ICNL Comments on the Policy for Regulation of International Non-governmental Organizations in Pakistan


This paper addresses the Policy for regulation of International Non-governmental Organizations (INGOs) in Pakistan adopted in October 2015. ICNL has reviewed this policy in light of Pakistan’s international legal obligations and good regulatory practices.

ICNL provides an analysis of the most concerning provisions of the INGO Policy, with recommendations to improve it. Key restrictions of the INGO Policy include:

  • An onerous and unclear registration process with no safeguards against arbitrary denial of registration of INGOs.
  • Prior government permission required to: (a) access foreign funds; (b) provide direct or indirect assistance to other NGOs; and (c) dispose of assets.
  • A thirty percent cap on administrative expenses.
  • Prior government permission required to hire foreign nationals, and foreign nationalsmay constitute only 10 percent of an INGO’s staff.
  • Broad and inappropriate bans on political activity and activities inconsistent with government interests or policy.
  • Restriction on INGOs from working in locations not previously authorized.
  • Government’s unlimited right to information and onerous reporting requirements.
  • Broad and inappropriate grounds for cancellation of registration.
  • No right to judicial appeal of adverse decisions and actions taken by the government.