Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Pakistan

Equal Remuneration Convention, 1951 (No. 100) (Ratification: 2001)
Discrimination (Employment and Occupation) Convention, 1958 (No. 111) (Ratification: 1961)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on equality, the Committee considers it appropriate to examine Conventions Nos 100 (equal remuneration) and 111 (discrimination in employment and occupation) together.

Convention No. 111 – National policy to promote equality of opportunity and treatment in respect of employment and occupation

Articles 1(1)(a), 2 and 3(b). Prohibited grounds of discrimination. Direct and indirect discrimination. Legislation. Provinces. The Committee notes the Government’s indication in its report that: (1) in the Gilgit-Baltistan administrative territory, section 45 of the draft Shops and Establishments Bill prohibits all forms of discrimination; and (2) it has been determined that labour laws in the Khyber Pakhtunkhwa province should include provisions similar to those of the Sindh Minimum Wages Act, 2015. However, the Committee has already noted that such provisions omit the grounds of national extraction and social origin, and that “political affiliation” is not “political opinion” within the meaning of Article 1(1)(a) of the Convention. Likewise, the Committee notes that neither the Sindh Companies Profits (Workers’ Participation) Act, 2015, nor the Sindh Employees’ Old-Age Benefits Act, 2014, that are mentioned by the Government, prohibit discrimination on the basis of at least all the grounds listed in Article 1(1)(a). The Committee also notes the indication that Article (1)(1)(a) is not applicable in the Islamabad Capital Territory and that the local authorities have requested assistance from the ILO to develop new labour laws. The Committee welcomes that, in 2024, Sindh and Punjab provinces have prepared, with the assistance of the ILO, a draft Labour Code which: (1) aims at eliminating discrimination in respect of employment and occupation; (2) provides for a definition of both direct and indirect discrimination; and (3) prohibits discrimination on at least all the grounds enumerated in Article (1)(1)(a). The Committee urges the Government to take the necessary measures to ensure that provisions explicitly defining and prohibiting direct and indirect discrimination in all aspects of employment and occupation on at least all the grounds enumerated in Article (1)(1)(a) of the Convention will be adopted in the near future in all the provinces of the country and that they will cover all categories of workers, including civil servants. Please provide information on any progress achieved in this regard.

Articles 1 to 3. National policy for equality of opportunity and treatment. Sex. The Committee welcomes the Government’s indication regarding the following initiatives in Khyber Pakhtunkhwa province: (1) implementation of a 10 per cent quota for women in the public sector; (2) childcare facilities; and (3) training programmes enabling women workers to increase their knowledge of their rights. The Committee also welcomes: (1) the Sindh Women Agricultural Workers Act, 2020, which ensures women’s participation in decision-making and fosters their empowerment through work; and (2) the quota system for women in government jobs that has been implemented in Gilgit-Baltistan administrative territory. However, the Committee notes the indication in the ILO Policy Brief, 2025 (“What lies behind the gender pay gap in Pakistan”) that the country presents one of the highest gaps worldwide between male and female employment rates and that, according to the 2023–27 Decent Work Country Programme (DWCP) for Pakistan, the country has the lowest rate of female entrepreneurship in the world due to discriminatory social norms. In this respect, the Committee notes that the 2024 Global Gender Gap report of the World Economic Forum shows that: (1) the labour force participation rate is estimated at 24.5 per cent for women, versus 80.6 per cent for men; (2) 91.7 per cent of women work in the informal economy (versus 82.1 per cent of men); (3) firms with female majority ownership represent only 2.1 per cent of the total number of firms; and (4) 3.4 per cent of firms have a woman as the top manager. The Committee also notes that 16.2 per cent of Members of Parliament are women and that only 5.9 per cent of ministerial positions are held by a woman. As far as educational attainment is concerned, the Committee notes that the 2024 Global Gender Gap report shows that only 68.3 per cent of girls are enrolled in primary education, 38.2 per cent in secondary education, and 12.9 per cent in tertiary education (versus 78 per cent, 45.3 per cent and 13.9 per cent of boys, respectively). In this respect, the Committee notes with interest the adoption of: (1) the Khyber Pakhtunkhwa Education Sector Plan 2020/21-2024/25, which aims at delivering good quality learning opportunities for all in the province; (2) the National Education Policy Development Framework, 2024, which, in view of the fact that girls lack education opportunities, recommends a set of guiding principles at the national and provincial levels; and (3) the Federal Foundational Learning Policy, 2024, which aims at creating an environment enabling every child to develop minimum proficiency in reading and mathematics. The Committee also welcomes the Government’s indication in its report to the UN Human Rights Council that: (1) 55,000 female students have been provided with skills development courses along with a monthly stipend; and (2) in Punjab, free vocational training was granted to 1,679 women belonging to minority communities (A/HRC/WG.6/42/PAK/1, 10 November 2022, paras 32 and 102). The Committee welcomes that Pakistan’s 2023–27 DWCP aims at: (1) increasing the participation of women in the labour market as well as in technical and vocational education and training; and (2) developing gender-responsive strategies at the federal and provincial levels to accelerate the transition from informal to formal employment. Lastly, the Committee welcomes the adoption of a Home-Based Workers Act in Balochistan and Punjab. The Committee asks the Government to continue to take proactive measures to address: (i) discrimination against girls and women, including those belonging to ethnic minority groups, and gender stereotypes regarding their role in employment and society; and (ii) women’s low participation in the labour market. The Committee also asks the Government to provide detailed information on the impact of the above-mentioned measures and policies on the situation of girls and women in employment and occupation, including statistical data on: (i) enrolment in education and vocational training, disaggregated by sex and field of studies; and (ii) the participation of men and women in the labour market, disaggregated by occupational category, and in the informal economy, if possible. The Committee also requests the Government to provide information on any cases of discrimination against girls and women in education, employment and occupation, and their outcome.

Sexual harassment. The Committee welcomes the Government’s indication that the Sindh Labour Department has: (1) prepared, in multiple languages, a Code of Conduct, which shall ensure a work environment free of harassment and intimidation for women; (2) designated competent authorities with a view to ensuring that all the employees are informed about the Code of Conduct and the process for addressing sexual harassment complaints; and (3) appointed a standing Inquiry Committee. The Committee also welcomes the establishment of a similar committee in Khyber Pakhtunkhwa province. The Committee notes with interest that, as a result of the adoption of the Protection against Harassment of Women at the Workplace (Amendment) Act, 2022, the definition of: (1) “employee” now includes informal workers without a contract, freelancers, domestic workers, interns, or trainees; (2) “workplace” has been expanded to encompass any location where professional services are rendered; and (3) the definition of “harassment” includes quid pro quo – e.g. blackmail and hostile or offensive work environment sexual harassment. In this respect, the Committee notes that, in February 2025, the Supreme Court of Pakistan delivered a Judgment in which it confirmed the decision to impose the major penalty of compulsory retirement from service to a driver who had been found guilty of harassing a lady doctor. Lastly, the Committee welcomes that the draft Punjab and Sindh Labour Code prohibits sexual harassment at work and provides for a gender-neutral definition of sexual harassment. The Committee reiterates its request that the Government extend to men the protection against sexual harassment in employment and occupation that has already been awarded to women. The Committee also requests the Government to continue to provide information on: (i) the adoption of laws and provisions prohibiting sexual harassment at the workplace and the establishment of mechanisms to adjudicate sexual harassment complaints in all the provinces of the country; (ii) any steps taken to raise awareness of the laws on sexual harassment among workers and employers, their respective organizations, as well as the public; (iii) any measures taken to train labour inspectors and judges on the issue of sexual harassment in employment and occupation; and (iv) the number and outcome (sanctions imposed and remedies granted) of sexual harassment cases at the workplace.

Transgender and intersex persons. The Committee notes the Government’s indication that: (1) the Khyber Pakhtunkhwa Minimum Wages Notification, 2023, provides that transgender workers are entitled to the same minimum wages as male workers for work of equal value; and (2) in Punjab and Khyber Pakhtunkhwa provinces and Gilgit-Baltistan administrative territory, awareness-raising campaigns on discrimination against transgender persons will be organized. However, the Committee notes from the 2023–2027 DWCP that discrimination against transgender persons in the world of work remains to be addressed within the “Leaving No One Behind” strategy (page 33) and that the UN Human Rights Committee expressed concern about reports of discrimination against lesbian, gay, bisexual, transgender and intersex persons (CCPR/C/PAK/CO/2, 2 December 2024, para. 10). Lastly, the Committee notes with concern that, in its Report No. 2024-02, ¨the Human Rights Commission of Pakistan stated that the Khunsa (Intersex) Persons (Protection of Rights) Bill, 2023 – which, if adopted, will repeal the progressive Transgender Persons (Protection of Rights) Act, 2018 – appears to discriminate indirectly against gender-diverse communities while purporting to protect their rights. The Committee urges the Government to take steps to ensure that transgender and intersex persons are not discriminated against in all aspects of employment and occupation. Please provide information on any progress made towards the adoption of the Khunsa (Intersex) Persons (Protection of Rights) Bill, 2023, and any cases of discrimination based on gender identity dealt with by the labour inspectors or the courts, and their outcome.

Religion. The Committee notes the Government’s indication that: (1) the Punjab Minimum Wages Act, 2019, as well as the Khyber Pakhtunkhwa and Gilgit-Baltistan labour laws prohibit discrimination on the ground of religion; and (2) in Sindh, the 5 per cent quota for non-Muslim minorities in government jobs is rigorously monitored. The Committee welcomes that, in Punjab and Khyber Pakhtunkhwa provinces, a 2 per cent quota was introduced for admission of minorities in public sector universities and other education institutions (A/HRC/WG.6/42/PAK/1, 10 November 2022, para. 32). However, the Committee notes that, while the United Nations (UN) Committee on the Elimination of Racial Discrimination (CERD) has welcomed the steps taken to promote inclusivity and multilingualism (such as the publication of textbooks for students belonging to several ethno-religious minority groups), it has also expressed concern about the exclusion of members of these groups, such as Ahmadis, from the seats reserved for non-Muslim candidates in the National Assembly, the Senate and provincial assemblies (CERD/C/PAK/CO/24-26, 24 September 2024, paras 19 and 33). The Committee also notes with concern that: (1) according to the 2023–2027 DWCP for Pakistan, religious minorities are part of the target groups of the “Leaving No One Behind” strategy, and jobs like sewage cleaning are performed by Christian workers who are, for the most part, unprotected daily wage workers (pages 14 and 33); and (2) the Annual Statistical Bulletin of Federal Government Employees for 2022–23 shows that, out of the 357,025 employees, only 11,066 posts are filled by minorities: 83.5 per cent are Christians, 13.86 per cent are Hindus, and 2.22 per cent, 0.31 per cent and 0.11 per cent belong to Ahmadis, Sikh and other minorities, respectively (page 207). The Committee again urges the Government to continue to: (i) actively promote equality of opportunity and treatment in education, employment and occupation for members of religious minorities; and (ii) provide information on any measures taken in this regard. The Committee also asks the Government to provide detailed information on the implementation of the quotas for members of religious minorities and the concrete impact on their access to education, vocational training and employment, as well as statistical data disaggregated by religion, sex and field of occupation.

Social origin. The Government reports that: (1) the Sindh authorities are committed to preventing discrimination and ensuring equal treatment for all workers; (2) in Khyber Pakhtunkhwa province, no disaggregated data is available concerning the employment of Dalits; and (3) in Gilgit-Baltistan administrative territory, there is no discrimination against any sub-caste in job appointments. The Committee notes, however, that CERD expressed concern about the higher rates of absence and drop-out among children and students belonging to ethnic minority groups and scheduled castes, in particular in rural communities, as well as discriminatory employment and advertisement practices based on racist stereotypes of certain ethnic minority groups or castes (CERD/C/PAK/CO/24-26, para. 21(c) and (f)). The Committee urges the Government to take measures, both at the federal and provincial levels, to enforce the prohibition of discriminatory practices targeting members of castes, including in education, employment and job advertisement. Please provide information on any progress made in this regard.

Convention No. 100 – Principle of equal remuneration for men and women for work of equal value

The Committee recalls that the underlying causes of the gender pay gap are closely related to equality of opportunity and treatment between men and women in employment and occupation, and in particular to matters such as access to employment and occupation, occupational segregation, an unbalanced distribution of family responsibilities, and gender roles and stereotypes. The Committee refers, in this regard, to its comments above on Convention No. 111.

Articles 1 to 4. Gender pay gap. The Committee notes the Government’s indication that, while there are no barriers to women’s labour force participation in Khyber Pakhtunkhwa, there is still a need to promote gender equality in the workplace and collect comprehensive data on gender pay gaps and occupational segregation. In this province, deductions for employer-provided transportation and wage increments based on performance or experience can sometimes mask wage disparities. The Committee recalls that, as indicated by the Government, the fact that no formal complaint regarding wage discrimination based on sex has been reported does not mean that there is no gender pay gap in practice in the country. The Committee notes from the above-mentioned ILO Policy Brief, 2025 that the gender pay gap: (1) is close to zero in the formal economy, low in the public sector, and above 40 per cent in the informal economy and household sector; (2) is higher among workers older than 35, which may reflect the fact that, when women resume work after childbirth, they might opt for more flexible (but often lower-paid) jobs in order to cope with their family responsibilities; and (3) is lower among workers with higher educational attainments. Lastly, the Committee welcomes that, according to the draft Punjab and Sindh Labour Code, the Equal Employment Opportunity Office will be tasked with promoting equal remuneration and producing studies on objective job evaluations to address the gender pay gap. The Committee asks the Government to: (i) take the necessary measures to address the gender-based occupational segregation and the gender pay gap, and provide information on any progress achieved in that regard (if possible, including in the informal economy); (ii) continue to collect and compile statistical data on the levels of remuneration disaggregated by sex, occupation, age and province; and (iii) provide such data together with any available information on the gender pay gap. Lastly, the Committee requests the Government to provide information on any cases of wage discrimination based on sex reported to or dealt with by labour inspectors or the competent authorities (number of cases and outcome).

Articles 1 and 2. The principle of equal remuneration for men and women for work of equal value. Legislation. The Committee notes with satisfaction the Government’s indication that section 7 of the Balochistan Payment of Wages Act, Act No. XIII of 2021, as well as section 26 of the Payment of Wages Act, 2013, the Minimum Wages Rules, 2022, and section 2(k) of the Minimum Wage Notification, dated 21 September 2023, that are applicable in Khyber Pakhtunkhwa, give full expression to the principle of the Convention. The Committee also welcomes that the draft Punjab and Sindh Labour Code provide for “equal remuneration for work of equal value” and that this term refers to rates of remuneration established without discrimination based on sex. The Committee notes, however, that no legislation gives effect to this principle in the Islamabad Capital Territory and that no information has been provided on how the principle is enforced in Gilgit-Baltistan. The Committee asks the Government to take the necessary measures to ensure that the principle of the Convention is applied in the Islamabad Capital Territory and in Gilgit-Baltistan administrative territory and to provide information on any progress achieved in this regard.

Definition of “remuneration”. The Committee notes with regret the Government’s indication that: (1) information regarding the definition of “remuneration” that applies in the Islamabad Capital Territory, Punjab and Gilgit-Baltistan is not available; and (2) the definition that applies in Khyber Pakhtunkhwa and Sindh has not been amended. The Committee notes that, in the draft Punjab and Sindh Labour Code, “remuneration” has been defined as the “ordinary wage or salary and any additional emoluments whatsoever payable directly or indirectly, whether in cash, negotiable instrument or in kind, by an establishment to an employee in respect of their employment or work done in such employment, capable of being expressed in terms of money; and which is payable, or would, if the terms of the employment agreement, express or implied, were fulfilled, be payable, provided that the value of any house-accommodation, supply of light, water, medical attendance or other amenity, or of any service excluded by general or special order of the Department; any travelling allowance or the value of any travelling concession; and any sum paid to the person employed to defray special expenses entailed on him by the nature of the employment shall not constitute part of the remuneration”. In this respect, the Committee recalls that the definition of “remuneration” should capture payments or benefits, whether received regularly or only occasionally, and cover, among others, travel allowances (2012 General Survey on the fundamental Conventions, paras 687 and 691). The Committee asks the Government to: (i) take the necessary measures to ensure that the definition of “remuneration” in the draft Punjab and Sindh Labour Code fully encompasses all elements required under the Convention; (ii) incorporate into the laws that apply in the other provinces a definition of “remuneration” that gives full effect to Article 1(a) of the Convention; and (iii) provide information on any progress achieved in these respects.

Articles 3. Objective job evaluation methods. The Committee notes the Government’s acknowledgement that a more standardized approach is needed on this issue. The Government indicates that: (1) objective job evaluation methods do not apply in Gilgit-Baltistan; (2) on the contrary, such methods already serve as a basis for the recommendations of the Punjab Minimum Wages Board; (3) the Khyber Pakhtunkhwa Labour Department is of the view that job-evaluation methods should be tailored to the specific needs of each sector, which could lead to potential inconsistencies; and (4) the national pay scale system based on job classifications and responsibilities is used in Sindh’s public sector, whereas in the private sector, wages are determined on the basis of a categorization of workers into skilled, semi-skilled and unskilled levels. Consequently, the Committee welcomes that, according to the draft Punjab and Sindh Labour Code: (1) “job appraisal” means a process that objectively compares jobs to determine the relative position of one job to another in a wage or salary scale; (2) the job appraisal method shall provide a classification of jobs without regard to sex and ensure the enforcement of the principle of equal remuneration for work of equal value; and (3) for the purpose of ascertaining whether work is of equal value, regard shall be had to factors including but not limited to professional ability and skills, work effort, responsibilities, and working conditions. The Committee asks the Government to: (i) ensure that the above provisions of the draft Punjab and Sindh Labour Code will be adopted in the near future and that similar provisions will also be adopted in the rest of the country; and (ii) provide information on any progress achieved in that regard and any measures taken to promote awareness of objective job-evaluation methods.Noting that the members of the Wages Board in the Islamabad Capital Territory have requested from the ILO a capacity-building workshop on objective job-evaluation methods, the Committee hopes that this assistance will be provided in the near future.

The Committee is raising other matters in a request addressed directly to the Government.