up. The provincial Government is 
working on a Prohibition of Early Marriage Bill and an Anti-Acid and Rehabilitation Bill for 
women.  

Despite  these  positive  steps,  since  2017,  with  regard  to  legislation  and  sensitisation  on 
violence against women (police, judiciary and other stakeholders), women and girls continue 
to be exposed to serious and widespread human rights violations, including murder, violence, 
rape, forced marriage and forced conversion and discrimination in practically all fields of life. 
Pakistan  was  named  once  again  the  second  worst  country  (ranked  149)  in  terms  of  gender 
equality  in  the  world  by  the  Global  Gender  Gap  Index  2018.  Most  notably,  domestic  and 
sexual  violence  continues  to  prevail.  ‘Honour’  killings,  acid  attacks,  social  restrictions  on 
movement  and  jobs,  inequality  and  abject  poverty,  forced  and  arranged  marriages  depict  a 
grim  picture.  According  to  the  United  Nations  Population  Fund  (UNFPA),  the  UK 
Department  for  International  Development  (DFID),  and  the  Punjab  Bureau  of  Statistics 
survey  on  Generating  Data  on  Women's  Economic  and  Social  Wellbeing  in  Punjab,  one  in 
every 3 women aged between 15-64 years has suffered violence11. No such data exist for the 
other three provinces.  

In  terms  of  political  participation,  there  has  been  a  record  number  of  women  running  for 
National Assembly general seats in the 2018 election. Reports of higher women’s turnout in 
the elections and the appointment of the first female chief justice in a Pakistani high court are 
positive  developments.  Concerning  the  National  Commission  on  the  Status  of  Women 
(NCSW),  the  body's  Employees  Recruitment  and  Conditions  of  Service  Rules,  2019,  were 
approved  and  notified.  The  ongoing  appointment  process  for  Commissioner  should  be 

11 Punjab Commission on the Status of Women.  

12 

 
 
 
 
 
                                                 
accelerated.  The  process  of  constitution  of  the  National  Commission  on  the  Rights  of  the 
Child needs to be expedited as well.  

In 2018, the state responded to campaigns launched by the transgender community for the 
provision  of  transgender  rights  through  a  comprehensive  legislation,  with  an  enacted  law 
titled  ‘Transgender  Persons  (Protection  of  Rights)  Act,  2018’.  The  Act  acknowledges 
transgender persons’ right ‘to be recognized as per his or her self-perceived gender identity’, 
which  has  been  a  great  success  for  the  transgender  community  who  have,  over  the  years, 
endured  allegations  of  inauthenticity  and  fraud,  as  well  as  invasive  tests  and  procedures  to 
determine  their  gender.  The  Act  also  forbids  discrimination  in  employment,  housing, 
education,  health,  and  harassment.  Significantly,  it  specifies  harassment  ‘both  within  and 
outside  the  home’,  thus  enacting  protection  for  transgender  people  from  their  own  families. 
The  explicit  ensuring  of  the  rights  to  assembly  and  to  access  public  spaces,  combined  with 
anti-harassment,  provides  legal  protection  for  transgender  people  in  daily  public  life  and 
space. Furthermore, the Act ensures that transgender people have inheritance rights, and the 
right to vote, to hold public office, and to own property. The Ministry of Human Rights has 
set  up  a  committee  with  representatives  from  government,  civil  society,  the  transgender 
community, the NCHR and the NCSW to review progress of the implementation of the Act. 

Convention against Torture and other Cruel, Inhuman or Degrading 
Treatment or Punishment (CAT) 

The UN Committee on Torture (Committee) recommended in its 2018 review of Pakistan that 
the  Government  define  and  criminalise  torture,  as  well  as  take  adequate  action  to 
investigate complaints of torture. Pakistan's follow up report on the recommendations of the 
Convention against Torture (CAT) Committee was submitted in May 2019.  

Article  14(2)  of  the  Constitution  prohibits  torture  for  the  purpose  of  extracting  information, 
while provisions of the Pakistan Penal Code prohibit the infliction of ‘hurt’, and Police Order 
2002  makes  torture  by  police  officers  punishable  in  Punjab,  Sindh,  and  Baluchistan.  In 
Khyber  Pakhtunkhwa,  the  Police  Ordinance  2017  prohibits  police  officials  from  torturing. 
However,  Pakistan’s  legislation  falls  short  of  a  law  specifically  defining  torture  and  fails  to 
explicitly criminalise torture as required under Convention against Torture (CAT).  

Despite these laws, the police are known to use torture to coerce accused persons to confess, 
including by sleep deprivation, rolling heavy objects over the limbs of the accused, beatings 
with  leather  rackets,  exposure  to  heat,  etc.  Since  such  practices  are  an  inherent  part  of 
investigation by the police, and as the Pakistan authorities have executed persons whose death 
sentences  were  pronounced  partially  or  wholly  based  on  evidence  gathered  through  torture, 
Pakistan has disregarded some of the obligations under  International  Covenant  on Civil and 
Political Rights (ICCPR) such as the right to life. This situation continues to be exacerbated 
by Pakistan's failure to fulfil its obligations under Convention against Torture (CAT). 

The National Commission for Human Rights conducted a nationwide inquiry into torture. The 
Ministry of Human Rights has prepared a draft Torture, Custodial Death and Custodial Rape 
(Prevention  and  Punishment)  Bill  2018,  covering  police  forces,  but  not  military  or  security 
services. A private Member's Bill has been presented in the Senate, which will be vetted by 
the  Standing  Committee  on  Human  Rights  and  recommended  to  the  National  Assembly  for 
discussion if the Standing Committee raises no objection. Pakistan expressed its reservations 
with  regard  to  Individual  Complaints Procedure  under  Article  22  of  the  Convention  against 
Torture (CAT).    

13 

 
 
 
In several cases, torture inflicted by Police has been subject to reprimand. Different major and 
minor punishments were given, while the Committee of the CAT has stated that it does not 
have  sufficient  information  to  assess  their  proportionality.  In  Punjab,  268  constables,  300 
Head  constables,  363  Assistant  Sub  Inspectors,  240  Sub  Inspector,  104  Inspector,    and  six 
Deputy Superintendent Police have been punished for violations i.e. torture, death in custody, 
misuse of official power, misbehaviour, and illegal confinements12.  

Convention on the Rights of the Child (CRC) 

The government in 2018 promised to uphold children’s rights in the country. The Ministry of 
Human  Rights  showed  renewed  resolve  to  improve  the  situation  of  children’s  rights  in  the 
country through legislation, judicial reforms, awareness raising, and other practical measures.  

Although the judiciary and law enforcement agencies were seen to be more actively pursuing 
cases of crimes against children, the extent and severity of the violence against children and 
their exploitation remained worrying. Despite the promulgation of the National Commission 
on the Rights of the Child Act, 2017, the Commission is not yet functional.  

The Criminal Law (Second Amendment) Act, 2016 has been enacted to criminalise violence 
against  children  such  as  exposure  to  seduction,  cruelty  to  a  child,  child  sexual  abuse, 
trafficking  of  human  beings,  and  child  pornography.  The  Ministry  of  Human  Rights  has 
conducted post-sensitisation workshops.  

The  Juvenile  Justice  System  Act,  2018  focuses  on  disposal  of  cases  through  diversion  and 
social  reintegration  of  child  offenders.  For  this  purpose,  the  Government  plans  to  establish 
corrective institutions for social reintegration of children involved in crime.  

In  2018-2019,  The  Ministry  of  Human  Rights  implemented  a  project  titled  ‘Preventing 
violence  against  children’  with  the  support  of  South  Asian  Association  for  Regional 
Cooperation  (SAARC)  Development  Fund.  This  project  had  five  thematic  areas  including 
child  abuse,  child  trafficking,  early  child  marriages,  and  corporal  punishment.  Various 
training workshops were conducted to sensitise media professionals, public and private sector 
stakeholders.  

The Wafaqi Mohtasib (Federal Ombudsman) in 2013 appointed Commissioners for Children 
at federal and provincial levels to monitor and address the grievances suffered by children. 

Despite  these  measures,  violence  against  children  saw  no  respite  in  2018  and  2019, 
encompassing a broad spectrum of physically  and sexually exploitative acts.  Although each 
province  has  dedicated  child  protection  legislations,  very  few  victims  received  protection, 
counselling, and legal services.  

In 2018, in response to the tragic and violent death of a little girl, which received extensive 
media  attention  and  resulted  in  massive  riots,  the  government  drafted  the  Zainab  Alert 
Response and Recovery Bill 2019 and submitted it to Parliament. The bill will ensure setting 
up  the  Zainab  Alert,  Response  and  Recovery  Agency  (ZARRA),  where  missing  child  cases 
will be reported and it will generate an automatic alert. The bill will also introduce response 

12 Data for other provinces are not available.  

14 

 
 
 
 
 
 
 
 
 
 
                                                 
and  recovery  mechanism  of  missing  children  to  prevent  acts  of  sexual  violence  against 
children. It is promising to see that the harsh punishment included in the draft Bill against the 
perpetrators such as death penalty and life imprisonment without parole have been excluded 
in  its  final  version.  This  case  also  led  to  the  formation  of  a  Committee  on  Children  by  the 
Federal  Ombudsman  to  conduct  an  analysis  of  child  abuse  in  the  country.  The  ensuing 
report released by the task force in October 2018 proposed short and long term measures to 
counter  the  rising  sexual  violence  against  children  in  the  country.  The  report  revealed  that 
Punjab was the most vulnerable province where  1089 cases of  child sexual  violence, out  of 
4,139 in the entire country in 2017, were reported; and that Lahore had the highest number of 
incidents.  

The Federal Ministry of Human Rights drafted an action plan in November 2018 to address 
the issue of child abuse in the country. A document presented before the National Assembly’s 
Special Committee on child abuse, stated that the plan would focus on prevention, protection, 
recovery,  reintegration,  and  participation.  The  plan  also  seeks  to  strengthen  the  National 
Commission  on  Child  Rights  (presently  National  Commission  for  Child  Welfare  and 
Development (NCCWD), and developing a referral system for child abuse victims.  

Early marriage remains a serious problem, with 21% of girls in Pakistan marrying before the 
age of 18, and 3% marrying before the age of 15. Following legislative measures taken earlier 
by  provincial  governments,  the  federal  Child  Marriage  Restraint  Bill,  2019,  has  been 
submitted to the Parliament for approval. It will set the legal age of marriage at 18 years for 
all.  

Conclusions and monitoring priorities 

Pakistan  has  shown  commitment  in  maintaining  ratification  and  meeting  reporting 
obligations  to  the  treaty  bodies  for  the  27  UN  conventions.  During  the  current  reporting 
period,  improvements have been made in adopting legislation, yet the capacity of institutions 
to  implement  and  enforce  the  legislation  remains  weak.  The  challenge  of  availibility  of 
reliable    data  on  implementation  of  treaty  body  obligations  makes  it  difficult  to  assess  the 
sitution on the ground. 

Shrinking  space  for  civil  society,  a  crackdown  on  freedom  of  expression,  curtailing  media 
freedom and impunity for crimes against journalists and human rights defenders are areas of 
serious  concern.  No  legislative  development  on  narrowing  down  the  scope  of  the  death 
penalty in  line with the artcle 6 of  the International Covenant  on Civil  and Political Rights 
(ICCPR)  has  been  demonstrated.  Tightened  procedures  for  registration  of  INGOs  (with 
domestic NGOs facing increasing pressure) and widespread violations of women's, children's 
and minority rights were documented during the reporting period. Enforced disappearances 
and extra-judicial killings remain prevalent. Legislative development to address this, such as 
criminalisation of enforced disappearances, would be a significant step forward.   

Pakistan must demonstrate that it will concretely increase its efforts and take more proactive 
and    sustained  actions  to  implement  legislation  and  to  address  problematic  areas.  In  this 
context, it is important that Pakistan follows up on the recommendations provided by the UN 
Human Rights Treaty Bodies, addressing salient shortcomings and strengthening the overall 

15 

 
 
implementation mechanism of the relevant Treaty Body obligations.  

Pakistan  needs  to  continue  developing  a  strong  and  transparent  institutional  setup,  which 
should translate its policies and legislation into concrete actions. 

The  Federal  and  Provincial  Treaty  Implementation  Cells  (TICs)  should  be  equipped  with 
appropriate  capacities  and  resources  to  effectively  monitor  and  coordinate  Pakistan's 
implementation of its international and domestic law commitments. Cooperation between the 
Federation  and  the  provinces  must  be  enhanced.  The  setup  of  a  National  Mechanism  for 
Reporting and Follow up and effective coordination with the TICs would be a positive step. 

Also in line with the recommendations of UN Human Rights Treaty Bodies, strengthening the 
capacities  of  the  National  Commission  for  Human  Rights,  adopting  legislation  on 
criminalising torture and progress on the definition of the most serious crimes as regards the 
death penalty, should be pursued.   

4.2  ILO Labour Rights Conventions  

Enforcement  of  Labour  standards  is  provincial  competence  in  Pakistan  since  devolution  in 
2010. Overall, the situation of labour in some provinces has improved. However, the situation 
of  labour  in  the  mining  sector  remains  a  challenge.  The  National  Commission  on  Human 
Rights  (NCHR)  has  alerted  Coal  Mine  Inspection  teams  in  provinces,  particularly  in 
Baluchistan,  to  act  proactively  and  use  new  techniques  to  ensure  the  safety  of  labourer’s  at 
work13.   

The  Ministry  of  Overseas  Pakistanis  and  Human  Resource  Development  (MOP&HRD)  has 
completed a National  Labour Protection Framework.  It carries provincial time-bound action 
plans, focusing on  seven thematic areas:  child labour, forced labour, freedom  of association 
and  collective  bargaining,  non-discrimination,  labour  inspection,  social  dialogue,  and 
occupational safety and health. This Framework is not yet applicable in all 4 provinces. 

The  Pakistan  Bureau  of  Statistics  (PBS)  released  its  findings  of  the  new  Labour  Force 
Survey (LFS) 2017-1814 in January 2019 after a gap of three years. The new data highlights 
the continued challenges facing the country. It indicates, for example, a gradual formalisation 
of  employment  (28%  of  non-agricultural  employment  is  in  the  formal  sector,  which  is  a 
marginal increase since 2015 (27.6%) and a first time reduction in share of agriculture in the 
total employment to 38% (from 42% in 2015). The remaining employment (62% workers) is 
distributed in  industry (24%) and services sectors (38%). The data  further indicates that the 
vulnerable employment (a combination of own account work and contributing family work) 
has  reduced  from  60%  to  56%.  This  is  a  significant  achievement  since  the  vulnerable 
employment  rate  was  hovering  at  around  60%  for  almost  a  decade.  The  gender  wage  gap 
remained relatively static at 40.4% (up from 38.55% in 2015). 

13 https://nchr.gov.pk/wp-content/uploads/2019/01/Coal-Mines-in-Balochistan.pdf  
14 http://www.pbs.gov.pk/content/pakistan-employment-trends-2018  

16 

 
 
                                                 
in 

take  place 

Occupational Safety and Health (OSH) continues 
to  be  an  issue  in  Pakistan.  Serious  incidents,  such 
as  factory  fires  and  building  collapses,  do  occur. 
The  construction  sector  remains  the  the  most 
hazardous  sector  in  terms  of  occupational  injuries. 
The  majority  of 
the 
injuries 
agriculture sector (42 %) followed by  construction 
and manufacturing (34 % combined). Some sectors, 
such as mining and the ship breaking industry, have 
particular problems. The incidence of occupational 
accidents  is  still  4%  for  the  overall  economy, 
in  every  25  workers  faces  an 
meaning  one 
occupational  accident.  Incidence  of  occupational 
diseases  is  double  in  the  informal  sector  (4.16%) 
when  compared  with  formal  sector  (2%).15  The 
actual numbers are likely to be much higher as not 
all  accidents  are  reported.  The  Federal  and 
Provincial  Governments  are  working  on  Bills  on 
OSH  to  improve  the  current  legislation.  The  new 
OSH legislation is still not adopted in all provinces. 
In  January  2019  the  Punjab  Government  adopted  
the  Punjab  Occupational  Safety  and  Health  Act 
2019.  

and 
International 
Environmental 
Standards 
Application in Pakistan's SMEs (ILES) 

Labour 

International 

This project is being implemented by 
the 
Labour 
Organisation  (ILO)  since  September 
to 
2016.  This  programme  aims 
promote  sustainable  and  inclusive 
growth in Pakistan by supporting the 
economic integration of Pakistan into 
the global and regional economy. To 
this end, and in order to increase the 
competiveness  of  textile  and  leather 
sector  in  particular,  the  programme 
helps  to  enhance  the  compliance  of 
with 
Pakistan’s 
international 
and 
environmental  standards.  The  total 
budget is € 12.6 million, of which an 
amount  of  € 600.000  is  co-financed 
by ILO. 

economy 
labour 

The  labour  inspection  system  is  too  weak  to  ensure  its  crucial  function  of  proper 
enforcement  and  overseeing  of  the  application  of  labour  laws  and  safety  standards.  The 
number of labour inspectors is too low and they lack technical and other capacity to perform 
their  tasks.  A  concerning  decision  from  Punjab  to  abolish  labour  and  social  security 
inspections of factories was reversed on 25 September 2019.16 The Government of the Punjab 
intends  to  introduce  third  party  inspections  of  the  industry  to  assess  the  situation  of  labour 
rights.  

Freedom  of  Association  and  Collective  Bargaining  (Conventions  87 
and 98) 

Pakistan made limited progress over the reporting period to ensure freedom of association and 
the right  to  collective bargaining. There are concerns over low  unionisation rate and  weak 
functioning  of  tripartite  social  dialogue  at  national  and  provincial  levels.  The  ILO 
supervisory  bodies  have  also  been  repeatedly  requesting  Pakistan  to  align  labour  legislation 
with the fundamental Convention 87 on freedom of association and to extend its applicability 
to  Export  Processing  Zones  (EPZs)  and  Special  Economic  Zones  (SEZs).  In  addition, 
Pakistan needs to bring its legislation in line with the Convention 98 to ensure, among others, 
that all categories of workers, with  the only possible exception of armed forces, police, and 
public servants in state administrations, enjoy the rights under the Convention.   

Unfortunately,  since  the  devolution  of  the  subject  of  labour  to  the  provinces  in  2010,  the 
Federal  and  provincial  governments  have  not  taken  steps  to  promote  unionisation.  The 

15 http://www.pbs.gov.pk/content/labour-force-survey-2017-18-annual-report 
16 https://cm.punjab.gov.pk/node/2886  

17 

 
 
                                                 
 
unionisation rate remains very low at less than 5%17. Unionised workers also continue to be 
subject to threats of violence and kidnapping. To address this, the Government needs to carry 
out effective, impartial, and systematic investigations into workers´ allegation of mistreatment 
and abuses.      

Although the Industrial Relations legislation is in place at Federal and provincial level, it does 
not  provide  for  unionisation  in  several  work  clusters.  The  Industrial  Acts  regulate  the 
formation of trade unions, collective bargaining, formations of federations and confederations 
of unions. According to the Government, a new proposal for Industrial Relations Act (IRA) in 
Balochistan has been prepared, which is supposed to address some of the issues such as  any 
restriction  for  workers  to  join  trade  unions,  the  financial  supervision  of  the  registrar,  and 
disqualification. 

The  power  of  Industrial  Relations  Acts  to  make  legal  decisions  is  also  questionable.  For 
instance,  there  are  eight  Export  Processing  Zones  (EPZs)  with  300  units  and  40,000 
workers, of which over 50% are women.  These EPZs are managed by a Federal autonomous 
body  Export  Processing  Zones  Authority  (EPZA).  Under  the  provisions  of  EPZA  laws,  the 
IRAs  (Industrial  Relations  Acts)  are  not  applicable.  Thus,  formation  of  labour  unions, 
collective  bargaining  and  strikes  are  forbidden  by  the  EP)  laws.  However,  the  Government 
has  committed  to  the  ILO  to  amend  the  laws  and  ensure  compliance  with  the  rights  of 
association  and  collective  bargaining.  This  is  important  because  Pakistan  is  developing 
Special  Economic  Zones  (SEZs)  under  the  ongoing  China  Pakistan  Economic  Corridor 
(CPEC) initiative. The SEZs will also have a separate autonomous Federal body for which the 
Government  of  Pakistan  commits  to  make  enterprises  abide  by  national  labour  laws  as 
applicable in all territories within Pakistan18. According to the Government, new EPZA Board 
has been constituted in March 2018, but it has not yet been functional as its Chairman has not 
yet been appointed.   

At  the  Federal  level,  the  Govenrment  of  Pakistan  has  set  up  a  National  Industrial  Relations 
Commission (NIRC)19. There has been a noticeable misuse of the Federal Industrial Relations 
Regulations, whereby employers of a firm located in one province artificially create a branch 
in  another  province,  by  which  they  force  the  union  to  deregister  at  the  provincial  labour 
department  and approach the NIRC.  In some  cases,  the employers have  registered two fake 
unions  at  the  NIRC,  justifiying  trans-provincial  locations  of  their  business,  thus  effectively 
blockading the possibility for the formation of a representative union in their firms.  
The  Baluchistan  Industrial  Relations  Act  2010  introduced  a  clause  of  'arbitration'20  which 
violates workers' right to strike (without prior notice of 14 days)21, thus askew with relevant 
convention. The arbitrators usually delay proceedings; hence, no decision is taken to appease 
the workers.   

Harassment and intimidation of trade union members continue to be an issue. This can take 
the  form  of  threats  of  dismissal.  The  widespread  practice  of  not  giving  workers  formal 
employment  contracts,  leaving  them  without  protection  or  the  ability  to  join  a  union, 
continues.  The  provincial  Labour  Departments  either  deny  this  or  blame  it  on  poor  labour 
inspections in the provinces.  

17 Source: Pakistan Workers' Confederation (PWC) 
18 Section 30 of the SEZ Act 2012: http://invest.gov.pk/sites/default/files/2019-01/SEZAct2016e.pdf  
19 http://www.nirc.gov.pk/  
20 Section 47 of BIRA: 
http://balochistan.gov.pk/Downloads/SERVICE%20Rules%20S&GAD%202013/Balochistan%20Industrial%20
Relations%20Act%202012.pdf  
21 Section 44 of BIRA. 

18 

 
 
                                                 
The  tripartite  structures  have  strengthened  since  2014.  The  National  Industrial  Relations 
Commission  (NIRC)  has  been  re-established  and  is  taking  a  more  active  role.  Recently 
established  Tripartite  Consultative  Committees  (TCCs)  at  federal  and  provincial  level  have 
also  met  regularly  in  the  last  few  years  and  discussed  relevant  labour  market  issues. 
According to the legislation, Tripartite Consultative Committees (TCCs) are supposed to meet 
at  least  twice  a  year.  Two  national  tripartite  consultations  were  held  in  2018  at  the  Fedeal 
level.  In  the  provinces,  the  meetings  of  the  tripartite  consultative  committees  (TCCs)  are 
being  held  regularly.  Since  2014,  in  Punjab  alone,  nine  meetings  have  been  held  –  two  per 
year and so far one in 2019.  

Abolition of Forced Labour (Conventions 29 and 105) 

Forced labour manifests itself in particular in the form of bonded labour and remains a major 
issue in Pakistan, despite its prohibition by law. The issue is that of non-implementation and 
is rooted in either political unwillingness or inability to implement the law. 

The Provincial Governments have enforced different laws to ensure proper investigations and 
prosecutions of child and forced labour incidences. Provincial labour inspectors, who are very 
few  in  number  and  have  limited  capacity,  carry  out  the  inspections.  According  to  the  ILO 
Office, there were 334 Inspectors in 2015/2016. Their number has increased to 430 in 2017 
(including 18 women inspectors). Prior to 2018, there had not been a single female inspector 
in  the  country.  In  2017,  for  instance,  in  Punjab,  usually  considered  to  be  ahead  of  other 
provinces in terms of rights provisions, the total number of inspectors was 164, of whom only 
70  inspectors  were  attributed  to  inspect  factories  (there  are  18,500  registered  enterprises  in 
Punjab),  70  inspectors  were  attributed  to  Occupational  Safety  and  Health  (OSH),  two 
technical inspectors, and 22 mine sector inspectors.  

The Global Slavery Index 201822 reflects that Pakistan has over 3.18 million people living in 
modern slavery23, with the estimated proportion of people in modern slavery at 16.82 out of 
1000  people.  The  Index  ranks  Pakistan  at  number  8  out  of  167  countries  and  classifies 
Government's response ranking as 'C', which is amongst the worst countries.   

One of the areas where incidence of forced labour is known to be high are the brick kilns in 
Punjab. Under the Punjab Restrictions on Employment of Children Act, 2016, the Provincial 
Government  carried  out  12,934  labour  inspections  in  2018  in  which  1,865  children  were 
found  employed.  First  Information  Reports  (FIRs)  were  lodged  against  176  employers  and 
correspondingly  30  arrests  were  made.  During  the  period  January  to  March  2019,  around 
13,000 inspections were carried out in which 539 children were found to be employed.  FIRs 
were lodged against 395 personnel out of which 193 were arrested. Data on prosecutions are 
not available.  

In  addition,  under  the  Punjab  Prohibition  of  Child  Labour  at  Brick  Kilns  Act  2016,  5,262 
labour  inspections  were  carried  out  in  2018,  during  which  166  children  were  found  to  be 
employed. Sixteen brick kilns were sealed and FIRs were lodged against 153 employers, out 
of which 57 were arrested. During the period January to March 2019, 3206 inspections were 
carried out in which 167 children were found to be employed in brick kilns. FIRs were lodged 
against 147 personnel, of which 105 were arrested.  

22 https://www.globalslaveryindex.org/2018/data/country-data/pakistan/  
23 Modern slavery refers to situations of exploitation that a person cannot leave because of threats, violence, and 
coercion, abuse of power or deception. 

19 

 
 
 
 
 
 
                                                 
The investigation data reflect that despite action in 2018, the prevalence of forced/child labour 
in  brick  kilns  remained  high.  One  limitation  is  that  the  data  pertaining  to  labour  in  the 
agriculture  sector  are  not  officially  available.  The  District  Vigilance  Committees,  which 
remove children from forced labour conditions and enrol them into schools, are functional in 
all 36 districts of the province.  

In the Khyber Pakhtunkhwa (KPK) province, the KPK Government carried out 8367 labour 
inspections in 2018. Under the Prohibition of Employment of Children Act, 2015, the Khyber 
Pakhtunkhwa  Government  carried  out  8,367  labour  inspections  in  2018  resulting  in  around 
213  prosecutions  out  of  which  courts  decided  on  95  cases.  During  the  period  January  to 
March 2019, 2,516 inspections were conducted of which 121 prosecutions were lodged while 
27 cases have been decided by the courts.  

The Khyber Pakhtunkhwa Labour Department deals with debt bondage in the formal sector24. 
The  enforcement  of  this  law  is  based  entirely  on  a  complaint  system.  In  2018,  only  one 
complaint was received. Another important feature of the law is the establishment of District 
Vigilance  Committees  (DVCs)  under  Deputy  Commissioners.  The  establishment  of  these 
committees  is  subject  to  the  formulation  of  rules  under  the  law.  Currently,  draft  rules  are 
being finalised.  

To  address  forced  labour  in  Pakistan,  stakeholders  involved  in  raising  awareness  among 
remote rural communities need increased capacity. More industrial and economic zones need 
to  be  initiated  in  the  country  to  address  increasing  bondage  labour,  as  the  higher  number 
industrial  zones  can  reduce  the  chances  of  the  forced  labour.  So  far,  no  concrete  plan  to 
address forced labour is in place. There is evidence of positive efforts in the cases of Punjab 
and  Khyber  Pakhtunkhwa  (KPK),  but  the  low  number  of  inspectors  makes  progress 
unsustainable.  

Minimum  Age 
(Conventions 138 and 182) 

for  Work  and  Worst  Forms  of  Child  Labour 

The  high  rate  of  child  labour,  especially  in  the  agricultural  sector,  but  also  in  brick  kilns, 
gemstones, and stone crushing, is of concern. The number of domestic child workers is also 
alarming. To understand the magnitude of these problems, it is essential to have robust figures 
on  the  number  of  child  workers  per  sector.  Such  data  can  also  support  the  development  of 
adequate measures at federal and provincial level to address this issue. To address this, there 
are  child  labour  surveys  planned  and  initiated  throughout  the  country  in  cooperation  with 
UNICEF. The results are expected to final by June 2020. There is further need to strengthen 
investigations  and  prosecutions  of  child  trafficking  and  exploitation  of  children,  including 
forced recruitment by armed groups.  

Child  labour  continues  to  be  a  provincial  subject,  but  any  real  progress  will  require  active 
federal  involvement  in  form  of  systematic  federal  strategy.  Provinces  have  made  moderate 
advancement in efforts to eliminate the worst forms of child labour and defining the minimum 
age for work. Provinces are also setting up their own Industrial Relations Institutes (the one in 
Punjab is already functioning), which will be mandated to train inspectors. 

24 According to The Khyber Pakhtunkhwa Bonded Labour System (Abolition) Act, 2015, Section 3; bonded 
labour is absolutely prohibited in the province. 

20 

 
 
 
 
 
 
 
                                                 
In Punjab, under the ‘Punjab Restriction on Employment of Children Act 2016’, the issue of 
age  restriction  has  been  resolved.  The  law  provides  for  a  blanket  ban  on  child  labour  for 
persons below 15 years of age. It also bans employment of adolescents (15-18 years) of age in 
38 hazardous occupations25.  

Khyber Pakhtunkhwa defines 14 years as minimum age for engaging in 'light work'; for the 
worst forms of labour, the minimum age is 18.26 Khyber Pakhtunkhwa Province also passed 
the  Free  Compulsory  Primary  and  Secondary  Education  Act,  making  education  free  and 
compulsory  for  children  ages  5  to  16.  The  Khyber  Pakhtunkhwa  province  is  devising  a 
National Labour Policy and a separate Child Labour policy with the help of ILO which entails 
a comprehensive Labour Policy for the province (not yet publically available).   

In  Baluchistan,  children  having  attained  14  years  of  age  can  engage  in  light  work,  whereas 
engagement in hazardous work is not allowed until 18 years of age under the Employment of 
Children Act 1991, which is applicable in Baluchistan. The Baluchistan Government is in the 
process  of  finalising  a  law  titled  'Baluchistan  Employment  of  Children  (Probation  and 
Regulation)  Bill'.  The  law  is  under  consultation  with  the  Provincial  Tripartite  Consultation 
Committee (PTCC) and the provincial law department.  

The province of Sindh has set up task forces constituting labour inspectors and officials of the 
Directorates  of  Labour  at  district  level  to  monitor  the  situation  of  child  labour.  In  201727, 
Sindh Province passed the Prohibition of Employment of Children Act, which establishes age 
15 as the minimum age for employment and age 19 as the minimum age for employment in 
hazardous  work.  District  Jamshoro  has  been  declared  as  Child  Labour  Free  District  and  a 
Task Force was set up by continuously monitoring the situation.  

Elimination  of  Discrimination 
(Conventions 100 and 111) 

Equal  value  and  remuneration  and  elimination 
of discrimination in respect of employment and 
occupation  still  pose  a    serious  challenge  in 
Pakistan.  There  is  a  considerable  gender  gap 
with  regards  to  labour  force  participation. 
According to the latest Labour Force Survey the 
participant  rate  of  women  in  labour  market  is 
less  than  15%  compared  to  46%  for  men.28 
Majority  of  the  female  labour  force  remain 
engaged in unpaid domestic work and low paid 
work  that  can  be  seen  as  presence  of  gender 
discrimination. Furtheremore there seems to be 
a  significant  discrimination  in  the  level  of 
positions held. Women have a limited presence 
in  high  level  occupations.  In  2015,  the  female 

at 

the 

project’s 

INSPIRED+  Pakistan  project 
The 
full 
enabling 
aimed 
implementation  of  labour  and  human 
rights  conventions  under  GSP+  focused 
on  enhancing  the  socio-economic  rights 
of  women  working  in  agriculture  in 
Punjab.  The 
assessment 
revealed  that  most  of  the  agro-women 
are  caught  in  a  web  of  chronic  poverty, 
exploited  in  terms  of  un-employment, 
low  wages,  lack  of  economic  agency, 
lack of knowledge about modern farming 
techniques,  and  facing  harassment  and 
marginalisation. Furthermore, their rights 
have  been  mostly  overlooked  in  legal, 
policy  and  administrative  framework. 
stakeholder 
facilitated 
The  project 
dialogues  and advocacy  activities on the 
protection of working women’s rights. 

25 http://extwprlegs1.fao.org/docs/pdf/pak164577.pdf: schedule in Section 2(a) enlists 38 occupations as 
hazardous.   
26 http://kp.gov.pk/uploads/2016/02/11._Prohibition_of_Employment_of_Children_Act,_2015_.pdf  
27  http://www.pas.gov.pk/uploads/acts/Sindh%20Act%20No.III%20of%202017.pdf 

21 

 
 
 
 
 
                                                 
employed labour force in senior positions like senoir officials, managers and legislators were 
less  than  1  %.29    There  is  a  significant  gender  wage  gap  of  60%  and  low  participation  of 
women in the labour market compared to men (24% vs. 76%).  

A Domestic Workers  Bill  was adopted by the Senate in  August  2017, but  did  not  pass the 
National Assembly. On the other hand, provinces are working on legal framework for workers 
in  informal  economy,  namely  in  Sindh  and  Punjab.  In  January  2019  the  Punjab  Assembly 
passed The Punjab Domestic Workers Act 2019, which intends to help enforce the rights of 
domestic workers. 

Conclusions and monitoring priorities 

Overall,  further  steps  have  been  taken  by  the  provinces  to  adopt  legislation  and  to  develop 
procedures  and  guidelines  to  implement  the  ILO  fundamental  conventions,  which  have 
resulted in some improvement in child labour. However, labour rights on collective bargain, 
wage discimination, and forced and bonded labour in agriculture and mining remain a matter 
of  concern.  Implementation  and  enforcement  of  laws  and  regulations  continues  to  be  a 
problem, although some provinces have stepped up efforts to  improve enforcement.  Further 
efforts  are  needed  to  improve  the  labour  inspection  system  and  overall  working  conditions 
with enhanced number of labour inspectors in each provice.  

The    Ministry  of  Overseas  Pakistanis  and  Human  Resource  Development  (MOP&HR)  has 
completed the work on a National Labour Protection Framework, which would include child 
labour,  but  the  Framekwork  has  not  yet  been  formally  adopted  by  the  4  provinces.  Child 
labour  surveys  are  ongoing  in  all  four  provinces  and  the  Labour  force  survey  has  been 
unvieled by the Pakistan Bureau of Statistics in early 2019. 

Overall, federal and provincial authorities must continue and further strengthen their efforts, 
with a particular focus on some of the most problematic issues, notably to ensure the right of 
trade unions to register and operate, to enhance the functioning of the labour inspection, to 
improve  occupational  health  and  safety  of  workers,  to  eradicate  bonded  labour,  and  to 
eliminate the worst forms of child labour.  

Key areas which need to  be prioritised are: (1)  Carry out  child labour surveys and include 
bonded labour in labour force surveys. Ensure proper investigations and prosecution of child 
and forced labour, trafficking and exploitation. (2)The labour inspection system is too weak 
to ensure its crucial function of proper enforcement and overseeing the application of labour 
laws and safety standards. The number of labour inspectors is too low and they lack technical 
and  other  capacity  to  perform  their  tasks.  (3)  Align  labour  legislation  with  the  ILO 
Conventions  87  and  98  on  Freedom  of  Association  and  Collective  Bargaining.  Ensure 
application of labour laws in Export Processing Zones and Special Economic Zones. 

28 http://www.pbs.gov.pk/content/labour-force-survey-2017-18-annual-report 
29 https://library.fes.de/pdf-files/bueros/pakistan/13953.pdf 

22 

 
 
                                                                                                                                                         
4.3  UN  Conventions  on  Environmental  Protection  and  Climate 

Change  

Convention  on  International  Trade  in  Endangered  Species  of  Wild 
Flora and Fauna (CITES) 

National legislation still falls under Category 2, which means that it is believed generally not 
to meet all of the requirements for the implementation of CITES. The implementing rules for 
the  Pakistan  Trade  Control  of  Wild  Fauna  and  Flora  Act  2012  are  enforced  since  31 
December 2018. Provincial Governments are fully functional to implement CITES in all four 
provinces.  In  December  2017,  CITES  Secretariat  noted  significant  legislative  progress  on 
CITES, after desinating Pakistan as a priority party in 2016.  

Pakistan  continued  to  actively  pursue  its  drive  against  illegal  trade  of  wildlife  within  the 
South Asia Wildlife Enforcement Network (SAWEN). Pakistan regularly attends SAWEN 
trainings and meetings, the last one in February 2019 in Kathmandu being on wildlife crime 
detection.  

The  Wild  Life  Department  of  the  Province  issues  a  permit  endorsed  by  the  Foreign  Office 
before  any  endangered  or  rare  species  is  to  be  transported  abroad.  The  Customs  Office  is 
responsible for conducting checks at the airport/other border areas. In October 2018, 7 falcons 
costing Rs. 3.5 million, were recovered at Islamabad airport. The WWF Pakistan developed a 
national  plan  of  action  and  trained  more  than  500  officials  of  law  enforcement  agencies  to 
monitor illegal wildlife trade, especially involving Indian Pangolin found in Sindh. In March 
2018, WWF Pakistan and Pakistan Customs signed a Memorandum of Understanding (MoU) 
to  work  together  through  innovative  means  to  curb  illegal  wildlife  trade  in  Pakistan.  The 
collaboration  includes  enhancing  the  capacities  of  Pakistan  Customs  and  other  concerned 
agencies  to  acquaint  them  with  the  key  aspects  of  illegal  wildlife  trade  in  order  to  enhance 
vigilance against wildlife trafficking (smuggling of freshwater turtles, falcons and pangolins).  

The  mountain  communities  safeguarding  the  Markhor  get  80%  of  the  revenues  generated 
through  issuing  permits  to  hunt  Markhor  and  selling  its  trophies.  They  are  involved  in 
conservation  activities,  from  watch  and  ward  to  monitoring  of  species.  Communities  are 
willing to continue this.30  

Basel Convention 

The Basel Convention Import Policy Order 2016, which bans import of hazardous wastes, has 
been issued.31 However, its  enforcement remains a matter of  concern. Pakistan continues to 
receive imported scrap which is used in multiple manufacturing sectors and is hazardous in 
nature. The local plastic manufacturers, for instance, use imported plastic scraps and waste to 
produce  finished  plastic  goods  and  articles.  These  scraps  are  not  tested  for  contaminants 
before being cleared for manufacturing. This is a clear violation of the import policy order put 
in place by the Government. 

Furthermore,  this  violates  the  Basel  Convention,  which  draws  out  the  scope  of  end-of-life 
plastic products containing contaminants and constituents that fall under hazard class 6 and 9 

30 At the CITES COP 18 meeting (in August 2019 at Geneva), a proposal by Pakistan to discuss quotas for 
Markhor hunting trophies was withdrawn considering reduction in the value of trophies and that the communities 
may not safeguard Markhor anymore which may be prone to extinction.  
31http://www.pkrevenue.com/customs/import-policy-order-2016-import-of-mobile-handset-subject-to-pta-
approval/ 

23 

 
 
                                                 
of  the  convention;  those  are  to  be  sent  back  to  the  country  where  the  plastic  waste  was 
imported from.  

 The  formulation  of  the  Hazardous  Waste  Management  Policy  is  under  process  and  
consultations  for  the  management  of  electronic  waste  generated  during  the  dismantling  of 
ships at Gaddani (Baluchistan) have been initiated. The Ministry of Climate Change held its 
first meeting with Gdani shipyard stakeholders in February 2018 which was followed up by 
the Environment Protection Agency (EPA) Baluchistan in May 2018.  

Convention on Biological Diversity (CBD) 

A National Biodiversity Strategy and Action Plan (NBSAP) has been prepared in  April 2018 
in  consultation  with  the  Provinces  and  is  currently  being  reviewed  by  the  Prime  Minister's 
Office.  Its  final  approval  is  still  in  process  and  its  draft  is  available  online32.    Land 
degradation  and  desertification  remain  serious  issues  in  Pakistan  and  are  the  main  cause  of 
loss of biodiversity and agricultural productivity. Land use planning is almost non-existent in 
Pakistan  and  consequently  the  impact  of  land  degradation  and  desertification  on  national 
economy  are  not  well  documented.  Water  erosion,  wind  erosion,  depletion  of  soil  fertility, 
water logging, salinity, deforestation, and overgrazing are major causes of land degradation. 
The  Federal  Government’s  'Billion  Tree  Tsunami'  project,    initially  launched  in  Khyber 
Pakhtunkhwa province, has been extended to the whole of Pakistan. Water shortages continue 
to be a serious area of concern. To address this, the Government plans to build small dams to 
act  as  reservoirs.  In  May  2019,  the  UNDP  organised  an  awarenss  workshop  on  the 
Himalayan subspecies of the Brown bears, which are one of the oldest and most significant 
inhabitants  of  the  Deosai  plateau.  The  population  of  these  bears,  once  known  to  be  over 
10,000 in number, has now plummeted to an estimated 54 bears residing in the plains. Deosai 
National  Park  (Pakistan)  remains  the  only  habitat  for  these  wild  mammals  where  the  fast 
receding population of the Himalayan brown bears is found. 

Stockholm Convention on Persistent Organic Pollutants 

Because  of  both  increasing  population  and  industrialization  in  the  agro-economic  sector, 
Pakistan has inevitably been confronted by complex environmental challenges. Owing in part 
to  poor  regulatory  framework,  pollution  due  to  Persistent  Organic  Pollutants  (POPs)  has 
caused  serious  problems  throughout  the  country.  Resultantly,  extensive  use  of  Persistent 
Organic  Pollutants  (POPs)  is  causing  vigorous  deterioration  of  environment  and  human 
health. There is a dire need to conduct a national meta-analysis and devise a national strategy 
to address the extensive use of Persistent Organic Pollutants (POPs). The Ministry of Climate 
Change has implemented a project to review and update the National Implementation Plan of 
the  Stockholm  Convention  which  concluded  in  May  2019.  As  part  of  the  project,  an 
international  consultant  is  delivering  training  to  stakeholders  on  inventory  of  Persistent 
Organic Pollutants (POPs) and hold training workshops on new Persistent Organic Pollutants 
(POPs) in Pakistan. 

Cartagena Protocol on Biosafety 

There are no significant updates related to the Cartagena Protocol over the reporting period33. 

32 https://www.cbd.int/doc/world/pk/pk-nbsap-v2-en.pdf  

33 For details, please refer to the biennial report for 2016-2017, SWD(2018) 32 final of 19.1.2018 

24 

 
 
                                                 
 
Conventions  on  Climate  Change  and  the  Protection  of  the  Ozone 
Layer 

Pakistan is among the most vulnerable countries to climate change. Due to a rapidly growing 
population  and  an  insufficient  public  infrastructure,  the  impact  of  a  changing  climate  and 
extreme  weather  events  is  multiplied.  Pakistan  emits  less  than  1%  of  total  annual  global 
greenhouse  gases.  .  Its  carbon  intensity  is  almost  4  times  the  world  average.  The  Global 
Climate Risk Index (2018) did not include Pakistan in its assessment although Pakistan was 
ranked 8 among the most adversely affected countries by climate change during 1998-201734 . 

At  the  34th  meeting  of  the  Least  Developed  Countries  Expert  Group  held  in  Sierra  Leone 
during 21-24 August 2018, Pakistan was among 26 developing countries that presented their 
project  proposals  on  National  Action  Plans  for  funding  under  the  Global  Climate  Fund 
support.  The  fund’s  Readiness  and  Preparatory  Support  Programme  provides  up  to  USD  3 
million per country. The proposal was accepted, but the Ministry of Climate Change has not 
shared details.  

Pakistan  remains  committed  to  reducing  20%  of  its  2030-projected  Greenhouse  gas  (GHG) 
emissions,  amounting  to  1603  million  tonnes  of  carbon  dioxide  equivalent,  subject  to  the 
availability  of  international  grants  to  meet  the  total  abatement  cost  for  the  indicated  20% 
reduction,  amounting  to  about  USD  40  billion  at  current  prices.  Pakistan  identified  its 
adaptation actions and priorities in its Nationally Determined Contributions (NDCs).  

Pakistan's NDCs stem from the country's strategic plan Vision 2025. The NDCs present the 
overall  GHG  emissions  profile  and  future  emission  projections,  by  considering  both  the 
present  and  future  socio-economic  parameters,  changes  in  the  demographic  dynamics  and 
emerging energy needs. They also describe mitigation and adaptation measures already being 
implemented  in  Pakistan  and  discuss  the  challenges  and  difficulties  being  faced  and  those 
likely  to  be  confronted  in  coming  years.  The  Ministry  of  Climate  Change  is  working  on  an 
Adaptation  Plan  to  implement  its  goals  set  under  the  NDCs.  As  for  mitigation  measures, 
Prime Minister has set up a task force within the Ministry of Climate Change.  

According to a preliminary projection, the GHG emissions levels for Pakistan are expected to 
increase many times in the coming decades. An important path to low carbon development is 
Carbon  Capture  and  Storage  (CCS),  which  focuses  on  securing  and  storing  carbon  dioxide 
emissions before these are released into the atmosphere.  

The  provincial  Governments’  Environmental  Protection  Agencies  are  working  to  create 
awareness on the benefits of tree plantation particularly with regard to addressing the climate 
induced  disasters  leading  to  droughts,  floods  and,  more  recently,  intense  heatwaves  in  the 
provinces of Sindh and Punjab in particular. 

A  2018  World  Bank  report,  ‘Pakistan’s  Hotspots:  The  Impact  of  Temperature  and 
Precipitation Changes on Living Standards’, claims that by 2050 annual average temperatures 
are projected to increase by 2.5°C under the climate ‘sensitive scenario’ (which represents a 
future in which some collective action is taken to limit greenhouse gas emissions) and up to 

34 

https://www.germanwatch.org/sites/germanwatch.org/files/Global%20Climate%20Risk%20Index%202019_2.pd
f  

25 

 
 
 
 
                                                 
3.0°C  under  the  carbon  ‘intensive  scenario’  (in  which  no  serious  action  is  taken). 
Approximately 49 million people, or 25 % of Pakistan’s total population, live in locations that 
will become ‘moderate hotspots’ by 2050 under the carbon intensive scenario. Containing the 
temperature is essential to prevent major areas of Pakistan from becoming uninhabitable in a 
future not too far away.  

Pakistan    agreed  to  the  Kigali  Amendment  to  the  Montreal  Protocol  and  benefits  from  a 
deferred schedule for phasing out hydrofluorocarbons (HFCs).  Pakistan also agreed to make 
HFC reductions on a slower track, starting with a freeze in 2028. Pakistan has not yet ratified 
the Kigali Amendment,  but  has ratified  all previous amendments  and is  in  compliance with 
the phase out obligations for ozone depleting substances under the Montreal Protocol. 

Conclusions and priorities 

Pakistan  has  actively  participated  in  regional  initiatives  such  SAWEN  (South  Asia  Wildlife 
Regional  Initiative  –  a  regional  initiative  for  wildlife).  There  is  a  growing  awareness  of 
effective  implementation  of  these  conventions  among  civil  society  organisations.  The 
Government  of  Pakistan  (Ministry  of  Climate  Change)  and  other  departments  including 
Forest  departments,  as  well  as  Pakistan  Customs,  have  improved  their  vigilance  to  combat 
illegal trafficking of wildlife exports. 

With  relation  to  climate  change,  Pakistan  is  committed  to  implement  its  Nationally 
Determined  Contributions  (NDC).  Pakistan  is  a  member  of  the  Nationally  Determined 
Contributions  (NDC)  Partnership,  a  coalition  of  governments  and  international  institutions 
working  together  to  ensure  countries  receive  the  tools  and  support  they  need  to  achieve 
ambitious climate and sustainable development targets. 

Pakistan  needs  to  improve  on  the  regulatory  mechanism  to  implement  the  conventions 
pertaining  to  environment.  In this connection, a  concerete wildlife protection programme is 
required to  be developed for  the Deosai region.  Likewise, a Hazardous  Waste  Management 
Policy and the rules for trade control of Wild Fauna and Flora are required to be formulated 
on priority.  

26 

 
 
 
 
 
4.4  UN Conventions on Good Governance  

International Drug Control Conventions 

South  Asia continues  to face a multitude of drug control challenges that are exacerbated, in 
part, by its geographical location between the two main illicit opiate producing and trafficking 
regions of the world, namely the Golden Triangle in South-East Asia and the Golden Crescent 
in  South-West  Asia  (covering  Afghanistan,  Iran  and  Pakistan).  The  International  Narcotics 
Control Board (INCB) Report 201835 highlights that the route used by traffickers to smuggle 
opiates  through  South  Asia  is  an  alternative  part  of  the  so  called  ‘southern  route’,  which 
typically runs through Pakistan (or the Islamic Republic of Iran) and, via the Gulf countries, 
continues to East Africa and on to the destination countries36. The Counter Narcotics Police of 
Afghanistan  continue  to  emphasize  that  precursors  were  mainly  trafficked  through  Iran  and 
Pakistan. 

According to Pakistan’s Anti-Narcotics Force (ANF), 
which  is  a  Government  law  enforcement  body  for 
anti-narcotics, Pakistan  was more vulnerable to  drug 
trafficking  due  to  increased  poppy  cultivation  in 
Afghanistan. Strict measures were taken by the ANF 
to  neutralize  drug 
trafficking  peddlers  around 
education 
institutions.  So  far,  137  cases  were 
registered, 163 traffickers were arrested and 2,518 kg 
drugs  were  seized.  In  January  2019,  Pakistan's  ANF 
reported that during last year the number of reported 
cases  was  1,184,  which  led  to  the  arrest  of  1,376 
culprits  and  seizure  of  100.26  t  of  drugs  and 
precursor  chemicals  of  approximate  worth  USD 
1,195.72 million. The ANF plans to increase capacity 
of its force from 3,148 to 10,000 in phased program.  

The  EU  Action  against  Drugs 
and Organised Crime (EU-ACT), 
a project for € 12 million, supports 
Pakistan  and  four  other  priority 
countries  along  the  Heroin  Route 
from  Afghanistan  in  their  counter 
narcotics  policies  and  operations. 
In  Pakistan,  project  activities 
commenced  early  in  2019,  will 
boost  the  capacity  of  the  Anti-
and 
Narcotics  Force 
associated 
to 
the 
investigate  and  prosecute 
of 
smuggling 
drugs  more 
through  streamlined 
effectively, 
internal 
improved 
and  more 
internal  oversight 
effective  data  sharing  between 
agencies  at  provincial,  national, 
and international level. 

(ANF) 
institutions 

processes, 

the  UNODC 

these  measures, 

trafficked  directly  from 

trafficked  from  Pakistan 

reports 
Despite 
highlighted that some of the heroin seized in Europe 
transited  Pakistan, 
that 
country  by  air  or  sea  to  Europe.  Opiates  are  also 
being 
the  Islamic 
Republic  of  Iran  for  trafficking  to  European  markets  along  the  Balkan  route.  The  vast 
majority  of  morphine  and  heroin  seized  in  the  Islamic  Republic  of  Iran  entered  the  country 
from Pakistan.37 Pakistan seized 24.4 t of heroin in 2017 compared with 23.1 t in 2016, and it 
saw  a  reduction  in  opium  seizures,  from  64.6  t  in  2016  to  40  t  in  2017.    Pakistan  saw  a 
substantial increase in seizures of cocaine, equalling 415 kg in 2017 compared with 231 kg in 
2016.  

to 

35 Report of the International Narcotics Control Board for 2018. 
36 Seizures made by countries along the Balkan route accounted for 47 per cent of global quantities of heroin and 
morphine seized outside Afghanistan in 2017. Other routes take heroin out of Afghanistan via Pakistan to South 
Asia or Africa (the southern route), or through Central Asia to markets in the Russian Federation (the northern 
route). However, those routes seem to be less important, and that importance is declining further, as in the case 
of the northern route (see World Drug Report 2019, UNODC). 
37 https://wdr.unodc.org/wdr2019/prelaunch/WDR19_Booklet_2_DRUG_DEMAND.pdf ; page 47. 

27 

 
 
                                                 
 
UN Convention against Corruption (UNCAC) 

Pakistan slightly improved its position in Transparency International's Corruption Perception 
Index 2018, ranking 117 out of 180 countries with score of 33 out of 100, up from ranking 
116 out of 176 countries with a score of 32 in 2016. 

The 2017 UNCAC review for Pakistan made several recommendations on criminalisation and 
law  enforcement  and  international  cooperation,  including  improvements  in  data  collection; 
increasing  the  investigative,  prosecutorial  and  enforcement  capacities  for  corruption  cases; 
and ensuring legislation is aligned with the Convention including laws on whistleblowers and 
witness protection. The review group also noted good practice in the enabling of the National 
Accountability  Bureau  (NAB)’s  autonomous  working;  and  identified  technical  assistance 
needs related to the Convention38. 

The  National  Accountability  Bureau  (NAB)  is  the 
official  Anti-Corruption  Agency  of  Pakistan.  The 
Federal  Investigation  Agency  (FIA)  and  Anti-
Corruption Establishments in the provinces also play 
a  role  in  curtailing  corruption.  Institutionally,  NAB 
has  stregthened  over  time.  A  special  helpline  for 
complaints  is  now  in  place.  Until  December  2018, 
NAB had lodged  4,185 complaint investigations, of 
which  323  are  pending  while  the  rest  have  been 
finalised during the year. The Chairman has recently 
informed the press that NAB had recovered Rs. 326 
billion in the recent past.  

terror 

through 

(UNODC) 

The  EU  supports  the  Government 
of  Pakistan  in  its  anti  money 
laundering  and  counter  financing 
of 
a 
efforts 
contribution 
agreement  with 
United  Nations  Office  on  Drugs 
and 
for 
Crime 
to  Counter-
Pakistan's  Action 
Terrorism  (PACT).  Under 
this 
project,  United  Nations  Office  on 
Drugs  and  Crime  (UNODC)  has 
facilitated Combating Financing of 
Terrorism  training  to  officers  of 
the justice, law and order sector at 
inter-provincial  level.  Should  the 
Government  express  an  interest, 
the EU could mobilise Anti Money 
Laundering/Combating  Financing 
of  Terrorism  technical  assistance 
under a global programme. 

However, 
the  National  Accountability  Bureau 
(NAB)  is  being  widely  criticised  by  the  opposition 
for  'nabbing'  the  opposition  parties  only  and  going 
slow  on  cases  against  the  Government.  In  fact,  the 
majority  of  complaint  investigations  are  towards 
opposition  leaders.  Very  few  cases  of  the  ruling 
party  Ministers  and  politicians  have  been  purused 
since the 2018 elections, which is considered to be a  
reflection of NAB's partiality.  The leadership of  the 
two main  political parties as well as the second tier 
(former  Ministers)  are  in  prison  mostly  for  interrogations.  The  opposition  leader  in  the 
National Assembly and former Chief Minister of the Punjab province has also been in custody 
for  charges  against  corruption  and  is  on  bail  now.  The  opposition  parties  have  expressed 
intention to do away with the accountability laws once they come into power.  

In 2019, NAB intends to continue with its anti-corruption drive by strengthening awareness 
with  a  strong  focus  on  the  youth  of  the  country.  It  plans  to  establish  an  exclusive  Anti-
Corruption  Academy  for  which  financial  allocation  has  been  requested  to  the  Federal 
Government. It also plans to form an anti-corruption forum in collaboration with countries in 
the  region  to  enhance  and  strengthen  anti-corruption  activities  across  borders.  In  December 
2018,  the  Supreme  Court  of  Pakistan  asked  Parliament  to  amend  the  accountability  law 
allowing  voluntary  return  of  plundered  money  or  else  the  court  would  pass  an  appropriate 
order in this regard. The process to propose the amendment has already begun. 

38 

https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/ImplementationReviewGroup/ExecutiveSu
mmaries/V1705613e.pdf 

28 

 
 
                                                 
 
The  National  Accountability  (Amendment)  Ordinance  II  was  promulgated  by  the  President, 
whereby  Voluntary  Return  &  Pleas  Bargain  under  Section  25  (a)  &  (b)  in  the  National 
Accountability  (Amendment)  Ordinance  (NAO)  1999  was  substituted  by  Voluntary  Return 
with amended implications of conviction. Previously, the plea bargain clause enabled corrupt 
individuals to walk free after paying back part of the ill gotten money. Presently, the National 
Accountability  (Amendment)  Ordinance  (NAO)  1999  is  being  reviewed  by  a  committee 
comprising legislators from both houses of the Parliament.  

In  relation  to  prevention  of  money  laundering  and  terrorist  financing,  Pakistan’s 
authorities maintain that as far as the financial sector is concerned the relevant regulators have 
established  an  effective  supervision  regime  of  their  regulated  entities.  However,  several 
strategic  deficiencies  have  been  identified  in  the  regime  for  the  prevention  of  money 
laundering and terrorist financing, leading to Pakistan’s inclusion in the document ‘Improving 
Global  Anti-money  Laundering  and  Countering  the  Financing  of  Terrorism  Compliance’  of 
the Financial Action Task Force (FATF), and consequently, on the EU list of high risk third 
countries39.  Pakistan  has  made  a  high-level  political  commitment  in  June  2018  to  address 
these deficiencies by the implementation of an Action Plan. The last set of action plan items 
were  set  to  expire  by  October  201940,  but  the  FATF  plenary  granted  a  period  of  extension 
until February 2020 for the implementation by Pakistan of their respective FATF Action Plan. 

Conclusions and priorities 

Pakistan  continues  to  face  drug  control  challenges.  Plans  to  increase  the  country’s  Anti-
Narcotics Force are welcome. However, further challenges remain in  closing  the routes for 
smuggling and enhancing cooperation within region.  

Efforts  are  being  made  to  strengthen  the  anti-corruption  framework,  including  through 
enhancing its capacity. This should be strongly encouraged. As for the Accountability drive, 
the Government must give confidence and autonomy to the National Accountability Bureau, 
which  should  follow  Accountability  for  All  in  its  actions.  At  present,  it  is  widely  being 
criticised for showing partiality by mostly taking up cases against the opposition parties. This 
poses a great risk to the country’s accountability drive.  

Strategic  deficiencies  in  the  regime  for  the  prevention  of  money  laundering  and  terrorist 
financing led to Pakistan’s inclusion in the ‘grey list’ of the FATF, and, the EU list of high-
risk third countries41. Pakistan has  made a high-level  political  commitment  in  June 2018 to 
address these deficiencies by the implementation of an Action Plan, the outcomes of which are 
yet to be determined.   

39 see Commission Delegated Regulation (EU) 2018/1467 of 27 July 2018 amending Delegated Regulation (EU) 
2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards 
adding Pakistan to the table in point I of the Annex 
40 http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/fatf-compliance-
june-2019.html#Pakistan 
41 see Commission Delegated Regulation (EU) 2018/1467 of 27 July 2018 amending Delegated Regulation (EU) 
2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards 
adding Pakistan to the table in point I of the Annex 

29 

 
 
                                                 
ANNEX 

5. Pakistan – Treaty Ratification and Reporting  

Convention 

Status of ratification / 
reservations42 

Compliance with reporting obligations to monitoring 
bodies 

1. Convention on the 
Prevention and Punishment 
of the Crime of Genocide 

2. International 
Convention on the 
Elimination of All Forms 
of Racial Discrimination 

3. International Covenant 
on Civil and Political 
Rights 

Ratified: 12.10.1957 

No reporting obligations 

No reservations 

Ratified: 21.09.1966 

Compliant with reporting obligations 

No reservations 

Last report submitted on 02.11.2015. 

Next report due by 04.01.2020.  

Ratified: 23.06.2010 

Compliant with reporting obligations 

Reservations made at 
ratification, of which two 
remain, on Articles 3 and 2543 

Last report submitted on 19.10.2015. 

Next report due by 28.07.2020. 

4. International Covenant 
on Economic, Social and 
Cultural Rights 

Ratified: 17.04.2008 

Compliant with reporting obligations 

Reservation made44 

Last report submitted on 16.10.2015. 

5. Convention on the 
Elimination of All Forms 
of Discrimination against 
Women 

Next report dye by 30.06.2022.  

Ratified: 12.03.1996 

Compliant with reporting obligations 

Accession subject to the 
provisions of the Pakistan 
constitution  

Reservation to Article 29 

Last report submitted on 23.10.2018.  

6. Convention against 
Torture and other Cruel, 
Inhuman or Degrading 
Treatment or Punishment 

Ratified: 23.06.2010 

Compliant with reporting obligations  

Reservations made at 
ratification, of which 
reservations to Article 8  two 
remain, on Articles 3 and 2545 

Last report submitted on 04.01.2016. 

Next report due by 12.05.2021. 

7. Convention on the 
Rights of the Child 

Ratified: 12.11.1990 

Compliant with reporting obligations 

No reservations 

Last report submitted on 23.05.2014. 

Next report due by 11.06.2021. 

42 Reservations do not apply in the ILO system, so there is no relevance to providing information on reservations 
under each of these conventions. 
43 Pakistan made nine reservations to the ICCPR at ratification. Leading up to joining the GSP+, most 
reservations were withdrawn, and the remaining reservations were made more specific. Currently, Pakistan has 
reservations to Articles 3 and 25.  
44 Reservation: 'with a view to achieving progressively the full realization of the rights recognized in the present 
Covenant, Pakistan shall use all appropriate means to the maximum of its resources.' 
45 Pakistan made nine reservations to the ICCPR at ratification. Leading up to joining the GSP+, most 
reservations were withdrawn, and the remaining reservations were made more specific. Currently, Pakistan has 
reservations to Articles 3 and 25.  

30 

 
 
 
                                                 
8. Convention concerning 
Forced or Compulsory 
Labour, No. 29 

9. Convention concerning 
Freedom of Association 
and Protection of the Right 
to Organise, No. 87 

10. Convention concerning 
the Application of the 
Principles of the Right to 
Organise and to Bargain 
Collectively, No. 98 

11. Convention concerning 
Equal Remuneration of 
Men and Women Workers 
for Work of Equal Value, 
No. 100 

12. Convention concerning 
the Abolition of Forced 
Labour, No. 105 

13. Convention concerning 
Discrimination in Respect 
of Employment and 
Occupation, No. 111 

Ratification: 1957 

Compliant with reporting obligations  

Latest CEACR comments: Observation 2017. 

Latest report received in 2019. 

Next regular report due in 2022.  

Ratification: 1951 

Compliant with reporting obligations  

Latest CEACR comments: Observation, Direct Request 
2018. 

Latest report received in 2018.  

Next report due in 2021. 

Ratification: 1952 

Compliant with reporting obligations 

Latest CEACR comments: Observation 2018. 

Latest report (out of cycle) received in 2018.  

Next report due in 2021. 

Ratification: 2001 

Compliant with reporting obligations  

Latest CEACR comments: Observation 2017; Direct 
Request 2017. 

Latest report received in 2018. 

Next report due in 2020. 

Ratification: 1960 

Compliant with reporting obligations  

Latest CEACR comments: Observation 2017; Direct 
Request 2017. 

Latest report received in 2019. 

Next regular report due in 2022.  

Ratification: 1961 

Compliant with reporting obligations  

Latest CEACR comments: Observation 2017; Direct 
Request 2017. 

Last report received 01.01.2018. 

Next report due in 2020. 

14. Convention concerning 
Minimum Age for 
Admission to 
Employment, No. 138 

Ratification: 2006  

Compliant with reporting obligations  

Minimum age specified: 14 
years 

Latest CEACR comments: Observation 2017; Direct 
Request 2017. 

15. Convention concerning 
Minimum Age for 
Admission to 
Employment, No. 182 

Latest report received in 2019. 

Next regular report due in 2022. 

Ratification: 2001 

Compliant with reporting obligations  

Latest CEACR: Observation, Direct Request 2017. 

Latest report received in 2019. 

Next regular report due in 2022. 

31 

 
 
 
16. CITES 

Accession: 20.04.1976 

Compliant with reporting obligations 

No reservations 

Last (2018) Annual Report submitted on 04.02.2019. 

Last (2015-2017) Implementation Report submitted on 
04.02.2019. 

Annual Illegal Trade report submitted for 2017. 

17. Montreal Protocol 

Accession: 18.12.1992 

Compliant with reporting obligations 

No reservations 

Most recent data for 2016 was submitted. 

No more recent reporting data is available. 

18. Basel Convention 

Ratification: 26.07.1994 

Compliant with reporting obligations 

No reservations 

Last (2017) National Report submitted on 25.01.2019. 

No data on 2018 Annual National Report available.  

19. Convention on 
Biological Diversity 

Ratification: 26.07.1994  

Lack of compliance with reporting obligations 

No reservations 

Last (Fifth) National Report submitted on 31.03.2014. 

Latest (Sixth) National Report was due on 31.12.2018. 

National Biodiversity Strategy and Action Plan submitted 
on 13.04.2018.  

20. UN Framework 
Convention on Climate 
Change 

21. Cartagena Protocol on 
Biosafety 

Ratification: 01.06.1994 

Lack of compliance with reporting obligations 

No reservations 

Latest (Second) National Communication submitted on 
09.08.2019.  

All Biennial Update reports since 2014 due.  

Ratification: 02.03.2009 

Compliant with reporting obligations  

No reservations 

Last (Third) National Report submitted on 07.09.2016. 

Next (Fourth) National report due on 01.09.2019. 

22. Stockholm Convention  Ratification: 17.04.2008 

Lack of compliance with reporting obligations 

No reservations 

Last (Third) National Report submitted on 22.01.2016.  

Latest (Fourth) National Report was due on 31.08.2018.  

23. Kyoto Protocol 

Accession: 11.01.2005 

No reporting obligations 

24. UN Single Convention 
on Narcotic Drugs 

25. UN Convention on 
Psychotropic Substances 

26. UN Convention against 
Illicit Traffic in Narcotic 
Drugs and Psychotropic 
Substances 

No reservations 

Ratification: 09.07.1965 

No reservations 

Accession: 09.06.1977 

No reservations 

Ratification: 25.10.1991 

No reservations 

Reviewing is fulfilled by the International Narcotics 
Control Board (INCB). 

INCB mission took place 11-14 September 2012. 

See report of the INCB for 2018.  

27. UN Convention against 
Corruption 

Ratification: 31.08.2007 

Reviewing is fulfilled by the UN Office on Drugs and 
Crime (UNODC).  

Last (first review cycle) executive summary information 
was made publicly available on 04.08.2017. 

32