JOINT STAFF WORKING DOCUMENT The EU Special Incentive Arrangement for Sustainable Development and Good Governance (GSP+) assessment of the Islamic Republic of Pakistan covering the period 2020-2022 Accompanying the document Joint Report to the European Parliament and the Council on the Generalised Scheme of Preferences covering the period 2020-2022
Date: 2023-11-21
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: EU market, Pakistan, common commercial policy, development aid, generalised preferences, governance, human rights, international convention, sustainable development, tariff preference

EN 

  EN 

   EUROPEAN COMMISSION HIGH REPRESENTATIVE OF THE UNION FOR FOREIGN AFFAIRS AND SECURITY POLICY Brussels, 21.11.2023  SWD(2023) 363 final  JOINT STAFF WORKING DOCUMENT  The EU Special Incentive Arrangement for Sustainable Development and Good Governance (GSP+) assessment of the Islamic Republic of Pakistan covering the period 2020-2022 Accompanying the document Joint Report to the European Parliament and the Council on the Generalised Scheme of Preferences covering the period 2020-2022 {JOIN(2023) 34 final} - {SWD(2023) 359 final} - {SWD(2023) 360 final} - {SWD(2023) 361 final} - {SWD(2023) 362 final} - {SWD(2023) 364 final} - {SWD(2023) 365 final} - {SWD(2023) 366 final} - {SWD(2023) 367 final} - {SWD(2023) 368 final}  
 
 
ISLAMIC REPUBLIC OF PAKISTAN 

1.  SUMMARY ASSESSMENT 

During  the  monitoring  cycle  2020-2022  the  Islamic  Republic  of  Pakistan  (Pakistan) 
experienced unprecedented economic, political, and environmental challenges: the global 
impact of the COVID-19 pandemic, the energy and food crisis induced by the unprovoked 
and unjustified war of aggression of Russia against Ukraine as well as the unprecedented 
floods hit the economy and the Pakistani population hard. Despite the political turmoil with 
a  change  of  government  on  federal  level  and  strong  tensions  between  government  and 
opposition at federal and provincial level, Pakistan has undertaken important legislative 
steps in areas linked to its sustainable development in line with GSP+. It will be crucial for 
Pakistan to continue legislative reforms and to implement legislation so that they lead to 
tangible improvements for all Pakistanis. 

Pakistan  is  the  largest  exporter  to  the  EU  under  the  GSP+  trade  scheme  and  the  EU  is 
Pakistan’s  most  important  export  destination.  However,  Pakistan  relies  significantly  on 
textile and apparel for its exports. Export diversification would help Pakistan reduce its 
trade imbalances and would also increase its resilience to external economic pressures and 
shocks.  The  Government  of  Pakistan  is  clear  on  its  commitment  to  maintain  its  GSP+ 
eligibility and during the monitoring period it has engaged openly with the EU at all levels. 
Political will needs to be coupled with more determined action for implementing reforms, 
in particular to better protect human and labour rights.  

1.1.  Priorities and Monitoring 

As defined in the 2020 GSP monitoring report, priorities for the current monitoring cycle 
in  the  human  rights  area  included  adopting  and  implementing  laws  against  torture  and 
against enforced disappearances, a law to protect journalists, as well as reducing the scope 
of the death penalty in line with international standards. Furthermore, to create a conducive 
environment  for  civil  society  organisations,  priorities 
the 
(re)registration of international non-governmental organisations (INGOs) and simplifying 
the rules for registration of domestic NGOs.  

included  facilitating 

In  the  area  of  labour  rights,  priorities  included  extending  the  application  of  labour 
legislation  to  Export  Processing  Zones  (EPZ)  and  Special  Economic  Zones  (SEZ), 
adopting and implementing a comprehensive child labour law and completing child labour 
surveys in all provinces, as well as strengthening the labour inspection system to enforce 
the existing labour legislation in all workplaces.  

In terms of environmental protection, priorities included formulating a Hazardous Waste 
Management  Policy  and  the  rules  for  trade  control  of  wild  fauna  and  flora  and 
implementing the Nationally Determined Contribution (NDC) under climate action.  

An EU monitoring mission visited Pakistan between 22 June and 1 July 2022. Besides the 
need  to  adopt  new  legislation,  the  monitoring  mission  underlined  the  need  to  better 
implement existing legislation across all policy areas. The findings of the mission informed 
this report. 

Page | 1 

 
 
      
1.2.  Human Rights 

Since  2020,  Pakistan  has  adopted  important  laws  in  the  field  of  human  rights,  namely 
regarding  preventing  and  punishing  torture,  the  protection  of  journalists,  gender-based 
violence,  preventing  domestic  violence,  and,  at  provincial  level,  promoting  women’s 
rights. The 2022 law against torture constitutes a significant step in the implementation of 
the Convention Against Torture, and the supervisory role given by the law to the National 
Commission  for  Human  Rights  in  investigations  is  a  positive  achievement.  Further 
substantial  efforts  are  needed  for  its  implementation  and  the  adoption  of  the  relevant 
implementation rules. Landmark judgements on juvenile and mentally ill defendants and 
legislative reforms have also limited the scope of application of the death penalty. These 
are important steps to start addressing long term concerns in the effective implementation 
of  human  rights  conventions.  Other  legislative  initiatives,  including  a  law  on  enforced 
disappearances  and  a  federal  law  on  domestic  violence,  would,  if  adopted,  constitute 
important steps towards the implementation of international human rights conventions in 
Pakistan.  

While legislative reforms are significant, important concerns remain, notably on enforced 
disappearances,  on  allegations  of  torture  as  well  as  on  restrictions  of  freedom  of 
expression, and media freedom. While first steps to reduce the scope of the death penalty 
have been taken, further efforts are needed to align with international standards, namely 
by  introducing  a  comprehensive  revision  of  the  mercy  petition  procedure.  Freedom  of 
religion or belief  and rights of persons belonging to minorities continue to be regularly 
violated,  despite  some  efforts  regarding  interfaith  dialogue.  In  this  context,  the 
Government must take determined action and clear positions against the discrimination of 
minorities, religious sects and vulnerable persons, the misuse of blasphemy laws, and the 
risk of false accusations, mob violence and even mob lynching.  

Restrictions to the civil society space through administrative hurdles, and other pressures 
on NGOs continue, even if the revised NGO policy of November 2022 foresees accelerated 
procedures. Despite obstacles, Pakistan’s civil society is vibrant. Pakistan’s international 
commitments, incentivised by the GSP+, provide a space for  civil society organisations 
and human rights defenders to address crucial issues and conduct advocacy.  

The National Action Plan for Human Rights established in 2016 continues to be valid but 
requires further efforts to be fully implemented. With support by the EU, in January 2021 
the Federal Ministry of Human Rights established a Human Rights Information Resource 
Portal as central repository on Pakistan’s domestic and on the international human rights 
framework (1). 

In 2021, the Government adopted a National Action Plan on Business and Human Rights, 
aimed at ensuring observance of Pakistan’s duty to protect against human rights abuses by 
business entities, and creating an environment conducive to fostering corporate respect for 
human rights.  

Courts  and  independent  commissions  are  crucial  for  the  the  implementation  of 
international standards in Pakistan. The chair and members of the National Commission 
on  Human  Rights  (NCHR)  were  appointed  in  November  2021  after  a  long  vacancy. 
Despite  awaiting  the  allocation  of  necessary  financial  and  human  resources,  the 
Commission plays a central role in the implementation of the human rights conventions. 

(1)   https://portal.mohr.gov.pk  As of October 2023, there has been no update on the portal since February 

2022. 
All links provided in this Staff Working Document were up to date as of 20 October 2023. 

Page | 2 

 
 
 
In February 2020, the Government also constituted the National Commission on the Rights 
of the Child. The chair and members of the National Commission on the Status of Women 
were  also  appointed.  Following  instructions  by  the  Islamabad  High  Court,  two  special 
Human Rights Courts for Islamabad Capital Territory were instituted in November 2022. 
Foreseen  in  all  provinces  in  the  NCHR  2012  Act,  they  are  to  provide  speedy  trial  of 
offences arising from violation of human rights. The creation of a National Commission 
for Minority Rights that would meet the requirements of the Paris principles and would 
include all minority groups, in line with a 2014 Supreme Court judgment in this regard, is 
still pending.  

1.3.  Labour Rights 

Pakistan  adopted  new  labour  laws (2)  in  several  provinces  to  align  its  legislation  with 
international  standards.  Labour laws have been  extended to  EPZ, including  the right to 
strike, and the Government of Pakistan confirmed that they are fully applicable to SEZ.  

However, ILO Conventions are often still not effectively implemented and enforced due 
to  limited  capacity  of  labour  inspectorates.  The  low  unionisation  rate  remains  a  major 
concern  as  it  limits  workers’  ability  to  improve  their  working  conditions,  including  by 
collective bargaining, and trade unions face practical hurdles when trying to register and 
operate. Child labour and forced labour persist at high levels. Discrimination of women in 
the  labour  market,  namely  limited  access  to  job  opportunities  and  lower  wages  for 
equivalent  work,  continues  to  be  widespread.  Despite  job  quotas  in  the  public  sector, 
discrimination  of  minorities  continues  and  lowly  paid  hazardous  work  for  example  in 
sanitation is primarily conducted by minorities. Insufficient occupational safety measures 
result in a high number of work accidents.  

1.4.  Environment and Climate 

Pakistan has faced environmental disasters caused by climate change yet again in 2022, 
with extreme heat and severe flooding at unprecedented levels. In 2021 the Government 
of Pakistan submitted an updated ambitious NDC under the Paris Agreement aiming at an 
overall 50% reduction in projected emissions by 2030. It has taken steps in the protection 
of wildlife as guided by the CITES Secretariat and in 2023, the protected areas are to be 
increased from 12% to 15% of the country’s territory. It has adopted a National Hazardous 
Waste Policy, for which implementation steps are in the process of elaboration (3).   

1.5.  Good Governance 

Corruption (political and economic) continues to be perceived as pervasive, and questions 
are  raised  on  the  independence  of  the  National  Accountability  Bureau  (NAB).  Anti-
corruption rhetoric and legal cases are heavily politicised.  

Following positive reports, Pakistan has achieved the deletion from the “grey list” of the 
Financial Action Task Force (FATF) (4) in a consensual decision by the FATF members 
in October 2022. 

(2)   New laws include among others: right to strike; old age benefits; protection of minimum wages and the 

rights to organise and collective bargaining agents (CBA).  

(3)  A departmental framework to strengthen Environmental Protection Agencies in the provinces is being 

formulated in the light of this policy. 

(4)  https://www.fatf-gafi.org/countries/s-t/turkiye/documents/increased-monitoring-october-

2022.html#pakistan  

Page | 3 

 
 
Pakistani  authorities  have  made  significant  efforts  in  combating  the  trafficking  of 
narcotics,  but  given  Pakistan’s  location  as  a  transit  country,  as  well  as  its  domestic 
consumption, it continues to remain a point of concern. Although efforts are being made 
to move from harsh punishment to health-based approaches to tackle drug use, these can 
be enhanced. 

1.6.  Status of Ratification and Reporting 

Pakistan has maintained ratification of relevant international conventions required by the 
GSP Regulation and has improved its reporting  compliance due to  enhanced awareness 
and capacity to engage in the Treaty Body Reporting exercise. The submission of overdue 
reports namely on the International Covenant on Civil and Political Rights (ICCPR) was 
completed  on  16  June  2022.  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  June  2022  and  October  2021  respectively,  and  has 
fulfilled its outstanding follow up reporting obligations for the International Covenant on 
Economic  Social  and  Cultural  Rights  (ICESCR).  Reports  are  also  partially  due  for  the 
Stockholm Convention on Persistent Organic Pollutants.  

Implementation of most of the Treaty Bodies’ recommendations remains slow and several 
of them have adopted written follow up procedures as part of the review and engagement 
process. 

The federal and provincial Treaty Implementation Cells (TICs) established in 2015 by the 
Government  of  Pakistan  constitute  a  dedicated  institutional  framework  to  oversee  and 
report on GSP+ implementation across the country. The provinces of Punjab and Sindh 
have established permanent structures with dedicated resources, while other TICs continue 
to lack capacity.  

In a positive recent development, on 18 April 2023 the Government of Pakistan launched 
a National Compliance Centre which will work with business to improve the understanding 
of international compliance requirements and to promote a culture of equitable growth and 
a discrimination free work place.  

Invitations  were  extended  to  the  following  UN  Human  Rights  Council  (HRC)  Special 
Procedure  Mandate  Holders:  the  Independent  Expert  on  the  effects  of  foreign  debt,  the 
Special  Rapporteur  (SR)  on  the  right  to  education,  the  Special  Rapporteur  on  extreme 
poverty and human rights, the Special Rapporteur on the rights of persons with disabilities, 
and the Special Rapporteur on the Right to Food. However, dates are not yet determined, 
and no SR visits took place in the monitoring period.  

The facilitation by Pakistan of a local presence of the UN Office of the High Commissioner 
for  Human  Rights  (OHCHR)  would  be  beneficial.  Nevertheless,  capacity  building 
activities  by  non-resident  OHCHR  staff  continue  to  benefit  the  advancement  of  human 
rights.  

2.  LONG-TERM VIEW: PAKISTAN SINCE JOINING GSP+ IN 2014 

Pakistan is an important actor in a region characterised by high instability, geo-strategic 
tensions, and absence of regional integration. Since its independence from colonial rule in 
1947,  Pakistan’s  political  power  alternated  between  civilian  governments  and  military 

Page | 4 

 
dictatorships.  Despite  continuous  civilian  rule  since  2008,  the  military  has  played  an 
outsize role in politics and the economy. Since 2014, Pakistan has been governed on the 
federal level by three different coalitions with one transition through general elections and 
one in 2022 through a no-confidence vote.  

Despite a certain political volatility, economic growth in Pakistan was solid until 2018: 
according to the World Bank, GDP increased at an average annual rate of 5.1% from 2013 
to 2018, clearly above population growth. Poverty also decreased from 29.5% in 2013 to 
21.9% in 2018, when measured against the national poverty line.  Economic growth slowed 
to 2.5% in 2019, contracted in 2020 by 1.3% as a result of the COVID-19 pandemic, but 
rebounded  strongly  in  2021  and  in  2022,  increasing  by  6.5%  and  6.2%,  respectively. 
Poverty  also  increased  in  2020  because  of  COVID-19  but  temporarily  recovered.  The 
overall GDP growth is likely to remain subdued because of the 2022 floods coupled with 
the financial crunch and the effects of the Russian military aggression against Ukraine on 
commodity prices. Likewise, inflation is likely to increase further in the coming months 
due to expected supply shocks and food imports. Important structural weaknesses affect 
economic performance, including low productivity growth, a large fiscal deficit and a large 
and  increasing  current  account  deficit,  which  had  led  to  depreciation  pressures,  in  turn 
fostering inflation.  

After  Pakistan  became  a  GSP+  beneficiary  in  2014,  all  three  successive  federal 
government  administrations  have  expressed  strong  commitment  to  the  GSP+  and  its 
requirements.  Pakistan has maintained ratification of the GSP relevant  conventions and 
has taken steps towards their implementation. Institutions such as treaty implementation 
cells (TICs) and a National Commission for Human Rights are in place and functioning, 
although  they  would  benefit  from  greater  resources.  Important  legislative  steps  in 
implementation of Pakistan’s international commitments have been taken, such as a law to 
protect transgender rights or a law against torture. Legislative steps have also been taken 
to  protect  women  at  work  and  a  child  labour  survey  is  ongoing,  although  delayed. 
However, some additional legislative steps such as a law on enforced disappearances and 
on domestic violence at federal level are outstanding. The scope of the death penalty has 
been  limited  to  an  extent  as  a  result  of  legislative  and  judicial  intervention,  and  no 
executions  have  taken  place  since  2019.  However,  further  steps  are  needed  to  ensure 
compliance with international requirements in this area. Moreover, continuous vigilance is 
required in order not to lose the gains achieved, such as the de-facto stop to executions. 

On the other hand, these steps have been taken in the context of a country and a society 
where human and labour rights violations have remained pervasive throughout the period. 
Problems of environmental degradation have also continued, with recurrent droughts and 
flooding culminating in the disastrous 2022 floods. Corruption has remained a widespread 
problem in Pakistan. However, the delisting of Pakistan in October 2022 from the FATF 
list  of  jurisdictions  under  increased  monitoring  (“grey  list”)  might  enhance  investors’ 
confidence  in  the  country’s  economy  and  financial  system.  Pakistan’s  authorities  have 
continued to register the transit of narcotics though its territory despite law enforcement 
efforts. Therefore, while the period from 2014 to 2023 has seen positive steps taken, further 
efforts  lie  ahead  to  improve  the  implementation  of  the  country’s  international 
commitments.  

Page | 5 

 
3.  RECENT DEVELOPMENTS  

After a no-confidence vote ousted Prime Minister Imran Khan, who had taken office during 
the  previous  monitoring  period,  a  broad  coalition  government  under  Prime  Minister 
Shehbaz  Sharif  formed  the  federal  Government  in  April  2022.  Since  then,  the  political 
scene in Pakistan has seen increasing polarisation and controversy in relation to former 
Prime  Minister  Imran  Khan.  The  political  stand-off  culminated  in  May  2023  with  the 
detention of Imran Khan and members of his party, as well as street protests with violence 
against  security  forces  and  their  installations.  In  the  aftermath,  many  protesters  were 
arrested  and  taken  for  trial  including  at  military  and  anti-terrorism  courts.  Internet  and 
social media were temporarily shut down. In early August 2023, former Prime Minister 
Imran Khan was arrested again and convicted, disqualifying him from contesting the next 
general elections. In August 2023, the National Assembly was dissolved a few days before 
the end of its term. Since then, a caretaker government is in place with a limited mandate 
until general elections.  

The political turmoil and constitutional challenges in 2022 and 2023 caused disruption and 
absorbed considerable energy of all political actors. At the same time, an economic crisis, 
high inflation and serious shortage of foreign reserves continue to affect the country. The 
unprecedented  floods  in  2022  affected  tens  of  millions  of  Pakistanis  and  will  require 
substantial efforts over the medium to long-term for reconstruction and rehabilitation while 
impacting existing structural discrimination and socioeconomic disparities. In July 2023, 
the Executive Board of the International Monetary Fund (IMF) approved a US$3 billion 
Stand-By Arrangement for Pakistan.  

EU–Pakistan Development Cooperation 

The  EU-Pakistan  2021-2027  Multi-Annual  Indicative  Programme  (MIP)  was  adopted  in 
December  2021.  A  Team  Europe  Initiative  concentrates  on  green  growth  and  building  back 
better  will  galvanise  EU  Member  States  support  and  help  deliver  the  Global  Gateway  in 
Pakistan. 

The indicative financial allocation for the initial period of the MIP (2021-2024) is € 265 million 
to  support  three  priority  areas:  i)  Green  Inclusive  Growth;  ii)  Human  Capital;  and  iii) 
Governance, including the Rule of Law and Human Rights. The first set of actions under the 
Annual  Action  Programme  (AAP)  2022  concerns  energy,  rural  development  and  vocational 
education  and  training,  and  will  also  contribute  to  the  recovery  efforts  following  the  flood 
emergency of 2022. The AAP 2023 addresses a resilient post-floods recovery and reconstruction 
in the rural and livestock sectors.  It also tackles governance, the promotion of human rights, 
women’s participation and leadership in political processes, and support to civil society.  

4.  EU–PAKISTAN TRADE AND GSP+  

The  EU  is  Pakistan’s  second  most  important  trading  partner,  accounting  for  14.3%  of 
Pakistan's  total  trade  in  2022  and  absorbing  29.8%  of  Pakistan’s  total  exports.  In  2022 
Pakistan’s exports to the EU were 58.9% higher than in 2019, while imports from the EU 
witnessed an increase by 9.0% over the same period. 

Page | 6 

 
Figures 1-4 illustrate Pakistan’s utilisation of the GSP+ in the context of the EU's overall 
imports from Pakistan (5). 

Between 2019 and 2022, Pakistan noted very high rates of utilisation of GSP+ preferences 
(Figure 1 and 2). In 2022, exports of goods worth almost €8 billion used GSP+ preferences 
(Figure 1 and 2) with textile products benefitting most (Figure 3) and incurring the biggest 
tariff  reductions  (Figure  4).  Pakistan  should  optimise,  however,  the  use  of  GSP+  by 
diversifying  its  export  base  and  including  value  added  products  into  its  export  basket, 
which at present is too concentrated on textiles.  

Figure 1: EU imports from Pakistan and GSP+ utilisation rate, 2019-2022 

Total imports, € million 

GSP+ eligible, € million 

GSP+ used, € million 

Share GSP+ in total, % 

GSP+ utilisation rate, % 

2019 

5,917.4 

5,268.9 

5,116.8 

89.0 

97.1 

2020 

5,434.1 

4,832.5 

4,695.3 

88.9 

97.2 

2021 

6,531.4 

5,874.9 

5,550.0 

89.9 

94.5 

2022 

Trend % 

58.87 

62.13 

55.87 

9,400.7 

8,542.4 

7,975.6 

90.9 

93.4 

Figure 2: EU imports from Pakistan by trade regime (€ million) and utilisation rates (%), 2019-2022 

10.000
9.000
8.000
7.000
6.000
5.000
4.000
3.000
2.000
1.000
0

567

7.976

152

137

325

5.117

4.695

5.550

648

2019
Other (MFN)

602

2020

657

2021

858

2022

GSP+ preferential

GSP+ eligible not used

100

95

90

85

80

97,1

97,2

95,4

95,1

89,0

88,9

94,5

93,1

89,9

93,4

91,7

90,9

2019

2020

2021

2022

Share GSP+ in total, %
GSP+ utilisation rate, %
Share duty-free in total

(5)   Source for all statistics: Eurostat data as of September 2023. GSP statistics only cover goods imported 
into 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. Trade flows registered as “confidential” do not appear in the 
GSP+  usage  figures  and  regime  1  normal  trade;  but  do  appear  in  total  trade  figures  (regime  4). 
https://ec.europa.eu/eurostat/cache/metadata/en/ext_go_agg_esms.htm#conf1537195068659  

Page | 7 

 
 
  
  
 
 
 
 
 
Figure 3: Top Pakistan product groups benefitting 
from GSP+ tariff preferences, 2022, € million 

Figure 4: GSP+ tariff reduction gains per product 
group, 2022, € million 

7.000

6.000

5.000

4.000

3.000

2.000

1.000

0

95,2

94,4

91,9

92,9

91,4

6
8
9
.
5

8
4
6
.
5

4
7
0
.
1

8
8
9

83,0

2
3
4

1
1
4

3
6
3

7
3
3

3
4
2

2
2
2

5
4
4

9
6
3

98,0
96,0
94,0
92,0
90,0
88,0
86,0
84,0
82,0
80,0
78,0
76,0

Leather 
articles
19,4

Footwear 
7,6

Others
22,5

Textiles
71,2

Apparel 
& 
clothing
669,8

Eligible

Used

Utilisation rate (%)

5.  COMPLIANCE WITH GSP+ OBLIGATIONS  

5.1.  UN Human Rights Conventions (Conventions 1-7) 

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

(CERD) 

The  Constitution  and  laws  of  Pakistan  do  not  provide  a  comprehensive  definition  of 
minorities  that  would  cover  all  the  grounds  of  discrimination  included  in  the  CERD. 
Instead,  it  uses  a  narrow  definition  of  minorities  as  non-Muslim  religious  groups,  with 
minority rights being granted accordingly. Individuals and communities who identify as 
Muslims are not covered by such provisions (6).  

As mentioned in the previous monitoring report, discussions about an Interfaith Harmony 
Policy  on  federal  and  provincial  level  have  been  ongoing  since  2015/2016.  Punjab 
province presented a draft policy in 2021. The independence of the National Commission 
for Minority Rights created by the Government in 2020, as well as a Bill introduced in 
2023 were criticised, including for not representing all minorities and for not meeting the 
Supreme Court 2014 requirements. 

Despite lacking a comprehensive policy to counter hate speech domestically, Pakistan has 
made efforts, in the last years, to position itself internationally as leading on activities to 
counter  hate  speech,  namely  anti-Muslim  hatred.  The  National  Action  Plan  to  Counter 
Terrorism  of  2014  calls  for  action  against  literature  promoting  hatred,  extremism, 
sectarianism  and intolerance,  as well  as  against religious persecution.  Its  impact  in  this 
regard remains however limited due to its primary focus on terrorism, as well as the lack 
of civilian ownership. Relevant legislation such as the the Pakistan Electronic Crimes Act 
2016  (PECA),  widely  criticised  for  being  used  to  clamp  down  on  dissent,  includes 
provisions against material that “advances or is likely to advance inter-faith, sectarian or 
racial hatred”, but closely links this to cyber-terrorism instead of addressing it as an issue 
in  its  own  right.  The  “Removal  and  Blocking  of  Unlawful  Online  Content  (Procedure, 
Oversight  and  Safeguards)  Rules  2021”  do  not  refer  to  hate  speech  as  grounds  for 

(6)  To  be  noted  that  in  Pakistan,  religious  affiliation  in  some cases  overlaps  with  ethnicity,  language or 

origin. 

Page | 8 

 
 
 
 
restriction of freedom of speech and removal of online content (even though a template for 
complaints refers to PECA).  

The  Government  introduced  a  ‘Single  National  Curriculum’  in  2020  to  harmonise  the 
school  programme  across  public,  private,  and  religious  educational  institutions. 
Nonetheless, critics point to the injection of Islamic religious reference in teaching material 
on  non-religious  subjects,  in  violation  of  paragraph  22  of  the  Constitution (7).  The 
curriculum has since been been renamed ‘National Curriculum of Pakistan’.  

Although minority job quotas exist in the public sector, those quotas are often not met, and 
if so, often only with lower category positions in lowly paid and hazardous jobs.  

Despite the Pakistan Penal Code prohibiting forced marriages, there are concerns about 
these  provisions  in  many  cases  not  being  applied  entirely  or  at  all (8).  Pakistan  has  not 
adopted  further  legislation  specifically  on  forced  conversions  and  marriage  despite  two 
inititatives during the monitoring period, namely the Protection of the Rights of Religious 
Minorities  Bill  (2020)  and  the  Prohibition  of  Forced  Conversion  Bill  (2021).  Forced 
conversions are often closely linked to underage marriage and socio-economic dynamics 
and marginalisation of people belonging to minorities. Statistics for 2021 based on news 
reports indicate 78 cases of forced or questionable conversion from religious minorities to 
Islam with at least 76% involving minors. 

Pakistan has rejected calls for a revision of the harsh law on blasphemy. In August 2023, 
the Senate tried to further extend the blasphemy law, but it was rejected by the President 
of Pakistan.  Blasphemy allegations continue to be misused, including for ulterior motives. 
Mob  violence  is  happening  regularly  and  observed  in  several  provinces  affecting 
individuals,  property,  places  of  worship,  and  cemeteries.  A  few  cases  of  mob  lynching 
have also been reported, not all of them targeting blasphemy suspects. The Government 
should  protect  life  and  property  of  all  citizens  and  strengthen  measures  to  prevent  hate 
speech and mob violence. Convictions for blasphemy in lower courts are often based on 
weak  evidence  and  procedures  and  can  result  in  death  sentences (9).  Administrative 
safeguards  to  protect  the  defendants  and  to  reduce  the  pressure  on  lower  courts,  which 
were mentioned in the previous monitoring report, are not applied systematically, and do 
not constitute an effective deterrent against and protection from the misuse of the law. No 
prosecution of false accusations of blasphemy, nor any rehabilitation of falsely accused 
defendants  has  been  reported.  As  a  result,  blasphemy  laws  and  their  abuse  continue  to 
infringe  on  the  freedom  of  religion  and  belief  as  well  as  the  freedom  of  expression, 
particularly for minorities. In 2020 and 2021 the Government reported a total of 681 cases 
registered for offences against religion under four sections of the Penal Code (10). While 
in absolute numbers, the majority accused of blasphemy are Muslim, non-Muslim religious 
minorities as well as Shia and Ahmadis were disproportionately affected.  

Contrary to their self-identification, the Constitution defines Ahmadis as non-Muslims. On 
this basis, discriminatory laws and administrative provisions effectively prevent them from 
exercising their freedom of religion and belief. In the reporting period, several  cases of 
desecration of Ahmadi mosques and cemeteries, sometimes with active support by local 

(7)   22(1) No person attending any educational institution shall be required to receive religious instruction, 

[…] if such instruction, ceremony or worship relates to a religion other than his own. 

(8)   See also special procedures communication Al PAK 6/2022 of 26 October 2022. 
(9)  A couple sentenced to death for blasphemy in 2014 was acquitted in 2021 and was able to travel to a 
safe place. The European Parliament had expressed concern about their cases in a Resolution of 29 April 
2021 https://www.europarl.europa.eu/doceo/document/TA-9-2021-0157_EN.html  

(10)  Sections 295, 295A, 295C and 298A.  

Page | 9 

 
 
law enforcement, took place, as well as targeted attacks against and killings of Ahmadi 
individuals, without the perpetrators being prosecuted. 

5.1.2.  International Covenant on Civil and Political Rights (ICCPR) 

In 2021, two landmark judgments (11) of the Supreme Court on juvenile and mentally ill 
defendants aligned Pakistan’s legal practice with the provisions of the ICCPR with regards 
to  the application of the capital  punishment in  these  cases.  In 2022 and  2023, Pakistan 
adopted  legislation  to  reduce  the  scope  of  the  death  penalty  by  removing  capital 
punishment  for  offences  of  railway  sabotage (12),  and  for  narcotics  offences (13).  The 
Cabinet  Committee  for  Disposal  of  Legislative  Cases  (CCLC)  has  recommended  three 
more  crimes  that  should  no  longer  lead  to  the  death  penalty (14).  The  further  review  of 
Pakistani penal rules is necessary to ensure implementation of the notion of “most serious 
crimes” of Article 6 of the ICCPR.  

After decreasing steadily since 2016, there have not been any executions since December 
2019. However, the death penalty is still pronounced by lower (trial) courts (in 728 cases 
in 2021 and 554 cases in 2022). The vast majority of cases is revised on appeal, indicating 
a high level of scrutiny by higher courts as well as a weakness of procedures on lower court 
level. Given the lengthy trials and appeal processes, a high number of people remain on 
death  row  under  dire  conditions  for  years,  even  if  they  might  be  acquitted  eventually. 
Independent sources report that the death row population fell significantly from 7,164 in 
2012  to  3,226  in  2022.  Lengthy  judicial  proceedings  hinder  the  speedy  resolution  of 
criminal cases, with sources reporting that 71.5% of the inmate population composed of 
prisoners await trial.  

A  revised  system  of  mercy  petitions,  simplifying  and  streamlining  the  process,  which 
would increase transparency, reliability, and introduce time limits for decisions, has not 
yet  been  adopted.  Since  the  lifting  of  the  moratorium  on  the  death  penalty  in  2014,  no 
mercy has been granted.  

An  important  step  to  address  long-standing  concerns  regarding  media  freedom  was  the 
adoption  of  the  Protection  of  Journalists  and  Media  Professionals  Act  2021  at  federal 
level (15). Concerns have been raised regarding Article 6 of the Act, which uses ambiguous 
terminology  regarding  disinformation,  hate  speech  and  incitement  to  violence  and 
“hostility”  and  could  be  used  to  suspend  the  journalists’  protection.  In  2022,  the  new 
government announced their decision to revise the Act as well as to disband the Pakistan 
Media Development Authority, which since its establishment through ordinance in May 
2021 was widely criticised by journalists for its unchecked powers to control and silence 
media and limit freedom of expression. 

Despite  the  legislative  progress,  the  media  community  reports  pressure  and  harassment 
limiting journalists’ ability to report. Pakistan continues to rank very low in international 
comparative  rankings  on  press  freedom,  150th  out  of  180 (16).  Women  journalists  are 
particularly targeted. On several occasions, government regulatory agencies blocked cable 

(11)  The Supreme Court ruling in the case Safia Bano v Home department regarding mentally ill defendants 

and the Lahore High Court judgment relating to Muhammad Iqbal regarding minors. 

(12)  Railway (Amendment) Act 2022. 
(13)  Control of Narcotics Substances (Amendment) Act, 2023.  
(14)  Assault or use of criminal force to woman and stripping her of her clothes; Kidnapping or abducting for 

extorting property, valuable security etc., Punishment for harbouring hijacker etc. 

(15)  Protection of Journalists and Media Professionals Act 2021. 
(16)  https://rsf.org/en/index?year=2022 (Comparison with previous years is not possible due to a change in 

methodology. 

Page | 10 

 
 
operators and television channels that aired critical or contentious content. The Pakistan 
Telecommunications Authority (PTA) indicated  on 9 May 2023 that it had received an 
order  for  a  blanket  mobile  broadband  suspension,  affecting  the  country’s  125  million 
mobile  broadband  users.  Several  journalists  suffered  violent  attacks  and  disappeared 
during the monitoring period. Online trolls target those expressing criticism of the civilian 
leadership or the military.  Journalists report that self-censorship  is  becoming a survival 
strategy for many. 

Besides the restrictions on media freedom, political activists, human rights defenders, and 
even elected representatives continue to see their freedom of expression limited through 
administrative,  legal,  and  other  measures.  Vague  concepts  and  the  lack  of  adequate 
safeguards in relevant laws, in particular the PECA of 2016, allow for stifling of critical 
and opposition voices.  

Students’ rights of association and expression remain constraint by the ban on students’ 
unions, which has been in force since 1993. As a positive step, in 2022 the Sindh province 
passed the Sindh Students Union Restoration Act allowing for the formation of student 
unions to promote and strengthen relations between students and educational institutions, 
as well as to facilitate the organisation of cultural, intellectual, and other extracurricular 
activities. 

Enforced  disappearances  continue  and  so  does  the  impunity  for  the  perpetrators.  The 
Commission on Forced Disappearances indicated that it had received 1,875 new cases and 
that it closed 1,814 cases  in  2020-2021. However, the Commission  has been  criticised, 
including by the Islamabad High Court in June 2022, for not fulfilling its duties and not 
prosecuting  anyone  responsible  for  enforced  disappearances.  A  Criminal  Law 
(Amendment)  Bill  2021,  which  aims  to  amend  the  Pakistani  Penal  Code  to  include 
enforced disappearances, was discussed by both Chambers of the Parliament but has not 
been adopted yet. In May 2022, a task force on forced disappearances led by the Minister 
of Law and Justice was constituted.   

In the aftermath of the 9 May 2023 protests, civilians are being tried at military and anti-
terrorism courts (17). This implies a very wide interpretation of the notion of “terrorism” 
and gives rise to concerns about compliance with Article 14 ICCPR, guaranteeing the right 
to a trial by a competent, independent, and impartial tribunal. According to the UN Human 
Rights  Committee,  the  “trial  of  civilians  in  military  or  special  courts  may  raise  serious 
problems  as  far  as  the  equitable,  impartial  and  independent  administration  of  justice  is 
concerned,” and that “trials of civilians by military or special courts should be exceptional, 
i.e. limited to cases where the State party can show that resorting to such trials is necessary 
and justified by objective and serious reasons,  and where … regular  civilian courts  are 
unable to undertake the trials.” (18) 

According to the data collected in 2019-2020, Pakistan was the fourth non-EU country of 
origin of victims of trafficking in human beings identified in the EU. Victims were mostly 
male adults trafficked for labour exploitation. In 2021, Pakistan was ranked 5th non-EU 
country of origin of victims of trafficking identified in the EU.  

(17)  The trial of civilians by military courts has been challenged in the Supreme Court and the hearing is 

ongoing (at the time of writing this report).  

(18)  UN Human Rights Committee, General Comment No. 32, Article 14: Right to equality before courts 
(2007); 
trial, 

and 
https://digitallibrary.un.org/nanna/record/606075/files/CCPR_C_GC_32-EN.pdf  

CCPR/C/GC/32 

tribunals 

U.N. 

Doc. 

and 

fair 

to 

a 

Page | 11 

 
 
The regulatory framework makes it difficult for NGOs to work effectively. The policy for 
local  NGOs/Non-Profit  Organisations  (NPOs)  Receiving  Foreign  Contributions (19) 
adopted in November 2022 aims to reduce processing time and the backlog of registrations. 
Concerns persist that approval and reporting requirements, which consider each funding 
stream as a separate project, create an undue hurdle for their efficient and agile operation. 
In the aftermath of the 2022 floods, the Government gave blanket approval to local and 
international NGOs to carry out activities related to flood relief.  

Only days before handing over to the caretaker government, the government passed more 
than 100 bills. Several of these laws (20) would in effect restrict fundamental freedoms and 
have  been  criticised  across  the  country.  The  Official  Secrets  (Amendment)  Bill  gives 
sweeping  new  powers  to  the  intelligence  agencies.  Similarly,  the  Pakistan  Army 
(Amendment)  Bill  criminalises  the  defamation  of  the  armed  forces  and  sanctions  the 
increasing role of the military in “national development and advancement of national or 
strategic  interests”,  i.e.  in  civilian  areas,  such  as  investment  facilitation  and  economic 
development.   

Promotion of Human Rights in Pakistan 

An  EU  project  implemented  between  2019  and  April  2022  supported  Pakistan’s  efforts  to 
improve  its  compliance  with  human  rights  commitments.  Its  aim  was  to  provide  technical 
assistance  and  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 human rights agenda, and to raise public awareness, knowledge, and understanding 
of rights and how to protect them. The project also aimed to support Pakistan to comply with its 
obligations under the GSP+. 

5.1.3.  International Covenant on Economic, Social and Cultural Rights (ICESCR) 

The Constitution of Pakistan protects many economic, social, and cultural rights, including 
prohibitions on “slavery”, “forced labour”, and the employment of “a child below the age 
of  fourteen  years”.  It  guarantees  the  rights  to  “freedom  of  assembly”,  “freedom  of 
association”, and the “freedom of business, trade and profession” but does not include all 
internationally  recognised  economic,  social,  and  cultural  rights.  The  country  faces 
difficulties with their realisation, according to the CESCR.   

Pakistan experienced the impact of the COVID-19 pandemic on the labour market as well 
as massive inflation and devastating floods during the monitoring period, casting the light 
on existing structural discrimination and socioeconomic disparities, with poor Pakistanis 
suffering  the  worst  of  the  impact.  While  the  pandemic  resulted  in  increasing  health 
budgets, the pandemic laid bare Pakistan’s fragile healthcare system.  

The Benazir Income Support Programme is a wide-ranging social protection and poverty 
alleviation programme. Expanded as Ehsaas Programme during the previous Government, 
its  implementation  has  been  challenging  in  the  context  of  the  current  financial  and 
economic crisis.  

(19)  https://ead.gov.pk/SiteImage/Policy/NGOs-Policy-2022.pdf   
(20)  Official  Secrets  (Amendment)  Bill  2023;  Pakistan  Army  (Amendment)  Bill,  2023;  National 
Accountability (Amendment) Bill, 2023; The Criminal Law (Amendment) Bill, 2023; Elections (Second 
Amendment) Act, 2023; The Pakistan Electronic Media Regulatory Authority (Amendment) Bill 2023. 

Page | 12 

 
 
 
5.1.4.  Convention  on  the  Elimination  of  All  Forms  of  Discrimination  Against  Women 

(CEDAW) 

Pakistan consistently ranks very low on international rankings regarding gender equality 
and the status  of women. The 2022 World Economic Forum Global  Gender Gap  Index 
ranks Pakistan as the 145th out of 146 countries (21), while recognising that in 2022 it has 
made “significant improvement”, namely on economic participation and opportunity. 

The Government continued to give high priority to the situation of women and girls. This 
has  resulted  in  new  legislation  and  policies  to  tackle  persistent  problems  and  in  some 
instances seems to have led to improvements on the ground. Positive steps taken in the 
area of women’s rights include enacting the Anti-Rape Investigation and Trial Amendment 
Act 2021, the Protection Against Harassment of Women at the Workplace Amendment 
Act,  the  Legal  Aid  and  Justice  Authority  Act  2021,  which  forsees  free  legal  aid  to 
marginalised victims, including women, and the Enforcement of Women’s Property Rights 
2021  Act.  A  Federal  Domestic  Violence  Bill  introduced  in  Parliament  in  June  2021  to 
punish all acts of physical, emotional, psychological, sexual, and economic abuse against 
women, children and other vulnerable persons in domestic relationships was referred to 
and criticised by the Council of Islamic Ideology, an advisory body to the Government. 
Domestic violence legislation exists in three provinces, but domestic violence is not always 
considered a criminal offense in these laws.  

indicating 

increased  vulnerability  of  women  under 

As in many other countries, civil society organisations and Government complaints cells 
registered  a  rise  in  complaints  of  domestic  and  online  violence  during  the  COVID-19 
the  confinement 
pandemic, 
arrangements. The low rates of investigation and prosecution of perpetrators as well as the 
lengthy and difficult judicial proceedings for sexual and gender-based victims demonstrate 
the  need  for  a  more  effective  national  policy  on  violence  against  women.  To  give  an 
example, independent sources indicate a 200% increase in rape cases in Sindh province, 
with a conviction rate of less than 1%.  

Women’s  rights  activists  continue  to  face  harassment  and  vilification  online,  on 
mainstream television, and in the Courts, including by senior political figures. Accusations 
of  vulgarity,  blasphemy,  and  foreign  interference  restrict  the  activists’  freedom  of 
expression and put them at high risk of attack.  

Following  continued  advocacy  by  women’s  rights  activists  challenging  the  archaic  and 
demeaning  ‘two-finger test’ for sexual assault  victims,  the Lahore High  Court declared 
such virginity tests unconstitutional in January 2021. 

The secondary implementing regulation of the Transgender Persons (Protection of Rights) 
Act 2018, the Transgender Persons Rules for Implementation, were notified in 2020. The 
Government  has  vowed  to  safeguard  and  implement  this  legislation,  which  was  a 
significant  achievement  of  the  previous  monitoring  period.  The  protection  of  rights 
provided  this  Act  are  under  political  attack,  as  well  as  subject  to  legal  challenge (22). 
Further efforts are needed to ensure that acquired rights of vulnerable minorities are not 
rolled-back.  Further,  prompt,  impartial,  effective  and  gender-sensitive  investigations  of 
violence against transgender persons should be ensured. 

(21)  https://www.weforum.org/reports/global-gender-gap-report-2022/  
(22)  On 19 May 2023 the Federal Shariat Court ruled against the application of certain provisions of the Act 

https://www.federalshariatcourt.gov.pk/Judgments/Shariat%20Petition%2005-
I%20OF%202020%20Hammad%20Hussain%20v%20FOP%20-%20Transgender.pdf  

Page | 13 

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

Punishment (CAT) 

In  response  to  the  2018  recommendation  of  the  UN  Committee  on  Torture,  Pakistan 
adopted the Torture and Custodial Death (Prevention and Punishment) Act 2022, which 
defines torture and cruel, inhuman or degrading treatment, creates the offence of torture, 
custodial  death  and  custodial  rape,  and  establishes  the  inadmissibility  of  statements 
extracted through torture. It tasks the Federal Investigation Agency, under the supervision 
of the NCHR, with the exclusive jursidiction to investigate complaints. In order for this 
important law to bring tangible results, implementing rules will need to be adopted and 
resources and training will have to be devoted to its implementation and the capacity of 
the  NCHR  needs  to  be  strengthened  to  enable  its  supervisory  role.  Meanwhile,  despite 
existing  laws  and  constitutional  protections,  torture  is  reported  to  be  routinely  used  to 
coerce accused persons to confess as central part of investigation.   

5.1.6.  Convention on the Rights of the Child (CRC) 

Legislative and regulatory progress has been made regarding children rights through the 
Zainab Alert Response and Recovery Act for Children 2020.  

Although  the  judiciary  and  law  enforcement  agencies  were  seen  to  be  more  actively 
pursuing  cases  of  crimes  against  children,  the  extent  and  severity  of  violence  against 
children  and  their  exploitation  remained  worrying.  In  2020,  2,960  cases  of  child  abuse 
were documented across the country, and in 2021, according to one estimate, a total of 
1,896 cases were registered, although the number is likely to be higher.  

Furthemore, early marriage remains a serious problem. Several legislative proposals have 
been submitted to the federal Parliament for approval, but remain pending. The Council of 
Islamic Ideology (an advisory body to the government) objected to the criminalisation of 
marriages under the age of 18 and avised the Governemnt to handle the subject sensitively. 
Sindh is the only province in Pakistan, which, going beyond the Child Marriage Restraint 
Act of 1929, banned marriages before the age of 18 for both girls and boys, in line with 
the Convention of the Rights of the Child. 

In October 2021, the Federal Shariat Court, confirming previous judgements by provincial 
high courts, declared that the tradition of swara/vani (i.e., girls, often minors, to be given 
for marriage as compensation to end disputes) was un-Islamic, and determined that setting 
a minimum age limit for girls’ marriage by the state was not against Islam.  

Another positive step was that the National Commission on the Rights of the Child became 
operational in 2021. 

Conclusions and priorities 

Since Pakistan’s inclusion in the GSP+ in 2014, progress has been recorded in the legal 
framework  related  to  human  rights  and  its  implementation.  However,  there  are  also 
some developments putting into question the progress achieved, thus causing concerns. 
Challenges remain with respect to Pakistan’s capacity to uphold and protect the human 
rights of its citizens.  

In the current review period, Pakistan has adopted important laws, such as those against 
torture, to protect journalists and media professionals, and to protect the rights of women 

Page | 14 

 
in the workplace. First steps have been taken to reduce the scope of the death penalty, 
while the adoption of a revised mercy petition procedure remains crucial.  

Additional legislation, notably on further reducing the scope of the death penalty, on 
enforced disappearances, and on domestic violence at federal level are needed to align 
Pakistan’s framework with its international commitments.  

Important shortcomings persist in protecting the freedom of religion and belief, and the 
rights of minorities, in particular in view of the blasphemy laws and their abuse, as well 
as hate speech and violence against minorities. Freedom of expression, of the press and 
of association, as well as the rights of women and girls continue to be of concern. 

Commitments  have  to  translate  into  effective  and  sustainable  implementation  with 
concrete targets. Further capacity-building at both federal and provincial levels, notably 
of the commissions working on human rights, is instrumental towards achieving a more 
effective application and enforcement of the international conventions that Pakistan has 
ratified. Courts also play a crucial role in protecting fundamental rights. The role of civil 
society  is  essential  for  pursuing  the  human  rights  agenda.  Rules  regulating  their 
activities should provide an enabling environment for them to operate freely. 

5.2.  ILO Labour Rights Conventions (Conventions 8-15) 

5.2.1.  Freedom of Association and Collective Bargaining (Conventions No. 87 and No. 

98) 

The  low  unionisation  rate  and  a  weakly  functioning  social  dialogue  at  national  and 
provincial  levels  persisted  during  the  reporting  period.  According  to  the  ILO,  4.1%  of 
workers  are  unionised (23).  In  some  provinces,  such  as  Khyber  Pakhtunkhwa  (KP),  the 
number of registered unions increased; in others, such as Sindh, it decreased significantly, 
and the total number is far below previous years. The latest data reported include 1,398 
unions registered in Punjab; 3,945 in Sindh; 467 in KP and 453 in Balochistan.  

Provincial legislation was adopted to extend labour rights (24) to EPZ, and the Government 
confirmed  that  they  are  fully  applicable  to  SEZ.  Attention  will  need  to  be  paid  to 
implementation (25). 

Several groups continue to be excluded by the national and provincial industrial relations 
acts or face other legal obstacles to establish or join trade unions, in particular workers that 
are  considered  to  belong  to  essential  services,  health  workers  and  public  servants. 
Limitations of trade unions’ activities also exist in the banking, aviation, and shipbuilding 
sector. Unions of government employees were banned in Balochistan, and the Supreme 

(23)  Decent 

Work 

Country 

Programme 

for 

Pakistan 

(2023–27), 

https://www.ilo.org/islamabad/whatwedo/publications/WCMS_882381/lang--
en/index.htm#:~:text=The%20Government%20of%20Pakistan%2C%20employers%E2%80%99%20a
nd%20workers%E2%80%99%20organizations%2C,priorities%20of%20the%20ILO%27s%20tripartit
e%20constituents%20in%20Pakistan.  

(24)  For example, Sindh has extended trade union rights to agriculture and fishing workers and amended laws 

to bar contract workers on production relation work. 

(25)  The CEACR requested the Government in its report published in February 2023 to provide information 
on the exercise of trade union rights in the EPZs, including the trade unions registered and the number 
of unionised workers, as well as any instances in which trade unions have been refused registration and 
the reasons therefore (CEACR report 2023, page 203; and reiterated with slightly different focus on page 
207). 

Page | 15 

 
 
 
Court ordered their reinstatement (26). Private companies that are owned by the defence 
services do not have the right to form unions. 

Workers Councils and Joint Management Boards exist in some companies and provide a 
channel of communication between management and employees. However, these are not 
as effective as independent trade unions, as they can be influenced by employers and do 
not provide a platform for collective bargaining. Management councils are not registered 
with the Directorate of Labour. Further, some unions, notably in brick kilns in Punjab, or 
in  the  agricultural  and  financial  sectors,  mention  the  existence  of  “pocket”  or  “yellow” 
unions, i.e., comprising employees that are chosen by management and which are easily 
dominated or influenced by the employer. Unions’ activities can also be hindered by the 
lack of formal employment contracts or the failure to respect them, hampering access to 
several rights, such as minimum wages and social security. 

According  to  most  of  the  existing  industrial  relation  acts,  collective  bargaining  is  only 
permitted  in  a  company  if  at  least  one  trade  union  represents  at  least  one  third  of  the 
company’s employees. But in many companies falling under these acts, there might be no 
union  reaching  this  threshold  and  therefore  no  collective  bargaining  is  allowed (27). 
Further,  there  are  reports  of  harassment  and  intimidation  of  trade  union  members,  and 
unions  have  reported  difficulties  during  the  process  of  registration.  Examples  provided 
include  the  fact  that  employers  may  be  alerted  to  union  registration  activities  by  the 
authorities,  when  checking  conditions  such  as  the  minimum  number  of  workers. 
Companies  can  also  undermine  the  registration  process  by  claiming  that  they  operate 
across  provinces.  In  this  case,  the  union  would  have  to  be  registered  at  federal  level 
(National  Industrial  Relations  Commission  -  NIRC)  and  any  previous  requests  made  at 
provincial  level  will be  denied. Even  companies that have a better record of respecting 
labour rights do not typically have strong trade unions, including in the textile sector. 

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

This project is being implemented by the ILO in partnership with the EU since September 2016. 
This programme aims to promote sustainable and inclusive growth in Pakistan by supporting 
the economic integration of Pakistan into the global and regional economy. To this end, and to 
increase the competitiveness of the textile and leather sector in particular, the programme helps 
to enhance the compliance of Pakistan’s economy with international labour and environmental 
standards.  The  total  budget  is  € 12.6  million,  of  which  an  amount  of  € 600  thousand  is  co-
financed by ILO. 

5.2.2.  Abolition of Forced Labour (Conventions No. 29 and No. 105) 

Legislation prohibiting forced and bonded labour is in place. However, reports from civil 
society indicate that forced labour continues to exist. Forced labour, primarily in the form 
of debt bondage is found across the country notably in sectors such as brick kilns, domestic 
work, carpet  weaving, agriculture, and mining (28).  In these sectors, apart  from  mining, 
women  account  for  a  major  share  of  the  labour  force.  Bonded  labourers  from  socially 

(26)  Legislative  changes  in  Balochistan  in  2022  have  addressed  many  of  these  problems,  but  not  yet  all 

(according to the CEACR report published in February 2023, page 200-201 and 206). 

(27)  Legislative changes in Balochistan in 2022 have addressed most of these problems for Balochistan; but 
for the federal level and for the other provinces, legislative changes are still needed (according to the 
CEACR report published in February 2023, page 207). 

(28)  Mechanisms  that  create  the  conditions  for  bonded  labour  include  piece  rate  pay  and  the  hiring  via 
thakedar (third party contractors). The workers are given peshgi (advance salaries) as loans in times of 
need, to supplement salaries (which in many cases are below the minimum wage). This results in a cycle 
of bondage, particularly in agriculture and at brick kilns. 

Page | 16 

 
 
 
excluded  groups, 
discrimination.  

including  minorities  and  migrants,  suffer  additionally  from 

Pakistan also supports the ILO’s Better Work Programme that aims at helping interested 
companies to comply with international labour standards. Inadequate resources provided 
to labour inspectorates and long judicial procedures continue to hamper law enforcement. 
Some provinces have a Labour Information Management System (LIMS), developed in 
cooperation with the ILO, whereby labour inspectors report each inspection visit by using 
an online tool. The frequency of these inspections is limited by the low number of staff, in 
particular inspectors, in each province. Punjab has 225 inspectors including 15 women, KP 
has 93, Balochistan has 76 (of which only 9 are factory inspectors while the remaining are 
focusing on shops), and Gilgit Baltistan has eight. Though relatively low, the number of 
female inspectors is increasing.  

Some industries have put in place policies to tackle forced labour. However, this does not 
necessarily  entail  the  whole  supply  chain.  Provincial  governments  have  yet  to  form 
'vigilance committees' in all districts to ensure that violations of labour rights are monitored 
and penalised. In Sindh, out of 29 districts, District Vigilance Committees (DVCs) have 
been constituted in  only 14 districts  (2021 data). In addition, provisions of the national 
legislation establishing penalties involving compulsory labour need to be reviewed in order 
to ensure compliance with the ILO Conventions (29). 

5.2.3.  Minimum Age for Work and Worst Forms of Child Labour (Conventions No. 138 

and No. 182) 

In  past  years,  the  provincial  governments  have  taken  measures  to  stop  children  from 
working and to increase their school enrolment, notably in the Punjab province. However, 
in 2020, the ILO supervisory bodies noted with deep concern the significant number of 
children under the minimum age engaged in child labour, including in hazardous work. 
The number of out-of-school children remains high and they can be encouraged to leave 
school early where the minimum age for admission to employment is lower than the age 
of completion of compulsory schooling. There are very few prosecutions of cases filed by 
district vigilance committees and the limited capacity of labour inspectorates is a challenge 
as well. In 2020, while authorities concentrated on mitigating the effects of the COVID-
19  pandemic,  the  closure  of  schools  increased  the  risk  of  attracting  children  into  the 
workforce. Limited awareness of the issue, including amongst domestic child workers, is 
also a factor.  

Child labour surveys (30), which were planned to be published in 2020 and form a basis for 
action to tackle the problem, are ongoing. At the time of finalising this report only Punjab 
and  Gilgit-Baltistan  surveys  have  been  published.  The  results  in  Punjab  show  the 
prevalence of child labour at  13.4% and in  Gilgit  Baltistan at  13.1%  (one out  of seven 
children). Among children in child labour, 47.8% of children in Punjab aged 10-14 work 
under hazardous conditions, 9.9% work for long hours (31). In the remaining provinces the 
child labour surveys are expected to be published in 2023.  

(29) https://www.ilo.org/dyn/normlex/en/f?p=1000:13100:0::NO:13100:P13100_COMMENT_ID,P13100_

COUNTRY_ID:4054656,103166  

(30)  https://labour.punjab.gov.pk/node/104 (Punjab);  

https://www.pbs.gov.pk/sites/default/files//other/cls2018-19/CLS_GB_Final_Report.pdf (Gilgit 
Baltistan)  

(31)  Punjab Child Labour Survey 2019-20 report; page XIX. 

Page | 17 

 
 
5.2.4.  Equal Remuneration and Elimination of Discrimination (Conventions No. 100 and 

No. 111). 

Equal remuneration for work of equal value and elimination of discrimination in respect 
of employment and occupation still pose a serious challenge in Pakistan. In January 2022, 
the Parliament adopted an amendment to the Protection against Harassment of Women at 
the  Workplace  Act  of  2010 that  specifically  includes  domestic  workers  and  brings 
Pakistan’s legislation closer to ILO Violence and Harassment Convention No. 190, which 
Pakistan  has  not  ratified  yet (32).  In  October  of  the  same  year  the  Act  to  provide  for 
regulation  of  employment  of  domestic  workers  in  Islamabad  Capital  Territory (33)  was 
adopted  by  the  Pakistani  Parliament.  The  Balochistan  Payment  of  Wages  Act  of  2021 
introduced  provisions  on  equal  remuneration  for  ‘work  of  equal  value’  and  rules  on 
objective job evaluation schemes were adopted which is a positive step forward, but the 
laws of other provinces still need to be brought into line with Convention No. 100 (34). 

Religious minorities and other vulnerable groups continue to face discrimination at work. 
For example, they represent nearly 80% of low skill and pay jobs in sanitation. The Ahmadi 
community faces several forms of labour market discrimination (35). The understanding of 
the concepts of employment discrimination and harassment remain low among employers, 
including public services.  

There is a considerable gender gap with regards to labour force participation. According 
to the latest Labour Force Survey the participation rate of women in the labour market is 
less than 21.4% of working age Pakistani women, compared to almost 68% for men (36). 
Most of the female labour force remains engaged in unpaid domestic work and low paid 
work. Furthermore, there seems to be a significant discrimination in the level of positions 
held.  Women  have  a  limited  presence  in  high  level  occupations.  In  2021,  the  female 
employed labour force in senior positions like managers was less than 1%. According to 
the Global Wage Report of the ILO, women in Pakistan earn 34% less than men (37). 

Conclusions and priorities 

The authorities of Pakistan have taken some steps to align labour legislation with the 
ILO’s labour standards and to tackle child labour and forced labour. The authorities also 
started activities to improve domestic workers’ rights, enhance labour inspections and 
increase awareness about workers’ rights and occupational safety and health. However, 
the  overall  situation  remains  of  great  concern  notably  when  it  comes  to  freedom  of 
association and the right to collective bargaining, which underpin the protection of the 
rights of workers in general.    

Federal and provincial authorities should facilitate activities of trade unions, simplify 
registration (including of sectoral ones), uphold the right to collective bargaining and 
reinforce  social  dialogue.  To  strengthen  trade  unions  and  improve  their  capacity  to 
register  and  operate  effectively,  areas  of  intervention  should  include  decreasing  the 
number of workers needed to establish a trade union, rules applying to trans-provincial 
activities of enterprises, and the protection of individual workers during the registration 

(32)  The legislation has yet to enter into force. 
(33)  https://na.gov.pk/uploads/documents/636a06c54f3fd_803.pdf 
(34)  CEACR report of February 2023, pages 648-649. 
(35)  The CEACR urged the Government again in its report published in February 2023 to “take immediate 
steps to amend discriminatory legal provisions and administrative measures, and to actively promote 
respect and tolerance for religious minorities, including the Ahmadi” (CEACR report 2023, page 651). 

(36)  https://www.ilo.org/surveyLib/index.php/catalog/7929  
(37)  https://www.ilo.org/global/publications/books/WCMS_650553/lang--en/index.html  

Page | 18 

 
 
procedure.  A  complete  list  of  registered  unions  should  be  available  for  all 
establishments.  Awareness-raising  activities  are  crucial  to  inform  workers  and 
employers about their rights and obligations, notably in  EPZ and SEZ, following the 
extension of all labour rights to these areas.  

Progress on effective implementation of legislation and its enforcement is necessary to 
address child labour and forced labour, including bonded labour, which remain high. 
Increased efforts to fight discrimination at the workplace are also needed. Child labour 
surveys in provinces where they have not been completed should be accelerated. Where 
finalised, the surveys need to be followed by concrete action plans. 

The capacities of labour inspectorates need to  improve considerably,  in  particular by 
substantially increasing the number of inspectors (including women) and providing the 
necessary  equipment  and  trainings.  In  person  on-site  inspections,  including  without 
notice, should be conducted regularly across industries.  

In summary, the priority areas where increased action is needed include facilitating the 
registration of trade unions, increasing the capacities of the labour inspectorates, and 
developing action plans based on the outcomes of the child labour surveys. 

5.3.  UN  Conventions  on  Environmental  Protection  and  Climate  Change 

(Conventions 16-23) 

5.3.1.  Convention  on  International  Trade  in  Endangered  Species  of  Wild  Flora  and 

Fauna (CITES) 

Pakistan  has  rich  geographic  and  climatic  conditions,  which  provide  habitats  to 
biodiversity. Nevertheless, despite the Trade Control of Wild Fauna and Flora Act of 2012 
and the Trade Control of Wild Fauna and Flora Rules 2018 being in place to implement 
CITES  in  Pakistan,  its  national  legislation  status  is  listed  as  Category  2  by  the  CITES 
Secretariat. In July 2020, the Secretariat conveyed some observations regarding Pakistan’s 
institutional arrangements, which the Government considers having addressed ahead of the 
CITES Conferences of the Parties in November 2022. 

An  example  of  the  difficulties  faced  by  wildlife  in  Pakistan  is  the  snow  leopard. 
Government agencies as well as NGOs (including local partner organisations) are working 
to  address  threats  to  these  animals  and  their  ecosystems  in  Pakistan.  The  2018-2023 
Pakistan Snow Leopard & Ecosystem Protection Programme (PSLEP) aims to address the 
above-mentioned risks.  

A community-based Trophy Hunting Scheme is also in place to protect the population of 
markhor (wild goats). Hunting female or young markhor is prohibited with harsh penalties, 
and limited licences are granted for hunting older males, with 80% of the revenue attributed 
to local communities. 

5.3.2.  Waste  Conventions:  Basel  Convention  on  the  Control  of  Transboundary 
Movements of Hazardous Wastes and Their Disposal and Stockholm Convention 
on Persistent Organic Pollutants (POPs) 

The Pakistani Government adopted Standard Operating Procedures for the import of waste 
materials. A ban on the import of hazardous waste is included in the Import Policy Order 
of  2022.  In  July  2022,  the  federal  cabinet  approved  the  National  Hazardous  Waste 
Management  Policy  2022,  which  aims  to  handle  hazardous  waste  and  rationalise  its 

Page | 19 

 
 
imports. In this endeavour, the provinces, notably their environment protection agencies, 
have a critical role to play. The implementation plan for this Management Policy is in the 
process of elaboration. Press reports indicate that Pakistan imports  waste from different 
parts of the world, and generates its own hazardous waste too, including hospital waste, e-
waste, and pesticides. 

With respect to POPs, the Government prepared an updated National Implementation Plan 
for  Phasing  out  and  Elimination  of  Persistent  Organic  Pollutants  in  2020.  This  policy 
document is formulated in the context of the goal of environmentally sound and sustainable 
economic and social development for the country. 

A project by the Ministry of Climate Change and the UNDP on POPs, completed in April 
2021, updated the inventory of obsolete pesticides all over the country and tested some 
4,184 transformers’ oil in all the provinces. The way forward includes the elimination and 
destruction  of  polychlorinated  biphenyls  (PCBs)  contaminated  oil  and  transformers  by 
2028. 

POPs pesticides are no longer used in Pakistan as they are banned or not registered except 
for dicofol, added to the Stockholm Convention in May 2019, registered for use in cotton 
but no longer used since 2021. 

5.3.3.  Convention on Biological Diversity (CBD) and Cartagena Protocol on Biosafety 

Pakistan  faces  challenges  of  environmental  degradation  in  particular  because  of  the 
disastrous floods in 2022, which were preceded by extremely hot temperatures. Experts 
believe that due to  unsustainable and inefficient  use of the limited water  resources, the 
country could face acute shortage of water by 2040 if authorities do not take robust medium 
to long-term measures.  

Biological  diversity  is  declining  due  to  human  activities  and  the  degradation  of  natural 
habitats, including forestry and mangroves. According to Pakistan’s third national report 
cited by the CBD, 20 mammal species, 25 bird species, 6 types of reptiles, 5 types of fish 
and  8  marine  molluscs  are  presently  threatened,  but  these  figures  are  likely  to  be 
underestimated.  

A  National  Biodiversity  Strategy  and  Action  Plan  (NBSAP)  prepared  in  2018  remains 
valid until 2030, although the Global Biodiversity Framework adopted in December 2022 
during COP15 of the CBD calls for all Parties to align their national biodiversity strategies 
and action plans, including national targets before CBD COP16 (2024). 

Milestones  of  Pakistan’s  action  include  the  establishment  of  a  protected  areas  system 
including almost all major habitats and ecosystems and covering more than 10% of the 
country’s territory, with a goal of increasing to 15%, providing job opportunities to 5,500 
people  and  promoting  ecotourism.  Pakistan  has  designated  23  national  parks,  97  game 
sanctuaries and 104 game reserves (38). 

The Government launched the “Ten Billion Tree Tsunami Programme” (39) with a total 
cost of about Rs. 125 billion (€440 million). The Ministry of Climate Change along with 
Provincial and territorial Forest and Wildlife Departments is responsible for implementing 
this project.  Its overall objective is  to  revive forestation  through native flora  across the 
country. 

(38)  https://www.cbd.int/countries/profile/?country=pk  
(39)  An independent assessment of the sustainability and overall impact of the initiative is not available.  

Page | 20 

 
 
To regulate Genetically Modified Organisms (GMOs) and their products related activities, 
a National Biosafety Centre (NBC) was established in Pakistan in April 2006 which since 
then provides the secretarial support to the Biosafety Committees. Since its establishment 
the  NBC  has  processed  more  than  400  cases  of  GMOs  and  their  products,  related  to 
laboratory genetic manipulation work, field trials for Research and Development (R&D), 
import  and  export,  and  commercialisation  (sale  and  purchase).  The  Centre  has  been 
regulating the R&D and commercialisation of genetically modified cotton, corn, and other 
crops  (sugarcane,  chili,  tobacco,  wheat  etc.).  Pakistan  has  approved  the  commercial 
cultivation  of  GMO  cotton  and  a  few  No  Objection  Certificates  were  issued  for  the 
commercial production of corn, though not commercialised. 

5.3.4.  Conventions on Climate Change and Protection of the Ozone Layer (40) 

Pakistan faces serious exposure to climate change and suffered a dramatic environmental 
disaster  in  the  tragic  2022  floods.  Even  before  these  floods,  faster  glacier  melt,  rising 
temperatures, shifting seasons, and irregular rainfall patterns have been all affecting the 
flow of the river Indus, which will have a growing impact on agriculture, food production, 
and lives. Pakistan had its hottest March and hottest April on record in 2022, with both 
months  having  national  mean  temperatures  more  than  4°C  above  the  long  term 
average (41).  The  Government’s  actions  in  this  area  include  support  to  climate  resilient 
agriculture and increasing water security through the Recharge Pakistan Project.  

Smog is another major issue in Pakistan’s industrialised eastern Punjab region, where the 
provincial  capital,  Lahore,  is  clogged  with  smoke  throughout  the  winter  months. 
Authorities  said  they  were  working  to  solve  the  problem,  which  involved  thousands  of 
brick kilns. 

Under the Paris Agreement on Climate Change, on 21 October 2021 Pakistan submitted 
its updated ambitious NDC, aiming at an overall 50% reduction in projected emissions by 
2030  with  15%  from  the  country’s  own  resources  and  35%  subject  to  provision  of 
international grant finance. In addition - for enhanced contributions - new sectors and new 
gases have also been added to the updated document. To reach the target, Pakistan aims 
among others to shift to 60% renewable energy, and 30% electric vehicles by 2030 and 
completely ban imported coal (42). 

Government estimates show an emissions reduction of 8.7% between 2016 and 2021. The 
Government also announced it would adopt a Pakistan Cooling Action Plan (PCAP) by 
2026.  This  would  “identify  the  key  cooling  needs  and  prioritise  actions  for  addressing 
current  and  future  cooling  demands  with  the  minimum  possible  impact  on  the 
environment”. A Climate Change Gender Action Plan is also under preparation. 

While implementing the Montreal Protocol on Substances that Deplete the Ozone Layer, 
Pakistan phased out the first generation of Ozone Depleting Substances (ODSs) in 2009 
and  reduced  the  second  generation  ODSs  by  50%  in  2022  and  aims  to  achieve  67.5% 
reduction by 2025. Pakistan is also conducting preparations for the ratification of the Kigali 
Amendment to the Montreal Protocol (43).  

(40)  United  Nations  Framework  Convention  on  Climate  Change,  Kyoto  Protocol  to  the  United  Nations 
Framework  Convention  on  Climate  Change,  and  Montreal  Protocol  on  Substances  that  Deplete  the 
Ozone Layer. 

(41)  World Meteorological Organization.  
(42)  https://unfccc.int/sites/default/files/NDC/2022-06/Pakistan%20Updated%20NDC%202021.pdf  
(43)  The Kigali Amendment to the Montreal Protocol is an international agreement to gradually reduce the 

consumption and production of hydrofluorocarbons (HFCs). 

Page | 21 

 
 
Conclusions and priorities 

Pakistan has faced unprecedented environmental challenges caused by climate change 
in 2022, with extreme heat and severe flooding. Even before 2022, climate change and 
environmental degradation affected the environment of Pakistan putting pressure on the 
population, as well as on biodiversity and on wildlife. The Government of Pakistan has 
demonstrated commitment to environmental protection, including in the context of the 
Paris  Agreement,  and  has  taken  important  steps  in  implementation  of  other 
environmental conventions and agreements. On the other hand, the magnitude of the 
problems faced will require continued efforts and significant resources. 

5.4.  UN Conventions on Good Governance (Conventions 24-27) 

5.4.1.  International Drug Control Conventions (44) 

Pakistan remains a transit country with high rates of opiate prevalence. The country is one 
of the world’s active transit corridors for opiates and cannabis products, which are known 
to be trafficked through its long borders with Afghanistan and Iran. The construction of 
the  fence  along  the  border  with  Afghanistan  is  close  to  be  completed  according  to  the 
authorities.  While  it  might  alter  smuggling  routes  and  volumes  locally  and  in  the  short 
term, it is unlikely to have a long-term effect. Pakistan’s seaports, airports, postal services, 
and  unpatrolled  coastal  areas  allow  illicit  drugs  to  be  distributed  globally.  The  United 
Nations Office on Drugs and Crime (UNODC) estimates Pakistan is the transit country for 
45% of the opiates produced in Afghanistan. Precursor chemicals used to produce heroin 
and methamphetamine also transit to Pakistan before global distribution. The Government 
has reported significant seizures of narcotics and precursors in the period 2020-2022, the 
majority  of  which  constituted  by  hashish,  followed  by  opium  and  heroin.  Seizures  of 
methamphetamines are more limited but growing. 

Pakistan has taken some institutional steps towards decreasing transit through for example 
the establishment of Port Control Units (PCUs) and Air Cargo Control Units (ACCUs) in 
collaboration with UNODC.  

The Government recorded around 78,000 and 93,000 drug related arrests in 2020 and 2021 
respectively. Thanks to a legal reform adopted in August 2023, drug offences no longer 
carry the death penalty.  

Pakistan’s  National  Anti-Narcotics  Policy  of  2019  outlines  supply  reduction,  demand 
reduction, and interagency and international cooperation as its main objectives. 

Data relating to the number of drug users in Pakistan has been limited over the reporting 
period as the last survey was published in 2013 while the following only in 2022. The Anti-
Narcotics Force (ANF) is running four model rehabilitation centres and reported almost 
22,000 volunteer drug patients who have been treated in these centres in the period 2005-
2021. In addition, the Government reports 96 treatment facilities and 33 drop-in centres 
run by the public and private sector. These efforts to adopt health-based approaches to drug 
use are a positive step, however they remain limited in a country with the population size 
of Pakistan. The Ministry of Narcotics Control has adopted a policy on opioids substitution 

(44)  UN Single Convention on Narcotic Drugs (1961), UN Convention on Psychotropic Substances (1971) 

UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (1988). 

Page | 22 

 
 
 
therapy (OST) and has undertaken, in cooperation with UNODC and WHO, the process of 
educating treatment professionals.  

An Inter-Agency Task Force (ATF) on Counter Narcotics comprises 32 different agencies 
in the country working on anti-narcotics, led by the ANF. However, the latter seems to 
have insufficient funding to launch dedicated operation to combat drug trafficking. Despite 
this limitation, the Law Directorate of the ANF pursued 862 cases of which conviction was 
awarded in 530 cases, 266 dormant cases were given final orders while 66 were acquitted 
with a conviction rate of 89% during 2021-22 (45). Overall, 664 traffickers were convicted 
while 135 were acquitted during 2021-2022.  

5.4.2.  UN Convention against Corruption (UNCAC) 

In  2022  Pakistan’s  continued  to  feature  low  (140  of  180  countries)  in  the  Corruption 
Perceptions Index of Transparency International with a small deterioration of score over 
the past 3 years (46). Although the fight against corruption figures prominently in national 
political  debates,  the  perception  of  civil  society  is  that  corruption  continues  to  plague 
interaction  with  the  public  administration  at  different  levels.  Accusations  and  the  fight 
against corruption has been highly politicised and instrumentalised to undermine political 
opponents, weakening the trust in the civilian leadership and justice system. 

The EU supports the Government of Pakistan in its anti-money laundering and counter financing 
of  terror  efforts  through  a  contribution  agreement  with  United  Nations  Office  on  Drugs  and 
Crime  (UNODC)  for  Pakistan's  Action  to  Counter-Terrorism  (PACT).  Under  this  project, 
UNODC has facilitated combating financing of terrorism training to officers of the justice, law 
and order sector at inter-provincial level. 

The  National  Accountability  Bureau  (NAB)  is  Pakistan’s  main  anti-graft  agency 
responsible for eliminating corruption. NAB claims to have recovered more than USD 4.8 
billion since it was established in 1999, but the consequences for convicted perpetrators 
are rarely severe. The NAB Ordinance of 1999 was amended in July 2023.  This recently 
passed amendment gives the Chairman power to issue arrest warrants for individuals who 
refuse to cooperate in ongoing investigations. Arrested suspects can be held in custody for 
up to 30 days (47). 

The  UNODC  has  launched  the  second  review  cycle  of  Pakistan  in  2019  which  covers 
Chapter II (Preventive Measures) and Chapter V (Asset Recovery) of the UNCAC. The 
review process has faced delays due to the COVID-19 pandemic. The reviewers visited 
Pakistan in June 2022. The report from the review has not been finalised at the time of 
writing.  

Regarding money laundering and terrorism financing, in June 2018 Pakistan was put by 
the FATF on the list of jurisdictions under increased monitoring (“grey list”). In June 2022, 
the FATF confirmed that Pakistan had addressed all items of the 2018 and 2021 Action 
Plans and in September organised an on-site visit of the FATF/Asia Pacific Joint Group to 
confirm  that  the  progress  was  tangible  and  sustained.  After  that  visit,  Pakistan  was 
removed from the FATF “grey list” on 21 October 2022. The Government passed a law to 
establish  the  National  Anti-Money  Laundering  and  Counter  Financing  of  Terrorism 

(45)  Year Book 2021-22, Narcotics Control Division: www.narcon.gov.pk  
(46)  https://www.transparency.org/en/cpi/2022  
(47)  https://pakistancode.gov.pk/pdffiles/administrator0de01d110521bb3226cc107779213571.pdf  

Page | 23 

 
 
 
Authority within Pakistan to act as a focal point for FATF and related organisations, and 
to review policy, laws and regulations to counter the financing of terrorism. 

Conclusions and priorities 

Pakistan  makes  significant  efforts  in  combating  the  trafficking  of  narcotics,  but  this 
remains a serious problem given Pakistan’s location as a transit country, as well as its 
domestic consumption. Although efforts are being made to move from harsh punishment 
to health-approaches to tackle drug use, these should be further improved.  

There  continues  to  be  a  perception,  including  among  civil  society,  that  corruption  is 
pervasive. On the other hand, in 2022 Pakistan was deleted from the “grey list” of the 
FATF. 
ANNEX: PAKISTAN – TREATY RATIFICATION AND REPORTING  

Convention 

Ratification status 
Reservations 

Compliance with reporting obligations to 
monitoring bodies 

Human rights conventions 
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 

4. International Covenant on 
Economic Social and Cultural 
Rights 
5. Convention on the 
Elimination of All Forms of 
Discrimination Against Women 

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

7. Convention on the Rights of 
the Child 

Ratified: 12.10.1957 
No reservations 

No reporting obligations 

Ratified: 21.09.1966 
No reservations 

Compliant with reporting obligations 
•  Last report submitted on 28.10.2021. 

Ratified: 23.06.2010 
Reservations to 
multiple articles 
under the Covenant: 
Arts. 3, 6, 7, 12, 13, 
18, 19, 40. (48) 
Ratified: 17.04.2008 
No reservations. (49) 

Ratified: 12.03.1996 
Accession subject to 
the provisions of the 
Pakistan constitution. 
Reservation to Article 
29(1) 
Ratified: 23.06.2010 
Reservations made 
upon ratification; 
reservations made to 
Article 8, 28 and 30 
remain (50) 
Ratified: 12.11.1990 
No reservations 

Compliant with reporting obligations 
•  Last report submitted on 16.06.2022. (was 

due by 28.07.2020.). 

Compliant with reporting obligations 
•  Last report submitted on 24.05.2023. (was 

due by 30.06.2022.). 

Compliant with reporting obligations 
•  Last report submitted on 09.10.2018. 
•  Next report due by 01.02.2024. 

Compliant with reporting obligations 
•  Last report submitted on 16.06.2022. 

Compliant with reporting obligations 

(48)  Pakistan has reservations to multiple articles under the Covenant: Arts. 3, 6, 7, 12, 13, 18, 19, 40. 
(49)  A formal reservation was made (“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”) but in substantive terms this constitutes a declaration rather than a reservation 

(50)  Article  8:  ‘The  Government  of  the  Islamic  Republic  of  Pakistan  declares  that  pursuant  to  Article  8, 
paragraph 2, of the Convention, it does not take this Convention as the legal basis for cooperation on 
extradition with other States Parties’. 
Article  28:  ‘In  accordance  with  Article  28,  paragraph  1,  of  the  Convention,  the  Government  of  the 
Islamic Republic of Pakistan hereby declares that it does not recognize the competence of the Committee 
provided for in Article 20’. 
Article  30:  ‘The  Government  of  the  Islamic  Republic  of  Pakistan  does  not  consider  itself  bound  by 
Article 30, Paragraph 1 of the Convention’. 

Page | 24 

 
 
 
 
 
 
Convention 

Ratification status 
Reservations 

Compliance with reporting obligations to 
monitoring bodies 
•  Last report submitted on 03.08.2023. (was 

due by 11.06.2021). 

Labour conventions (51) 
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 
14. Convention concerning 
Minimum Age for Admission to 
Employment, No. 138 

15. Convention concerning the 
Prohibition and Immediate 
Action for the Elimination of 
the Worst Forms of Child 
Labour, No. 182 
Environmental conventions 
16. Convention on International 
Trade in Endangered Species of 
Wild Fauna and Flora 

Ratified: 23.12.1957  Compliant with reporting obligations 

•  Latest CEACR comments: 2021. 
•  Latest report received in 2020. 
•  Next regular report due in 2023. 

Ratified: 14.02.1951  Compliant with reporting obligations 

•  Latest CEACR comments: 2023. 
•  Latest report received in 2022. 
•  Next report due in 2025. 

Ratified: 26.05.1952  Compliant with reporting obligations 

•  Latest CEACR comments: 2023. 
•  Latest report: 2022. 
•  Next report due in 2025. 

Ratified: 11.10.2001  Compliant with reporting obligations 

•  Latest CEACR comments: 2023. 
•  Latest report received in 2021. 
•  Next report due in 2024. 

Ratified: 15.02.1960  Compliant with reporting obligations 

•  Latest CEACR comments: 2021. 
•  Latest report received in 2019. 
•  Next regular report due in 2023. 

Ratified: 24.01.1961  Compliant with reporting obligations 

Ratified: 06.07.2006 
Minimum 
specified: 14 years 

age 

•  Latest CEACR comments: 2023. 
•  Last report received: 2021. 
•  Next report due in 2024. 
Compliant with reporting obligations 
•  Latest CEACR comments: 2021. 
•  Latest report received in 2020. 
•  Next regular report due in 2023. 

Ratified: 11.10.2001  Compliant with reporting obligations 

•  Latest CEACR comments: 2021. 
•  Latest report received in 2020. 
•  Next regular report due in 2023. 

Acceded: 20.04.1976 
No reservations 

Compliant  with  reporting  obligations  in 
last two years (not compliant in 2019).  
•  Annual Report (2021) submitted on 

12.04.2022. 

•  Annual Report for 2020 submitted on 

12.03.2021. 

•  Annual Report for 2019 not submitted. 
•  Previous annual reports submitted: 2018 

AR on 04.02.2019; 2017 AR on 
04.04.2018; 2016 AR on 02.05.2017; 
2015 AR on 18.02.2015. 

•  Last (2019-2020) Implementation Report 

submitted on 12.03.2021.  

•  2018-2019 Implementation Report 

submitted on 04.02.2019. 

•  2015-2017 Implementation Report 

submitted on 02.05.2017. 

•  Earlier IRs submitted for 2013-2014, 

2011-2012 and 2007-2008. 

•  Annual Illegal Trade report submitted for 

2016, 2017, 2018 and 2020. 

(51)  Reservations  do  not  apply  in  the  ILO  system,  so  there  is  no  relevance  to  providing  information  on 

reservations under each of these conventions. 

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Convention 

17. Montreal Protocol on 
Substances that Deplete the 
Ozone Layer 

18. Basel Convention on the 
Control of Transboundary 
Movements of Hazardous 
Wastes and their Disposal 

Ratification status 
Reservations 
Acceded: 18.12.1992 
No reservations 

Compliance with reporting obligations to 
monitoring bodies 
Compliant with reporting obligations 
•  Most recent data for 2020 was submitted. 

An ODS licensing system has been 
established. 

Ratified: 27.06.1994 
No reservations 

Compliant with reporting obligations 
•  Last National Report for 2020 submitted 

19. Convention on Biological 
Diversity 

Ratified: 27.06.1994 
No reservations 

20. The United Nations 
Framework Convention on 
Climate Change  

Ratified: 01.06.1994 
No reservations 

on 29.12.2021. 

•  National Report for 2019 submitted on 

28.12.2020. 

•  National Report for 2018 submitted on 

31.12.2019. 

•  National Report for 2017 submitted on 

25.01.2019. 

Compliant with reporting obligations 
•  Last (sixth) National Report due 

31.12.2018 submitted in July 2019. 
•  Previous National Reports submitted: 

NR5 on 31.03.2014; NR4 on 08.01.2010; 
NR3 on 01.12.2006; NR2 on 09.11.2001; 
NR1 on 16.01.2008. 

•  Second National Biodiversity Strategy 

and Action Plan submitted on 13.04.2018. 

•  First NBSAP submitted 17.10.2000 
Compliant with reporting obligations 
•  Updated NDC submitted on 21.10.2021. 
•  Latest (Second) National Communication 

submitted on 09.08.2019. 

•  First Biennial Update Report (BUR) 

submitted on 28.04.2022. 

•  BURs have not been submitted in 2014, 

2016, 2018, and 2020. 

21. Cartagena Protocol on 
Biosafety 

Ratified: 02.03.2009 
No reservations 

Compliant with reporting obligations 
•  Fourth National Report on 

22. Stockholm Convention on 
Persistent Organic Pollutants 

Ratified: 17.04.2008 
No reservations 

23. Kyoto Protocol to the 
United Nations Framework 
Convention on Climate Change 
Good governance conventions 

Ratified: 11.01.2005 
No reservations 

Implementation of the Cartagena Protocol 
updated on 12.06.2020. 

•  Third National Report submitted on 

20.10.2016. 

•  Second National Report submitted on 

12.09.2014. 

•  First National Report not submitted 
Partially compliant with reporting 
obligations 
•  Updated NIP for Phasing out of POPs 

under Stockholm Convention published 
on 12.02.2020. 

•  Updated NIP addresses required 

amendments of COPs 4-6, but not those 
of COP 7 (update due 15.12.2018) and 
COP 8 (update due 18.12.2020)  
•  Fourth National Report submitted on 

12.06.2020. 

•  Fifth Report submitted on 24.08.2022. 
•  Third National Report due 31.08.2014 

submitted on 22.01.2016. 

No reporting obligations 

Page | 26 

 
 
 
Convention 

24. United Nations Single 
Convention on Narcotic Drugs 

25. United Nations Convention 
on Psychotropic Substances 
26. United Nations Convention 
against Illicit Traffic in Narcotic 
Drugs and Psychotropic 
Substances 

Ratification status 
Reservations 
Ratified: 
09.07.1965 (52) 
No reservations (53) 
Acceded: 09.06.1977 
No reservations 
Ratified: 25.10.1991 
No reservations 

27. United Nations Convention 
against Corruption 

Ratified: 31.08.2007 
No reservations (54) 

Compliance with reporting obligations to 
monitoring bodies 
Partially compliant with reporting 
obligations 
•  No reports and statistics provided for 

2020 under the Convention against Illicit 
Trade (2021 not yet reported on) 

•  Other reports and statistical information 

provided, with few exceptions.  

Review by INCB 
•  Last INCB mission took place in 2012.  
•  No indication of non-compliance in INCB 

reports 

No reporting obligations 
Compliant with notification requirements 
Review by UNODC & peer review 
•  Executive summary of first cycle review 

published in 2017. 

•  Review in 2nd cycle ongoing; no report 

issued yet. 

(52)  Participation in the Convention by virtue of ratification, accession or succession to the Protocol of 25 

March 1972 or to the 1961 Convention after the entry into force of the Protocol: 02.07.1999 

(53)  Reservations made upon the original ratification in 1965 were: “The Government of the Islamic Republic 
of Pakistan will permit temporarily in any of its territories: (i) The quasi-medical use of opium; (ii) The 
use of cannabis, cannabis resin, extracts and tinctures of cannabis for non-medical purposes, and (iii) 
The production and manufacture of and trade in the drugs referred to under (i) and (ii) above.” 

(54)  Declaration made in line with Article 66(3) of UNCAC that Pakistan does not consider itself bound by 
the provisions of Article 66(2), arbitration and potential referral of cases to the International Court of 
Justice. 

Page | 27