TI Pakistan

Transparency International Pakistan has published The Civil Society Governance Diagnostic Assessment for Pakistan. The report introduces a comprehensive set of governance reform recommendations designed to address key areas important for economic growth namely: Fiscal Governance, Financial Regulation and Rule of Law.

TI Pakistan highlights that as Pakistan undertakes structural economic reforms, in line with International Monetary Fund (IMF) supported 37-month Extended Fund Facility (EFF) worth US$ 7 billion, the parallel challenge of reforming governance systems must not be overlooked. The report reveals that Pakistan’s economic problems are underpinned by governance issues’ emanating from lax rules, corruption and ineffective implementation of policies.

In total, the report has put forth 54 pivotal governance benchmark recommendations necessary for economic growth. Transparency International Pakistan hopes that this report contributes to informing practical, and inclusive reform pathways including contributing to the IMF’s ongoing governance diagnostic exercise in the country.

Final_Copy of Civil Society Governance and Anti-Corruption Diagnostic Assessment on Pakistan Report
Civil Society Governance Diagnostic Assessment on Pakistan
internal-Monetary-Fund
Pakistan: First Review Under the Extended Arrangement Under the Extended Fund Facility

Section A: MEASURES TO ENHANCE FISCAL GOVERNANCE TRANSPARENCY

BM No. Sections & Statements Timeframe Lead Agency / Institution Status Progress Notes
1 Strengthen the role of Parliament in budget process by empowering parliamentary Standing Committees in the budget vetting process Jun-26 Ministry of Law & Justice
Not Initiated
 Standing Committees currently lack authority over Finance Bills. Amendments to Rule 104 needed.
2 Increase number of days allocated to the budget approval process and parliament to convene after presentation of the Budget and pass the recurring expenditure for a period of 30 or 45 days. Dec-25 Ministry of Law & Justice
Not Initiated
 Requires change in budget approval rules. Currently, only 2 days are allocated for debate.
3 Extend the power of the Senate to scrutinize and vote on Money Bills to enhance provincial say in the allocation of national resources Jun-26 Ministry of Law & Justice
Not Initiated
 Senate can recommend changes, but lacks voting powers on Money Bills. Reform requires constitutional amendment.
4 Publish the details regarding proceedings and implementation of Rules 201(6) and 201(7) by Parliament Secretariats Jun-26 National Assembly & Senate Secretariats
Partially Implemented 50%
 Despite 202 recommendations by Committees in 10 years, none were accepted or explained.
5 Replace Article 84 and Article 124 with proviso to permit, to place the case for amendment to certain expenditure provision before the National/Provincial Assembly Standing Committee on Finance and Revenue for prior emergency approval. Jun-26 Ministry of Law & Justice
Not Initiated
 Constitutional articles currently allow post-facto Executive budget changes. Parliamentary control is minimal.
BM No.Sections & StatementsTimeframeLead Agency / InstitutionStatusProgress Notes
6Remove the undue advantage of ‘tax shelters’ from Agriculture sector by Amending Item 47 of the Fourth Schedule of the Constitution, and ensure that all sectors face the same tax barsDec-25Federal Government
 
Partially Implemented 50%
Agriculture sector remains outside federal tax net. Reform requires constitutional change.
7Implement the principle of ‘Right of First Purchase’ to reduce grey areas in real estate, ensuring that all property transactions negotiated between two parties – seller and buyer – are uploaded on Federal Board of Revenue (FBR) website, detailing the property characteristics and agreed price to enable a 3rd party to bid higher for the same propertyDec-25Federal Board of Revenue (FBR)
 
Not Initiated
Requires FBR portal to record agreed prices and offer transparency in real estate transactions.
8All property transactions must be taxed at a single, uniform tax based on market value, consolidating existing taxes into a single levy to streamline real estate taxation and curb tax evasion.Dec-25Federal Government, FBR and Provincial Revenue Authorities
 
In Progress 30%
Multiple levies still apply inconsistently. Coordination between federal and provincial bodies needed.
9Upload Summaries of all Letters of Credit (LIC), specifying the product(s) and f.o.b. price, on dedicated Customs Department website along with the valuation system must be updated based on international best practices to address tax evasion and under-invoicing in ImportsDec-25Pakistan Customs, FIn Progress
 
Not Initiated
Customs portal exists but lacks transparency on FOB prices. Valuation rulings outdated.
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
10 The Divisions, and associated departments, autonomous and semi-autonomous agencies, related to subjects that have been devolved to the provinces vide 18th Constitutional Amendment must be decentralized Jun-26 Federal Govt
Partially Implemented 50%
 Committees formed in 2024 for downsizing; implementation pending.
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
11 BISP shall adopt lean management practices to streamline its administrative structure by leveraging its extensive automation Dec-25 Benazir Income Support Program
Not Initiated
 Despite automation, administrative staffing remains bloated. Multiple DGs and layers identified.
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
12 Prioritize the Public Private Partnership (PPP) approach: privatize management, not assets. Where assets are privatized, exclude land which must remain with the government to prevent conversion to non-industrial uses. Jun-27 Federal Government, Privatization Commission, Ministry of Finance
In Progress 30%
 Government has listed 24 SOEs for privatization; PPP discussions gaining ground.
13 Ensure compliance with PPRA ordinances 2002 and PPRA Rules 2004 in the State-owned Enterprises (Governance and Operations) Act 2023 to address SOEs discretion in procurement processes Dec-25 Federal Government
Not Initiated
 SOEs currently allowed to follow their own procurement rules under SOEs Act 2023. Requires amendment of Section 17(2).
14 The composition of SOEs boards must ensure that there is no Conflict of Interest (COI) between board members and public and private entities. On July 15, 2025, Ministry of Finance & Revenue
In Progress 30%
 the Cabinet Committee on State-Owned Enterprises (CCoSOEs) approved the appointment of six independent directors to the boards of the Pakistan Television Corporation (PTVC) and Pakistan Broadcasting Corporation (PBC).

SECTION B: BUILDING ROBUST FINANCIAL OVERSIGHT SYSTEMS FOR FISCAL INTEGRITY

BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
15 Introduce a binding legal provision mandating the appointment of the Leader of the Opposition as PAC Chair at both national and provincial PACs to institutionalize impartial parliamentary oversight. Jun-26 National & Provincial Assemblies
Not Initiated
 No legal provision mandates this at the moment. In Sindh PAC Chairman is member of the sitting government.
16 Establish statutory timelines and ensure adequate resourcing for PACs to complete and submit audit reports within two years of the fiscal year's end. Jun-26 Auditor General of Pakistan
Not Initiated
 PACs face severe backlogs and lack of technical support.
17 Parliamentary disclosures under FRDL Act including debt status must be published online. Dec-25 Ministry of Finance and Central Debt Management Office
Partially Implemented 50%
 Limited reports are publicly available but rarely debated in parliament.
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
18 The Government must publish a 5-year plan on Digitization of Public Service Delivery, providing a roadmap to automate process for essential public services, minimizing Discretionary Powers and abuse of authority. Jun-26 Federal Government, Ministry of Science and Technology
In Progress 30%
 As per the media reports, the federal government in coordination with the provincial governments is working on digital transformation plan and its effective implementation. The plan envisions digitization of economy and key public services to promote transparency.
19 Mandate the upgradation of the AGPR’s SAP system and direct FBR to enforce uniform tax credit adjustments at the DAO level, ensuring alignment with tax laws and promoting efficient, equitable public financial management. Dec-25 Accountant General Pakistan Revenues
In Progress 30%
 It is reported that the AGPR is in process to upgrade the SAP module.
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
20 Implement a fully digitized business registration system, reducing human interaction. Jun-27 FBR
In Progress 30%
 The current procedure requires approaching different offices, interacting with officials, filling out forms, depositing necessary fees and etc.
21 Make a concerted effort, through the State Bank of Pakistan, to increase the electronic financial transaction footprint by instituting incentives for ‘sellers’ and ‘buyers’. This can be achieved by providing cash back to both parties equal to, say, one percent of the total transaction value over the period of one year Jun-27 State Bank of Pakistan
Not Initiated
 Pakistan’s informal economy remains large, with limited documentation of financial transactions. Digital
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
22 The position of Federal Board of Revenue (FBR) Chairman must be a fixed-tenure appointment and opened to qualified private sector professionals to ensure stability and leadership continuity. Jun-27 Federal Government
Not Initiated
 The position of Chairman should be converted into a fixed-tenure role, ideally for a term of three to five years, with protections from arbitrary changes.
23 All tax related decisions, including court decisions and notifications (SROs, office orders, file notes, etc.) regarding tax and administrative changes must be uploaded to the FBR website to avoid arbitrariness in interpretation. Jun-26 FBR
Not Initiated
 Decisions remain classified. No routine disclosures of tax related decisions.
24 All matters related to taxes must be automated end to end, with explanatory notes in simplified language to ensure easy comprehension Jun-26 FBR
Not Initiated
 Automation remains minimal.
25 Monetary, fiscal and administrative incentives and supports, offered at the time the investment decision is made, is not altered mid-stream. On July 25, 2025 Federal Government
Not Initiated
 Frequent and unexpected changes create uncertainty, increase costs, and undermine investor confidence.
26 Mandate a Centralized, Public, and Verified Beneficial Ownership Registry. Jun-26 SECP
Implemented 70%
 the Securities and Exchange Commission of Pakistan (SECP) vide S.R.O. 1356(I)/2025 has introduced amendments to the Companies Regulations, 2024. The amendments provide for creating a centralized Ultimate Beneficial Owners (UBO) registry to enhance corporate transparency in Pakistan. The registry will publish accurate and up-to-date beneficial ownership data for companies for each financial year on or after June 30, 2025.
27 Mandatory publication of Tax Directory of public officials (drawing remuneration from the public exchequer) within six months of close of tax year. June 20, 2025 Federal Government
Implemented 70%
 The Senate passed the Civil Servants (Amendment) Bill, 2025, which mandates civil servants in grades BPS-17 to BPS-22 to publicly declare both their domestic and foreign assets, including those of their immediate family members.

SECTION C: ENHANCING INSTITUTIONAL INTEGRITY AND ANTI-CORRUPTION FRAMEWORKS

BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
28 A Lean Anti-Corruption Agency with an Oversight Committee should be formulated for NAB’s Accountability Dec-25 Federal Government
Not Initiated
 Pending approval and institutional design.
29 NAB should make a thorough analysis of the entire chain of system to improve its conviction rate Dec-25 NAB
Not Initiated
30 The timeline to dispose of a Corruption case must not exceed 30 days Dec-25 NAB
Not Initiated
31 The option of Plea Bargain should only be exercised for approver/s in a transparent manner, only when the main accused in a corruption case can be prosecuted on the approver’s confession Dec-25 Federal Government
Not Initiated
32 NAB must publish clear Rules within three months Dec-25 NAB
Not Initiated
33 NAB should ensure that the reference prepared and successfully tried in the Accountability Courts should be upheld in all subsequent review petitions in High Courts and Supreme Court Dec-25 NAB
Not Initiated
34 Strengthen the institutional capacity, independence, and resourcing of provincial anti-corruption establishments. Jun-26 Provincial Anti-Corruption Establishments
In Progress 30%
35 Mandating regular publication of UNCAC Country Report July 30, 2025 Federal Government
Partially Implemented 100%
 The Ministry of Law and Justice, Government of Pakistan has published the UNCAC Country Review Report on Pakistan. The review conducted by Kenya and Qatar pertains to the implementation by Pakistan of Articles 5-14 and 51-59 of the United Nations Convention against Corruption for the review cycle 2016-2021
36 At least 20% of budgetary allocation of NAB, FIA, Provincial Anti-Corruption Establishments must be dedicated to prevention and awareness Jun-26 NAB
Partially Implemented 50%
37 Integrate Anti-Corruption and civic education in the curriculum of the elementary, secondary and degree programs of educational institution Jun-27 Federal Government
Not Initiated
38 Adopt a robust and comprehensive Whistleblower Protection Legislation. May 16, 2025, Ministry of Law and Justice
Implemented 70%
 Parliamentary body unanimously, approved the Whistleblower Protection and Vigilance Commission Bill, 2025. The bill, presented by the Ministry for Law and Justice aims to establish a robust legal framework to encourage whistle blowing while ensuring whistleblowers are shielded from reprisals. The draft bill is not yet publicly available.
39 Enact Conflict of Interest (COI) Regulations for Public Officials Dec-25 Ministry of Defence, Ministry of Law and Justice
Not Initiated
BM No.Section & StatementTimeframeLead AgencyStatusProgress Notes
40Strengthen Implementation of RTI Laws Across All Jurisdictions including adoption of RTI law in Gilgit Baltistan (GB) and Azad Jammu and Kashmir (AJK) through enforcement and digitizationDec-25Right to Information Commission (RTI) and Ministry of Information
 
In Progress 30%
 
41Enhance public awareness, accessibility and utilization of Right to Information (RTI) laws and proceduresJun-26Right to Information Commission (RTI) and Ministry of Information
 
In Progress 30%
 
42Establish a systematic Cabinet decision publication mechanism for public disclosure of key decisionsJun-26Cabinet Division
 
Not Initiated
 
43Improving Composition of Information Commissions by ensuring Gender Parity and Timely Appointments in Information CommissionsJun-26Federal and Provincial Government, Ministry of Information and Information Departments
 
In Progress 30%
 
44Publish Quarterly Reports of Public Bodies Highlighting Data on Information Requests, Appeals/Complaints, Penalties and Performance of Public BodiesDec-25RTI Commissions
 
In Progress 30%
 
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
45 To ensure full efficacy of the e-procurement system, fully digitised Evaluation Procedure as well as Digitised Complaint Handling Process, without the involvement of department officials, must be ensured Dec-25 Pakistan Public Procurement Regulatory Authority (PPRA)
In Progress 30%
46 Amend PPRA Rule 38B to ban Single Tendering Dec-25 Federal Government
Not Initiated
47 Address Conflict of Interest in the Composition of PPRA Board Dec-25 Federal Government
Not Initiated
BM No. Section & Statement Timeframe Lead Agency Status Progress Notes
48 Addition of a dedicated chapter on Local Government, outlining the institutional structure, power, functions, tenure and list of jurisdiction over local subjects, along the lines of the existing chapters on federal and provincial governments Jun-26 Federal Government
Not Initiated
49 Institute Provincial Finance Commission (PFC) along the line of the National Finance Commission (NFC) to determine distribution of provincial fiscal resources between the province and local entities and among local entities Jun-26 Supreme Court, High Courts
Not Initiated
BM No.Section & StatementTimeframeLead AgencyStatusProgress Notes
50Align Public Financial Management (PFM) with climate finance, by including climate change as a multi-sectoral theme at each stage of financial managementDec-25Ministry of Finance
 
Implemented 70%
 
51The Ministry of Finance must made publicly available Climate Budget Tagging Data as part of budget data or as a separate report on climate finance on yearly basisDec-25Ministry of Finance
 
Partially Implemented 50%
 
52Implement Capacity Building of Supreme Auditing Institutions on Climate Finance TransparencyJun-27Auditor General of Pakistan
 
In Progress 30%
 
53Ensure full transparency in climate finance flows, allocation, procurement and distribution process, through a national tracking system accessible to citizens and civil societyDec-25Ministry of Climate Change and Provincial Climate Change Departments
 
In Progress 30%
Some data released via RTI; full transparency not institutionalized. No proactive disclosure.
54The Ministry of Climate Change & Environmental Coordination (MOCC&EC) must establish Equitable Benefit-Sharing mechanisms as part of Carbon Market Activity RulesDec-25Ministry of Climate Change & Environmental Coordination
 
In Progress 30%