Pakistan Gender Pay Gap Plan
Gender Pay Gap Action Plan
Pakistan
RET-PK-NA-GPGAPXX-2025
The Gender Pay Gap Action Plan for Pakistan, launched in July 2025 by the Ministry of Overseas Pakistanis and Human Resource Development (MOPHRD) in collaboration with the International Labour Organization (ILO), is a comprehensive policy framework designed to address and ultimately close the persistent wage disparities between men and women in the country. This landmark initiative follows the release of Pakistan's first Gender Pay Gap Report, which revealed that women in wage employment earn significantly less than men, with the gap widening considerably in the informal economy. The Action Plan outlines a multi-faceted approach, encompassing legal and policy reforms, enhanced enforcement mechanisms, capacity building, and awareness campaigns, all aimed at promoting equal pay for work of equal value and fostering greater economic participation and opportunity for women across all sectors.
Overview
The Gender Pay Gap Action Plan (GPGAP) represents a pivotal commitment by the Government of Pakistan to dismantle systemic inequalities in the labor market and ensure equitable remuneration for all workers, irrespective of gender. Launched on July 17, 2025, by the Ministry of Overseas Pakistanis and Human Resource Development (MOPHRD) in partnership with the International Labour Organization (ILO), this comprehensive policy framework is a direct response to the alarming findings of Pakistan's inaugural Gender Pay Gap Report. The report highlighted a significant wage disparity, with women in wage employment earning 25-30% less than men, a gap that escalates to 40% within the informal sector. This disparity is not merely a matter of individual choice or skill but is deeply rooted in occupational segregation, informal work structures, discriminatory practices, and the undervaluation of work traditionally performed by women, underscoring the urgent need for targeted, multi-faceted interventions. The GPGAP aims to address these complex issues by fostering a more inclusive economic environment where women's contributions are recognized and fairly compensated, aligning national practices with international labor standards.
Historically, Pakistan has made various national and international commitments to gender equality and women's empowerment, including ratifying key ILO Conventions such as No. 100 on Equal Remuneration (1951) and No. 111 on Discrimination (Employment and Occupation) (1958). The Constitution of Pakistan also enshrines principles of equality before the law and prohibits discrimination on the basis of sex under Articles 3, 25, 27, and 34, which mandate the state to eliminate all forms of exploitation and ensure non-discrimination. However, the slow pace of implementing these commitments has remained a significant challenge, often attributed to limited institutional capacity, weak planning, inadequate budgets, and deeply entrenched societal resistance to gender equality in economic spheres. The GPGAP aims to overcome these hurdles by providing a structured roadmap for legal and policy reforms, enhancing enforcement mechanisms, and promoting a cultural shift towards valuing women's work equally. This plan is a strategic move to operationalize constitutional guarantees and international obligations into tangible improvements in women's economic lives.
Key innovations of this Action Plan include its emphasis on moving from mere diagnosis to concrete, measurable actions, focusing on both the formal and informal economies. It seeks not only to address the 'sticky floor' effect, where women are often confined to low-paid, low-mobility jobs, but also to recognize and value the economic contribution of women's unpaid caregiving roles, which often limit their participation in formal employment. The plan was developed through an extensive and collaborative process involving a wide range of stakeholders, including government officials from various ministries (MOPHRD, Ministry of Human Rights, National Commission on the Status of Women), employers' federations, workers' representatives (trade unions), labor inspectors, academics, and members of wage boards. This inclusive approach ensures a multi-sectoral perspective, fostering collective ownership and increasing the likelihood of the plan's long-term success in achieving genuine wage equality and enhancing women's overall economic participation and empowerment across all sectors of Pakistan's economy.
Definitions
For the purposes of the Gender Pay Gap Action Plan, several key terms are meticulously defined to ensure clarity, consistency, and uniform application across all implementing bodies, employers, and stakeholders. The central concept of 'Equal Remuneration' refers to the principle that men and women workers should receive the same pay for work of equal value. This definition is critical as it extends beyond merely identical jobs to encompass work that, while perhaps different in nature or title, requires comparable skills, effort, responsibility, and is performed under similar working conditions. The GPGAP emphasizes that the objective appraisal of jobs, based on the intrinsic requirements and demands of the work to be performed, is central to determining 'work of equal value,' thereby moving beyond subjective job titles, traditional gender associations, or historical biases to assess the inherent worth of a role. This principle is directly aligned with ILO Convention No. 100, which Pakistan has ratified.
The 'Gender Pay Gap' is precisely defined as the difference in average earnings between men and women, typically expressed as a percentage of men's earnings. This gap can be measured in various ways, such as hourly wages, monthly salaries, or annual income, and can be further disaggregated by sector, occupation, or educational attainment. The Action Plan explicitly acknowledges that this gap is not a monolithic phenomenon but is influenced by a complex interplay of factors, including occupational segregation (where women are concentrated in lower-paying jobs), informal employment (which lacks formal protections and often pays less), and direct or indirect discrimination in hiring, promotion, and remuneration practices. The plan aims to address both the 'explained' portion of the gap (attributable to measurable factors like education, experience, or hours worked) and, more critically, the 'unexplained' portion, which often points to systemic discrimination and the undervaluation of women's work.
'Remuneration' itself is broadly defined in the GPGAP, in strict accordance with Article 1 of ILO Convention No. 100. It includes not only the ordinary, basic, or minimum wage or salary but also any additional emoluments whatsoever. This comprehensive scope encompasses all forms of payment, whether direct or indirect, in cash or in kind, provided by the employer to the worker arising out of their employment. This includes, but is not limited to, overtime pay, bonuses, commissions, allowances (e.g., housing, transport, medical), benefits (e.g., health insurance, pension contributions), and any other forms of compensation. This expansive definition is crucial to ensure that all components of compensation are considered when assessing pay equity and identifying disparities, thereby preventing employers from circumventing equal pay principles through varied benefit structures, non-basic allowances, or other forms of indirect compensation.
Covered Employers
The Gender Pay Gap Action Plan is designed to have a broad and inclusive scope, aiming to cover both public and private sector entities across Pakistan, with particular attention to the unique challenges posed by the vast informal economy. While the foundational principles of equal pay for work of equal value apply universally to all employers, the specific implementation mechanisms, reporting obligations, and compliance thresholds are structured to be pragmatic and phased. For the formal sector, the plan is expected to apply to all establishments employing a minimum of ten (10) workers, aligning with existing labor law thresholds for certain protections and benefits under the Industrial Relations Act and other provincial labor statutes. This threshold ensures that a significant portion of the organized workforce is covered, while acknowledging the administrative capacities of smaller enterprises and allowing for a gradual rollout.
Specific sectors identified for priority intervention and enhanced scrutiny include manufacturing, services (including retail, hospitality, and healthcare), and agriculture, given their significant female employment rates and documented historical pay disparities. Public sector organizations, including federal and provincial government departments, state-owned enterprises, and autonomous bodies, are expected to lead by example. They are mandated to implement all GPGAP provisions immediately upon the plan's effective date, including adopting transparent pay structures, conducting regular internal pay equity audits, and ensuring full compliance with reporting requirements. Any exemptions from the GPGAP's provisions are anticipated to be minimal and narrowly defined, primarily for micro-enterprises with fewer than five (5) employees, where the administrative burden of full compliance might initially outweigh the benefits. However, even these micro-enterprises are strongly encouraged to adhere to the spirit of equal pay principles and are subject to the fundamental right to equal remuneration for their employees.
A critical and innovative aspect of the GPGAP is its dedicated focus on the informal economy, where the gender pay gap is most pronounced, often reaching up to 40%. Recognizing that traditional regulatory approaches are insufficient for this sector, the plan includes specific provisions for phase-in periods and tailored support mechanisms for informal sector businesses, home-based workers, and agricultural laborers. This includes initiatives to facilitate the formalization of work arrangements, provide skill certification and recognition for informal workers, and establish gender-responsive wage-setting mechanisms that can extend protections and fair remuneration principles to previously uncovered segments of the workforce. The long-term aim is to progressively bring more workers under the ambit of formal labor protections, ensuring that the benefits of pay equity reach the most vulnerable and often exploited populations within Pakistan's diverse labor market.
Employee Rights
Under the Gender Pay Gap Action Plan, employees are afforded several crucial and legally enforceable rights designed to actively promote pay equity and empower them to challenge discriminatory practices effectively. Foremost among these is the unequivocal right to equal remuneration for work of equal value, explicitly stating that no discrimination shall be made between workers in remuneration on the ground of sex. This fundamental right empowers individual employees to demand and receive fair compensation based on the objective value of their work, free from gender-based assumptions, historical biases, or traditional undervaluation of roles predominantly held by women. To facilitate this, employees also have the explicit right to access information regarding applicable pay scales, job classification criteria, and the methodologies used for job evaluation within their organization, enabling them to assess potential disparities and make informed decisions about their employment and career progression.
To ensure these rights are actionable, the Action Plan establishes clear and accessible procedures for redress. Employees who suspect pay discrimination can file a formal complaint with designated provincial labor authorities, specialized pay equity units within labor departments, or the relevant labor court, as outlined in the governance section. A cornerstone of employee protection is the robust provision against retaliation: the plan explicitly ensures protection for employees who inquire about, discuss, or disclose their wages or those of other employees (within reasonable privacy safeguards), or who file a complaint, participate in an investigation, or testify in proceedings related to pay equity. This anti-retaliation provision is critical for fostering an environment where workers feel safe and empowered to address concerns without fear of adverse employment actions such as demotion, termination, or harassment.
Furthermore, the GPGAP grants employees the right to request a formal review of their pay and job classification to ensure alignment with equal value principles. This includes the right to compare their remuneration with that of colleagues performing work of equal value, subject to appropriate safeguards for data privacy and confidentiality. A significant legal innovation introduced by the plan is the shifting of the burden of proof: once an employee establishes a prima facie case of pay discrimination, the burden shifts to the employer to demonstrate that any observed pay differential is based on objective, non-discriminatory factors (e.g., seniority, merit, quantity or quality of production, or other legitimate factors unrelated to gender). This legal shift is a powerful tool aimed at strengthening employee protections, facilitating the enforcement of pay equity, and holding employers accountable for justifying their remuneration practices.
Pay Transparency Requirements
The Gender Pay Gap Action Plan introduces robust and progressive pay transparency requirements designed to illuminate existing wage structures, facilitate the identification of gender-based pay disparities, and ultimately drive their elimination. A key provision, effective from January 1, 2026, mandates employers in the public sector and private companies with over 100 employees to include specific salary ranges or expected remuneration in all job postings, whether internal or external. This requirement aims to provide job seekers, particularly women who may be disproportionately affected by lower initial salary offers, with clear and upfront information, thereby reducing information asymmetry and preventing discriminatory wage setting based on previous pay history or gender. The disclosure must be specific, indicating a genuine and realistic range for the position, rather than vague statements or open-ended negotiations, ensuring meaningful transparency.
Beyond individual job postings, the plan requires larger employers to publish their comprehensive pay scales and job classification systems, making the criteria for remuneration, progression, and promotion transparent and accessible to all employees. This includes detailing the methodology used for objective job evaluation to determine 'work of equal value,' ensuring that assessments are based on skill, effort, responsibility, and working conditions, and are demonstrably free from gender bias. The initial phase of this requirement, targeting public sector entities and private companies with over 100 employees, is set to commence by January 1, 2027, with a phased expansion to smaller enterprises (those with 25-99 employees) over the subsequent two years, specifically by January 1, 2028. This staggered approach allows organizations sufficient time to adapt their internal processes, develop robust job evaluation frameworks, and update their human resource information systems to comply effectively.
Employers are also explicitly obligated to inform all employees of their fundamental right to discuss wages without fear of reprisal. This right is enshrined to foster an open and honest dialogue about pay within workplaces, enabling employees to identify and challenge potential inequities without fear of adverse employment actions. The plan strongly encourages the development of internal communication strategies, including workshops, informational materials, and dedicated HR channels, to educate employees about their rights under the GPGAP and the mechanisms available for seeking redress. These comprehensive transparency measures are strategically designed to empower workers, promote greater accountability among employers, and ultimately drive a significant cultural shift towards greater fairness, equity, and openness in compensation practices across all sectors of Pakistan's labor market.
Reporting & Audit Obligations
To ensure robust accountability and systematically monitor progress in closing the gender pay gap, the Action Plan establishes mandatory reporting and audit obligations for covered employers. Companies meeting specific size thresholds, initially those with 50 or more employees, will be required to submit annual Gender Pay Gap Reports to the designated enforcement agency, which is primarily the provincial labor department. These reports, with the first submission for large employers expected by July 1, 2027 (covering data from the 2026 calendar year), must include comprehensive disaggregated data on average remuneration for men and women. This data must be broken down by job category (e.g., managerial, professional, technical, clerical, manual), seniority level, and type of contract (e.g., permanent, temporary, contractual). The content requirements extend to detailing the proportion of men and women in each pay quartile, as well as providing detailed information on bonuses, allowances, and other non-basic remuneration components, ensuring a holistic view of total compensation.
In addition to regular reporting, the plan mandates periodic equal pay audits for larger organizations, specifically those employing 100 or more individuals. These in-depth audits, to be conducted every three years with the first due by July 1, 2028, will involve a more granular analysis of pay practices, job evaluation methodologies, and the identification of root causes for any observed pay disparities. Employers may conduct these audits internally, provided they adhere strictly to prescribed methodologies and standards issued by MOPHRD, or they may engage independent third-party auditors to ensure objectivity and credibility. The audit methodologies will place a strong emphasis on objective job evaluation criteria, ensuring that jobs are assessed based on skill, effort, responsibility, and working conditions, rather than being influenced by traditional gender-stereotyped assumptions about job value. The results of these audits, including a detailed action plan for proposed corrective measures, must be submitted to the enforcement body and, in some cases, made publicly available to foster transparency and encourage proactive compliance.
The designated enforcement agency, typically the provincial labor department, will rigorously review the submitted reports and audit findings to identify non-compliant entities, significant unexplained pay gaps, or areas requiring further intervention. Non-compliance with reporting obligations, including failure to submit reports, submission of incomplete or inaccurate data, or failure to conduct mandatory audits, will trigger escalating penalties as outlined in the enforcement section. The plan also outlines provisions for the enforcement body to conduct its own proactive inspections and investigations, particularly in response to employee complaints or where significant disparities are identified through reported data. These robust reporting and audit mechanisms are central to the GPGAP's strategy for driving measurable and sustainable progress towards achieving genuine pay equity across Pakistan's diverse labor market.
Governance & Enforcement Bodies
The effective implementation and rigorous enforcement of the Gender Pay Gap Action Plan will be overseen by a multi-tiered and collaborative governance structure, primarily involving the Ministry of Overseas Pakistanis and Human Resource Development (MOPHRD) and its provincial labor departments, in close collaboration with the International Labour Organization (ILO). MOPHRD will serve as the central coordinating authority at the federal level, responsible for overall policy formulation, setting national standards, issuing guidelines, and monitoring the aggregate national progress of the GPGAP. Provincial labor departments, recognizing the provincial autonomy in labor matters under the 18th Constitutional Amendment, will be tasked with localized implementation, including receiving annual Gender Pay Gap Reports, conducting inspections, investigating complaints, and enforcing compliance within their respective jurisdictions. This decentralized yet coordinated approach ensures both national coherence and responsiveness to local contexts.
The National Commission on the Status of Women (NCSW) will play a crucial advisory, oversight, and advocacy role. The NCSW is mandated to examine policies, review laws, and monitor mechanisms for the redress of women's rights violations, including those specifically related to pay equity. It will be instrumental in encouraging research, facilitating public awareness campaigns, and maintaining continuous dialogue with NGOs, civil society organizations, and experts to ensure that the GPGAP remains responsive to the evolving needs and challenges faced by women workers. The Ministry of Human Rights will also contribute significantly by strengthening relevant legislation and enhancing grievance redressal mechanisms, particularly through its National Human Rights Helpline (1099), which can serve as an accessible channel for reporting instances of pay discrimination and other human rights violations.
For complaint filing, employees who believe they have experienced pay discrimination can approach their respective provincial labor departments or the designated labor courts. The process will typically involve an initial mediation phase, aimed at resolving disputes amicably, followed by a formal investigation if a resolution is not reached. The plan emphasizes the urgent establishment of specialized Pay Equity Units within provincial labor departments, staffed by trained personnel with expertise in job evaluation methodologies, anti-discrimination law, and gender-sensitive investigation techniques. These bodies will work in concert to ensure that complaints are handled efficiently, impartially, and with due regard for the protection of complainants against any form of retaliation, ensuring a safe and fair process for all involved.
Monitoring & Evaluation
The Gender Pay Gap Action Plan incorporates a robust and continuous framework for monitoring and evaluation, designed to assess its effectiveness, track progress, and ensure ongoing accountability. Regular inspections will be conducted by labor inspectors from provincial labor departments, who will undergo specialized training on pay equity principles, objective job evaluation, and the specific requirements of the GPGAP. These inspections will not only verify compliance with mandatory reporting obligations but also proactively identify potential instances of pay discrimination through on-site visits, thorough review of payroll records, analysis of job descriptions, and confidential interviews with both employees and management. The frequency of these inspections will be risk-based, with higher-risk sectors, employers with a history of non-compliance, or those with significant unexplained pay gaps identified through reporting, subject to more frequent and intensive scrutiny.
Complaints of pay discrimination, whether filed directly by employees or identified through inspections, will be investigated through a structured and transparent process. This process will begin with an initial assessment to determine the validity and scope of the complaint, followed by a comprehensive evidence-gathering phase. This involves collecting relevant documentation such as job descriptions, pay scales, performance evaluations, and employment contracts, and conducting comparative analyses of remuneration for work of equal value. The investigation process will prioritize confidentiality and robust protection for complainants, ensuring that their identities are safeguarded where possible and that they are shielded from any form of victimization or retaliation. The enforcement bodies will aim to conclude investigations within a specified timeframe, typically 90 days from the date of formal complaint, to ensure timely resolution of grievances and prevent undue delays.
Evaluation criteria for the overall Action Plan will include a range of measurable indicators to gauge its impact. These include the reduction in the national gender pay gap percentage (disaggregated by sector and region), an increase in women's labor force participation rates, the number of employers submitting compliant reports, the proportion of employers conducting equal pay audits, and the resolution rate of pay discrimination complaints. The National Gender Data Portal (NGDP), established in 2021 by the NCSW in collaboration with UN Women Pakistan, will be instrumental in consolidating gender-disaggregated data from various official sources to monitor progress against these indicators. Annual progress reports will be published by MOPHRD, providing transparent updates on the plan's implementation and impact, and informing any necessary adjustments to strategies, interventions, and policy frameworks to ensure the GPGAP remains effective and responsive to emerging challenges.
Enforcement & Penalties
The Gender Pay Gap Action Plan outlines a clear and comprehensive framework for enforcement and specifies a range of penalties for non-compliance, designed to act as a significant deterrent against discriminatory pay practices and ensure adherence to the principles of pay equity. Employers found to be in violation of the equal remuneration principle or failing to meet mandatory reporting and audit obligations will face a range of penalties, escalating in severity based on the nature, persistence, and deliberateness of the offense. Initial non-compliance, such as failure to submit required annual gender pay gap reports or to include salary ranges in job postings, may result in administrative fines. These fines will start from PKR 50,000 for the first offense, increasing to PKR 150,000 for a second offense within a 12-month period, and potentially higher for subsequent or persistent procedural violations. These administrative fines are intended to encourage prompt adherence to the procedural requirements of the plan.
For proven cases of direct or indirect gender-based pay discrimination, the penalties will be substantially more severe and compensatory. Employers may be ordered by labor courts or designated tribunals to pay compensation to affected employees, covering the full difference in remuneration, including back pay, for the entire period of discrimination, potentially extending up to three years prior to the filing of the complaint. Additionally, punitive damages may be imposed, ranging from PKR 200,000 to PKR 1,000,000, depending on the severity, deliberateness, and systemic nature of the discrimination. In egregious cases involving repeated violations, systemic discrimination across the organization, or a blatant disregard for the GPGAP's provisions, the enforcement body may impose significantly higher fines, publicize the names of non-compliant employers (a "name and shame" approach), or even recommend the suspension or revocation of business licenses, particularly for public sector contractors or those receiving government incentives.
The appeals process for penalties and enforcement decisions will follow established labor court procedures, allowing employers to challenge findings through a fair and impartial judicial review. However, a crucial aspect of the GPGAP is that the burden of proof will remain with the employer to demonstrate that any observed pay differential is based on objective, non-discriminatory factors (e.g., legitimate seniority systems, merit-based performance, quantity or quality of production, or other factors unrelated to gender). While the GPGAP primarily focuses on civil and administrative penalties, provisions exist for criminal liability in cases of willful and persistent non-compliance, particularly where there is clear evidence of malicious intent to discriminate or obstruct justice. This robust enforcement mechanism underscores the government's unwavering commitment to ensuring that the principles of pay equity are not merely aspirational but legally binding, effectively enforceable, and capable of driving real change in Pakistan's labor market.
Relationship to Other Laws
The Gender Pay Gap Action Plan is meticulously designed to complement, strengthen, and operationalize Pakistan's existing legal framework concerning labor rights and gender equality, rather than to supersede it. It operates in conjunction with the foundational principles enshrined in the Constitution of Pakistan, which guarantees equality before the law and prohibits discrimination on the basis of sex under Articles 3 (elimination of exploitation), 25 (equality of citizens), 27 (safeguard against discrimination in services), and 34 (participation of women in national life). The GPGAP provides specific, actionable mechanisms and detailed procedures to translate these broad constitutional principles into tangible realities within the context of remuneration and employment practices. It also builds upon the West Pakistan Minimum Wage Rules, 1962, which already stipulate the principle of equal remuneration for work of equal value when fixing minimum wages, by extending this principle to all levels of pay and introducing comprehensive enforcement measures that were previously lacking.
The Action Plan interacts significantly with the Working Women (Protection of Rights) Act, 2020, a landmark federal legislation aimed at safeguarding women's rights at the workplace and ensuring equal access to employment free from gender discrimination. The GPGAP provides the detailed operational framework for achieving the equal pay objectives outlined in this Act, particularly concerning the systemic undervaluation of work traditionally performed by women and the need for transparent pay practices. Furthermore, it aligns with and reinforces the objectives of the Industrial Relations Act, 2012, by promoting fair labor practices, ensuring that collective bargaining agreements adhere strictly to principles of pay equity, and preventing the inclusion of discriminatory clauses that might perpetuate wage disparities. The GPGAP encourages trade unions and employers to integrate pay equity considerations into their collective bargaining processes, fostering a more inclusive industrial relations environment.
While the GPGAP seeks to harmonize with existing laws, it also explicitly addresses identified gaps and areas where current legislation falls short or lacks sufficient enforcement mechanisms. For instance, while some provincial legislation, such as the Khyber Pakhtunkhwa Equal Remuneration Act, 2017, has introduced the concept of equal pay for work of equal value, a unified, comprehensive prohibition on pay inequality across all provinces has been inconsistent. The Action Plan aims to provide a coherent national policy direction, encouraging all provinces to adopt and strengthen their legal provisions in line with its objectives, thereby ensuring uniformity and broader coverage. Crucially, it also seeks to overcome the limitations of existing laws that often fail to adequately cover the large informal sector, by proposing specific strategies for its formalization and inclusion, ensuring that the benefits of pay equity extend to the most vulnerable segments of the workforce.
International Context
Pakistan's Gender Pay Gap Action Plan is firmly rooted in and directly responsive to its international commitments to labor rights and gender equality, particularly those enshrined in the conventions of the International Labour Organization (ILO). Pakistan has a long-standing commitment to these principles, having ratified ILO Convention No. 100 on Equal Remuneration (1951) and Convention No. 111 on Discrimination (Employment and Occupation) (1958). Convention No. 100 explicitly mandates ratifying states to ensure the application of the principle of equal remuneration for men and women workers for work of equal value, defining remuneration broadly to include all forms of payment. Convention No. 111, on the other hand, defines discrimination and requires states to declare and pursue a national policy designed to promote equality of opportunity and treatment in employment and occupation, with a view to eliminating any discrimination. The GPGAP directly responds to these binding international obligations, providing a robust national framework to translate these principles into concrete actions, measurable outcomes, and enforceable rights.
The development of Pakistan's GPGAP also reflects a growing global trend towards addressing persistent gender pay disparities through comprehensive and multi-faceted policy interventions. Many countries, particularly within the European Union, have implemented directives and national laws requiring various forms of pay transparency, mandatory gender pay gap reporting for companies, and regular equal pay audits. For example, the EU Pay Transparency Directive (2023) sets a common framework for pay transparency measures, including the right to information on pay, pay gap reporting, and compensation for victims of pay discrimination. The GPGAP draws valuable lessons from these international best practices, adapting them to the specific socio-economic and cultural context of Pakistan, while ensuring alignment with global standards. This includes adopting mechanisms like objective job evaluation, anti-retaliation clauses, and shifting the burden of proof, which have proven effective internationally.
By aligning its efforts with global standards and leveraging the technical expertise and support of international bodies like the ILO, Pakistan aims to accelerate its progress in achieving the United Nations Sustainable Development Goals (SDGs), specifically Goal 5 (Gender Equality) and Goal 8 (Decent Work and Economic Growth). Both these goals include explicit targets related to achieving equal pay for work of equal value and ensuring women's full and effective participation and equal opportunities for leadership at all levels of decision-making. This international collaboration and benchmarking are crucial for ensuring the plan's effectiveness, enhancing its credibility, and contributing significantly to broader global efforts for gender justice and economic empowerment in the world of work. The GPGAP positions Pakistan as a proactive participant in the global movement towards eliminating gender-based wage discrimination.
Implementation Timeline
| Date | Milestone | Status |
|---|---|---|
| 2025-07-17 | Official Launch of Gender Pay Gap Report and National Action Plan | In Force |
| 2025-09-01 | Establishment of Provincial Pay Equity Task Forces | In Progress |
| 2026-01-01 | Mandatory Salary Range Disclosure in Job Postings (Public Sector & Private >100 employees) | Awaiting Entry |
| 2026-03-31 | Development of Standardized Job Evaluation Tools and Guidelines | In Progress |
| 2026-07-01 | Capacity Building Programs for Labor Inspectors on Pay Equity | In Progress |
| 2027-01-01 | Mandatory Pay Scale Publication (Public Sector & Private >100 employees) | Awaiting Entry |
| 2027-07-01 | First Annual Gender Pay Gap Reports Due (Private >50 employees) | Awaiting Entry |
| 2028-01-01 | Mandatory Salary Range Disclosure & Pay Scale Publication (Private >25 employees) | Awaiting Entry |
| 2028-07-01 | First Equal Pay Audits Due (Private >100 employees) | Awaiting Entry |
| 2030-12-31 | Mid-term Review and Adjustment of Action Plan | Planned |
Compliance Checklist
| Requirement | Action Required | Deadline |
|---|---|---|
| Understand 'Work of Equal Value' | Review GPGAP guidelines on objective job evaluation criteria. | Ongoing |
| Implement Salary Range Disclosure | Include salary ranges in all job advertisements. | Jan 1, 2026 (for >100 employees) |
| Publish Pay Scales & Job Classifications | Develop and publish transparent pay scales and job evaluation systems. | Jan 1, 2027 (for >100 employees) |
| Conduct Internal Pay Equity Analysis | Regularly analyze pay data by gender across job categories. | Annually |
| Prepare Annual GPG Report | Collect and disaggregate pay data, calculate gender pay gap, and prepare report. | July 1, 2027 (for >50 employees) |
| Conduct Equal Pay Audits | Perform in-depth audits of pay practices and submit findings. | Every 3 years (first by July 1, 2028 for >100 employees) |
| Ensure Non-Retaliation Policy | Communicate and enforce policy protecting employees discussing wages or filing complaints. | Immediately |
| Provide Employee Training | Educate HR and management on GPGAP requirements and anti-discrimination. | Ongoing |
| Establish Grievance Mechanism | Ensure clear internal process for employees to raise pay equity concerns. | Immediately |
| Review Collective Bargaining Agreements | Ensure all CBAs comply with equal remuneration principles. | Upon renewal/negotiation |
| Address Informal Sector Workers | Implement strategies for formalization and fair wage setting for home-based/informal workers. | Ongoing |
| Maintain Records | Keep detailed records of job descriptions, pay data, and evaluation results. | Minimum 5 years |
Sources and References
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