Pakistan presents a stark paradox in global climate governance: its climate ambition under the Paris Agreement has grown exponentially, yet actual implementation has systematically declined. Mitigation targets escalated from a conditional 20 percent reduction below business-as-usual emissions in the First Nationally Determined Contribution (2016) to 50 percent by 2035 in NDC 3.0 (September 2025), with financial demands reaching an unprecedented $565.7 billion. Adaptation frameworks evolved from broad nature-based solutions to comprehensive alignment with the Global Goal on Adaptation and integration of the National Adaptation Plan (2023).
Yet Pakistan’s greenhouse gas emissions continued to rise[1], while climate vulnerability remained fundamentally unaddressed. The 2025 monsoon floods arrived with devastating predictability[2]. Within three years of the 2022 catastrophe that submerged one-third of Pakistan’s landmass, communities once again faced inundation, infrastructure failures, and high vulnerability. Between these disasters, climate ambition had escalated dramatically on paper, but floods exposed an uncomfortable truth: federal pledges had not translated into provincial preparedness.
This paper argues that Pakistan’s climate implementation failure stems from a fundamental institutional design flaw – a constitutional trap systematically overlooked in policy discourse. Federal climate commitments are made for subjects that are constitutionally provincial. This institutional disconnect, rooted in the 18th Constitutional Amendment, creates an implementation vacuum where ambitious targets exist without corresponding authority or capacity to deliver them.
1. Constitutional Devolution and the Implementation Vacuum
The Devolution Paradox
The 18th Constitutional Amendment of 2010 transformed Pakistan’s federal structure by devolving critical climate-sensitive sectors – agriculture, water management, irrigation, land use, forestry, environmental protection, and disaster management – exclusively to provincial governments. These sectors account for over 90 percent of required adaptation and mitigation actions. Yet Pakistan’s NDCs remain centralized federal documents, developed with minimal substantive provincial input.
This creates a structural anomaly: federal ministries pledge ambitious targets to the UNFCCC but lack constitutional authority to implement commitments in devolved sectors. A federal ministry can set a national target for water-efficient irrigation but cannot compel Punjab or Sindh to adopt drip irrigation systems. It can commit to nature-based flood solutions but possesses no mechanism to ensure provinces invest in wetland restoration or urban drainage infrastructure.
The Fiscal Architecture of Failure
Pakistan’s fiscal framework compounds this constitutional misalignment. In fiscal year 2025-26, provincial annual development budgets totalled approximately Rs. 2,869 billion – substantially exceeding federal development allocations[3]. These resources flow through the National Finance Commission (NFC) Award, a constitutional mechanism designed to ensure provincial financial autonomy.
The critical flaw: climate action is neither recognized nor incentivized within the NFC formula. Provinces receive substantial fiscal transfers without binding requirements to allocate funds toward NDC-aligned projects. Federal climate commitments thus lack dedicated funding streams, monitoring mechanisms, or enforcement capacity at the provincial level – the very tier responsible for implementation in climate-sensitive sectors.
Consider the implications: a province can receive billions in development funds yet allocate zero rupees to climate adaptation infrastructure. Federal ministries cannot redirect these resources, condition their release on climate performance, or penalize non-compliance. The fiscal architecture guarantees that federal climate ambition remains unfunded and unenforced provincially.
The Planning Commission’s Institutional Omission
This oversight manifests concretely in the PC-1 approval process—the mandatory technical, financial, and administrative review for all public sector development projects. The Planning Commission notified its revised Development Manual in June 2024, introducing a Handbook on Climate Risk Screening to integrate climate-proofing into project approvals. Yet this reform exists only on paper. All 56 projects approved during fiscal year 2024-25, and reviewed by this author, used older PC-1 templates without climate risk screening. Projects continued to proceed to federal approval (CDWP/ECNEC) without reference to national climate commitments, NDC alignment, or climate impact assessment. The institutional machinery failed to operationalize its own reform: climate-proofing requirements introduced in the manual were systematically bypassed in actual practice, demonstrating how procedural reforms without enforcement mechanisms remain cosmetic exercises that fail to alter development planning behaviour.
The consequences are material: a provincial irrigation scheme can secure approval and financing despite using flood-vulnerable designs. A road project can proceed through climate-sensitive zones without adaptation measures. Each approved project locks in high-carbon infrastructure and climate-vulnerable systems, increasing both fiscal risk and disaster exposure. The Planning Commission, despite its coordinating mandate, operates without institutional guidance to climate considerations.
2. The Political Economy of Centralized Ambition
Federal Incentives for Hollow Commitments
The persistence of this institutional dysfunction reflects misaligned political incentives. It has been argued that the federal ministries in developing countries seek international prestige by submitting ambitious NDCs at global climate forums[4]. Making a $565 billion conditional pledge is politically costless: federal entities secure credit for ambition while implementation burden falls on provinces or depends on elusive international climate finance.
This creates perverse dynamics. The federal government can escalate mitigation targets from 20 percent (NDC 1.0, 2016) to 50 percent (NDC 3.0, 2025) without corresponding institutional reforms to enable implementation. International recognition increases; domestic delivery capacity does not.
Provincial Disincentives for Climate Action
Provincial governments face opposite incentives. Driven by short electoral cycles, they prioritize projects yielding immediate political returns – visible infrastructure, employment schemes, or social programs. Multi-year climate adaptation processes offer little political reward.
The 18th Amendment’s devolution compounded this challenge by triggering significant technical capacity losses in provincial departments. For a provincial chief secretary or planning department, the NDC appears as an unfunded federal mandate rather than a strategic roadmap. Provinces inherit implementation responsibility for targets they did not set, through processes they did not participate in, without dedicated fiscal resources.
Punjab provides an illustrative case: despite receiving the largest NFC allocation and facing severe water stress, the province has not developed a comprehensive climate-aligned water management plan integrated with federal NDC commitments. In fact, Punjab has not operationalized its Punjab Water Act 2019, approved to establish integrated water resource management, improve water use efficiency, and ensure cost recovery through rational pricing mechanisms. The Act remains unimplemented six years after approval, exemplifying how provincial legislative frameworks fail to translate into operational institutions or behavioural change in water management practices.
The Untapped IMF Leverage
While financing constraints are not the root cause, climate finance architecture reinforces federal-provincial disconnect. Multilateral Development Banks (MDBs) – the World Bank and Asian Development Bank – negotiate loan agreements with federal sovereign entities even when funds target provincial projects. This consolidates perceptions that climate finance remains federally controlled despite implementation being provincial.
A significant opportunity exists through the International Monetary Fund. Pakistan’s 2023 Stand-By Arrangement and 2024 Extended Fund Facility introduced climate-focused structural benchmarks. The IMF’s Resilience and Sustainability Facility (RSF), approved alongside the EFF, explicitly incorporates climate resilience policy actions: strengthening climate information systems, enhancing water resource management, improving energy efficiency, and establishing coordinated disaster risk financing frameworks[5].
These conditionalities align directly with NDC implementation objectives and address Pakistan’s acute vulnerability to climate-induced economic shocks. Yet in practice, these IMF-mandated reforms are treated as technical compliance exercises managed by the central bank and finance division. They fail to trigger horizontal coordination between federal ministries and provincial planning departments required to translate policy conditionalities into NDC-aligned investments.
Pakistan has not established institutional mechanisms to leverage IMF financial conditionalities – which directly impact macroeconomic stability and capital market access – as enforcement tools for provincial NDC implementation. This represents a strategic policy failure: the financial leverage embedded in IMF programs could incentivize or mandate provincial climate action in devolved sectors.
3. Recurring Catastrophes as Implementation Failure
The 2022 Stress Test
The 2022 floods – affecting 33 million people and submerging one-third of Pakistan’s landmass – constituted the ultimate stress test for adaptation commitments made in NDCs 1.0 (2016) and 2.0 (2021). Provincial vulnerability remained essentially unchanged. Despite years of federal pledges, floods revealed that adaptation commitments existed only on paper at the federal level and had failed to translate into provincial capacity building, resilient infrastructure investment, or community preparedness.
The absence of integrated water resource management (IWRM) systems in Sindh and Balochistan directly reflected this institutional failure. Both provinces had received substantial NFC allocations between 2016-2022, yet neither had invested systematically in NDC-aligned flood resilience infrastructure. Federal adaptation pledges had not triggered provincial action.
The 2025 Repetition
The pattern repeated with catastrophic predictability in 2025. Despite Pakistan’s National Adaptation Plan launch in 2023, floods exposed identical provincial vulnerabilities. The recurrence within a three-year span – even as NDC 3.0 was being finalized – demonstrates the fundamental failure of existing institutional architecture.
Federal commitments to adaptation had escalated dramatically: NAP integration, Global Goal on Adaptation alignment, and $565 billion in demanded finance. Yet provincial capacity to prevent, prepare for, and respond to climate disasters had not materially improved. This implementation vacuum has recurring human costs that neither increased ambition nor inflated financial demands can remedy without addressing the constitutional disconnect.
4. A Transformative Institutional Framework: Provincial NDCs
Pakistan’s climate implementation failure cannot be resolved through increased financing or enhanced technical capacity alone. The solution requires fundamental institutional restructuring that aligns constitutional authority with implementation responsibility. This paper proposes the mandatory development of Provincial Nationally Determined Contributions (PNDCs) as the core mechanism to bridge the federal-provincial divide.
Each of Pakistan’s federating entities must develop comprehensive PNDCs that translate national climate commitments into provincial action frameworks. These documents cannot be symbolic exercises or perfunctory provincial versions of federal pledges. Rather, PNDCs must constitute binding implementation roadmaps grounded in each province’s specific climatic vulnerabilities, economic structure, and institutional capacity. A functional PNDC framework requires several essential components operating in concert.
Provincial vulnerability assessments must move beyond generic climate projections to provide granular, district-level analysis of climate risks. Punjab’s PNDC, for instance, would detail water stress patterns across its canal command areas, identify heat-vulnerable urban centres, and map flood-prone tributaries with specific infrastructure exposure data. Sindh’s assessment would also include coastal erosion rates in the Indus Delta, salinity intrusion affecting agricultural productivity, and urban flooding patterns in Karachi’s drainage basins. These assessments provide the empirical foundation for targeted provincial climate action rather than adopting one-size-fits-all federal frameworks.
Building on these assessments, each province must establish sector-specific mitigation and adaptation targets for subjects under provincial constitutional authority. These targets would be negotiated with the federal government to ensure consistency with national NDC commitments while reflecting provincial implementation realities. Punjab might commit to specific reductions in agricultural emissions through precision farming adoption in designated districts, alongside targets for renewable energy integration in its industrial zones. Khyber Pakhtunkhwa and Gilgit-Baltistan could establish glacier monitoring systems and downstream early warning infrastructure as measurable adaptation targets, while committing to forest cover restoration in specified watersheds as mitigation contributions.
Critically, PNDCs must contain fully costed implementation plans that identify specific funding sources rather than generic references to international climate finance. Each provincial climate action must be mapped to either provincial development budget allocations, identified MDB loan facilities, or other specific financing sources. This costing discipline forces provincial planning departments to confront implementation realities during target-setting rather than after commitments are made. The costing exercise itself becomes a mechanism for provincial ownership by requiring provinces to decide which climate actions warrant budget prioritization against competing development demands.
The fiscal transparency mechanism emerges through mandatory Provincial Climate Budget Tagging, operationalized through each province’s Annual Development Program. Every development project in provincial budgets must be screened and tagged according to climate relevance using standardized criteria. The State Bank of Pakistan’s National Taxonomy for Sustainable Finance, approved in 2024, provides an established classification framework that can be adapted for budget tagging: projects would be classified as climate-positive (directly contributing to NDC targets). This tagging system enables systematic tracking of how much provincial development spending actually aligns with climate commitments. More importantly, it creates internal provincial accountability by making climate spending visible to provincial assemblies, audit institutions, and civil society watchdogs.
To operationalize this framework, each province will need to establish a Provincial Climate Finance Unit with technical capacity to directly engage multilateral development banks, private sector or other climate finance institutions. The federal government’s role transforms fundamentally under this framework. Rather than functioning as top-down target-setter making commitments for provincial subjects, the federal government assumes the role of ensuring provincial actions collectively meet Pakistan’s international obligations while providing technical facilitation, coordination and capacity support. This role shift requires specific institutional mechanisms.
The Planning Commission must integrate NDC alignment as a mandatory approval criterion in the PC-1 process. Currently, projects proceed through technical and financial evaluation without climate screening. Under reformed procedures, every PC-1 submission would require a climate alignment certificate demonstrating consistency with relevant PNDC targets and national NDC commitments. Projects increasing emissions or climate vulnerability in devolved sectors would be flagged for redesign or rejection. This procedural reform embeds climate considerations into Pakistan’s core development planning machinery rather than treating climate as a separate policy domain.
The Council of Common Interests provides the constitutional platform for federal-provincial NDC coordination. CCI meetings would include regular agenda items on PNDC implementation progress, resource allocation coordination, and resolution of federal-provincial climate policy conflicts. Through CCI, provinces negotiate their PNDC contributions to ensure national commitments are met while federal government provides technical support and coordinates cross-provincial climate actions requiring federal facilitation. This utilizes existing constitutional machinery rather than creating parallel climate governance structures.
The Economic Affairs Division’s engagement with multilateral development banks must make provincial programming conditional on PNDC existence and implementation. This creates powerful financial incentives for provinces to develop and implement PNDCs rather than treating them as voluntary exercises. MDB reluctance to finance climate-vulnerable or high-carbon provincial infrastructure becomes an enforcement mechanism driving provincial climate action.
Perhaps most significantly, future IMF program reviews should incorporate PNDC development and implementation as explicit structural benchmarks. The 2024 Extended Fund Facility already includes climate resilience conditionalities, but these operate at federal policy level without provincial implementation triggers. Revised benchmarks would require all four provinces, GB and AJK to submit approved PNDCs within specified timeframes and demonstrate measurable progress in tagged climate budget allocations as conditions for program review completion. This leverages IMF’s macroeconomic policy influence to drive sub-national climate governance reform, transforming provincial climate action from optional to economically imperative.
This institutional framework addresses the root cause of Pakistan’s climate implementation failure by aligning where authority resides with where action must occur. Federal commitments gain implementation capacity through provincial ownership, while provinces gain recognition, resources, and international standing for climate action in constitutionally devolved sectors. The framework transforms Pakistan’s federal structure from an implementation barrier into a potential climate governance asset, enabling tailored provincial approaches within nationally coordinated frameworks.
References
[1] World Meteorological Organization (WMO). (2025). State of the Global Climate 2024. WMO-No. 1368. Geneva, Switzerland: WMO. Retrieved from: https://wmo.int/sites/default/files/2025-03/WMO-1368-2024_en.pdf
[2] Ashfaq, M., Johnson, N., Kucharski, F. et al. (2023). The influence of natural variability on extreme monsoons in Pakistan. npj Climate and Atmospheric Science, 6, 148. https://doi.org/10.1038/s41612-023-00462-8
[3] Government of Pakistan. (2025). Federal Budget 2025-26: Public Sector Development Programme (PSDP) and Provincial Annual Development Programs (ADP).
[4] Shawoo, Z., & McDermott, C. L. (2020). Implementing climate change adaptation policy in developing countries: a synthesis of challenges and lessons learned. Climate Policy, 20(9), 1163–1177.
[5] International Monetary Fund. (2023). Pakistan: Request for a Stand-By Arrangement. IMF Country Report No. 23/246. Washington, DC.; International Monetary Fund. (2024). Pakistan: Requests for Extended Arrangement Under the EFF and Arrangement Under the RSF. IMF Country Report No. 24/312. Washington, DC.
