IMF Wants 174 Laws Changed Under Pakistan's $8.4 Billion Programmes

Pakistan's finance ministry told the National Assembly Standing Committee on Finance and Revenue this week that the International Monetary Fund is seeking around 174 amendments to existing laws as a condition attached to the country's two live programmes, worth a combined $8.4 billion. Finance Secretary Imdad Ullah Bosal briefed the committee, chaired by Syed Naveed Qamar, as a separate IMF mission held parallel technical talks with State Bank of Pakistan officials in Karachi for the fourth review of the $7 billion Extended Fund Facility (EFF) and the third review of the Resilience and Sustainability Facility (RSF).

What the amendments cover

The 174 changes are not confined to one sector. Bosal told the committee they cover financial-sector governance, state-owned enterprises, foreign remittances, climate change and local-currency integration. He also said the government had already implemented several IMF-linked measures, including removing tax exemptions and banning supplementary grants. One of the highest-profile items is already public: the governance amendments to the Sovereign Wealth Fund law, introduced in the Senate in September, which the IMF has listed as a specific benchmark ahead of this review.

Parliament's prerogative, not a rubber stamp

Bosal was explicit on one point: the government has told the IMF that passage of any amendment remains parliament's decision, not something Islamabad can commit to unilaterally on the Fund's timeline. That distinction matters because it is the same tension that has slowed other IMF-linked legislation in the past — a proposed change can be agreed at the technical level between the finance ministry and IMF staff, then stall for months once it reaches the floor of the National Assembly or the Senate, where coalition arithmetic and provincial objections come into play.

An EFF programme review already underway raises the stakes for how quickly that legislative backlog gets cleared. Roughly $4.5 billion of the $7 billion EFF has been disbursed after three completed reviews, and each review's structural benchmarks build on the last. A country entering a fourth review with 174 amendments still pending is, in effect, negotiating this review's technical questions while carrying forward unfinished business from earlier ones — a pattern we've tracked since talks opened in Karachi on September 23.

Why the scope is unusually wide

Programme conditionality has typically clustered around a handful of headline items — a subsidy cut here, a tax measure there. A list of 174 amendments spanning six or seven distinct policy areas signals something closer to a comprehensive rewrite of the regulatory architecture underpinning fiscal and financial governance, rather than a narrow set of prior actions. State-owned enterprise reforms, including the governance of power-sector companies, connect directly to how circular debt builds up, the subject of our explainer on the mechanics of circular debt, while financial-sector and local-currency reforms speak to a longer-running IMF concern about the depth and stability of Pakistan's domestic financial sector.

The diplomatic framing around it

The disclosure came in the same week Prime Minister Shehbaz Sharif's government has been publicly reaffirming its commitment to the IMF relationship, including remarks made around the UN General Assembly session, and as the IMF's own managing director has spoken favourably about Pakistan's trajectory. That diplomatic tone sits alongside the more mechanical reality inside the National Assembly committee room: 174 individual pieces of legislation, each requiring its own path through parliament, each a potential point of delay.

What happens next

The technical phase of the fourth EFF review and third RSF review is expected to conclude in Karachi before the IMF mission moves to Islamabad for policy-level talks. Whether the amendments move in step with that review, or lag behind it as earlier tranches of conditionality have, will be one of the clearer signals of how much slack remains between what Pakistan agrees to on paper and what it can actually pass into law on the IMF's clock.

Build Better Pakistan's Economy Desk is tracking the fourth EFF review and the legislative amendments tied to it, and will update this piece as individual bills move through parliament.