Policies without budget

EACH budget season brings the same compla­int: climate finance is inadequate. As allocations fall short of commitments, the adaptation gap widens. The complaint is legitimate. The diagnosis is wrong.

Most of Pakistan’s climate policies are neither formally approved nor notified. The Federal Appr­opriation Act can only fund programmes anchored in policies duly approved by the relevant forum and notified in the Gazette of Pakistan. A ministerial press release cannot be a budget line. A strategy launched at a COP pavilion cannot be a PSDP entry. The budget reflects this accurately. Tight fiscal space is only a secondary reason. Where is the architecture of climate-smart budgeting?

Pakistan’s policy landscape has five tiers of ap­­p­r­­oval, each carrying different legal weight. At the top sit policies enacted as acts of parliament, carr­y­­­ing full legal force on all ministries and provinces. Below these are cabinet decisions gazette-notified as statutory regulatory orders (SROs), bin­­ding the federal executive and judicially enfo­r­­ceable. Then come cabinet decisions that were never gazette-notified, binding on paper but unenforceable in court and invisible to the budget process.

Below these sit policies that bypassed even the cabinet, approved only at ministerial level, binding nobody outside the issuing ministry. At the base sit documents prepared for donors, launched at international conferences, and cited in official submissions as policy commitments, never having passed through any formal approval forum at all.

Most of Pakistan’s climate policies are neither formally approved nor notified.

Pakistan’s climate governance is concentrated in tiers three, four and five. The 2021 updated National Climate Change Policy, for example, was published merely as a ministerial document, lacking any gazette SRO, binding no other ministry, province, or budget line. Despite being the stated foundation of Pakistan’s climate architecture, it has no domestic legal standing. The same status applies to the National Forest Policy (2015), Biodiversity Strategy (2015), Urban Policy (2021), and Clean Air Policy (2023). All these are ministerial documents, cited internationally, but binding domestically on none.

The National Climate Finance Strategy offers the sharpest recent example. Launched at COP29 in Baku in November 2024 by the Federal Finance Minister. Described as a cornerstone of Pakistan’s Paris Agreement commitment. Cited in donor co-financing documents as operative government policy. Never approved by Cabinet. No gazette notification. The Finance Minister presided over its launch without his ministry having formally adopted it. It is an official document without the legal standing to match its ambition.

The National Adaptation Plan is the one celebrated exception, making it the most instructive case. The cabinet approved it in July 2023, binding all federal ministries through collective responsibility. It was a real step forward. But never gazette-notified. Without a SRO, the NAP cannot generate PSDP budget lines, compel Finance Division compliance, or sustain judicial enforcement. Not surprisingly, three years after cabinet approval, not a single ministry carries a dedicated NAP budget allocation. This is tier three in operation: approved, unnotified, unfunded.

Then there is the tier that carries inter-governmental ambition without the legal authority to match it. The Council of Common Interests (CCI) is the constitutional forum for policies that cross provincial boundaries. All climate ministry policies, by their nature, are inter-provincial: forest, biodiversity, wetlands, water conservation, finance, gender, housing, agriculture, circular economy. All these policies have moved through the system below the CCI threshold and circulated to provinces as non-binding federal guidance.

The NDC (Nationally Determined Contribut­ions) repeats the pattern. International commitments, no constitutional mechanism for provincial delivery — the gap between what Pakistan signs and what government can enforce is not a failure of intent but a failure of design.

Jurisdictional overlap turns cross-cutting mandates into recurring battles. The National Electric Vehicles Policy, prepared under prime ministerial instruction, was contested by the industries ministry arguing EVs fell within its domain. Cabinet approval stalled in the Economic Coordination Committee. Seven years later, no gazette-notified EV policy covers all vehicle categories.

The climate ministry faces the same friction across every sector it touches: housing standards sit as unadorned guidelines because the Building Code belongs elsewhere; the climate-smart agriculture framework coexists unreconciled with those of the national food security ministry and four provincial departments; three flood management frameworks from three separate institutions carry no legal hierarchy between them.

The State Bank of Pakistan has a Green Finance Taxonomy. The Securities and Exchange Commission has sustainability disclosure guidelines. The Planning Commission has SDG alignment frameworks. These are useful within their respective jurisdictions. They are not climate policy. They do not bind private sector, banking institutions, or any provincial government. They are cited in donor documents as components of Pakistan’s climate governance architecture. The institutions they are meant to guide may not have even read them.

How many people know that the climate ministry has a National Drinking Water Policy or a Climate Change Gender Action Plan? These documents bind nobody. They are policy in the way a wish list is a plan. They generate no budget allocation.

The sum of all this is a governance ecosystem in which the budget process functions correctly by refusing to fund what is not legally fundable, while the policy process functions incorrectly by producing documents that are designed to appear fundable without being so. The result looks like a budget problem — and that it is not.

Fix the architecture in three steps, for accessing the budget, First, gazette-notify the NAP immediately, anchoring it in an amendment to the Public Financial Management Act so that climate budget-tagging becomes a legal requirement rather than a donor aspiration. Second, take the NDC sectoral targets and the NAP to the CCI for formal endorsement, so that provinces are constitutional parties to the commitments rather than recipients of ministerial circulars. Third, revise the Rules of Business to establish a clear mandate hierarchy for cross-cutting climate subjects, so that the same jurisdictional battles stop recurring in every sector.

The fix costs nothing. No new money, no new institutions. The government simply has to do what it has been avoiding for decades. Until then, complaining about the budget is complaining about symptoms. A budget cannot be climate-friendly when the legal and institutional scaffolding that would make it so does not exist.

The writer is a climate expert.

Published in Dawn, June 18th, 2026 ...