Pakistan can register a company online and still make running it an obstacle course. After incorporation come tax portals, provincial levies, inspections, no-objection certificates, municipal permissions and demands for documents that another arm of the state already holds. Every government promises a one-window operation. The business owner keeps moving from window to window. This is the problem addressed by the PRIME Institute’s new policy brief, Regulatory Reforms in Pakistan: A Comparative Review of Diagnostic Tools. Tuaha Adil and Ahmed Qadir compare four instruments available to reformers: the World Bank’s Business Ready (B-READY) framework, PIDE’s Sludge Series, the Regulatory Guillotine and the Standard Cost Model (SCM).
Their central argument is sensible. These are not competing brands. B-READY benchmarks broad weaknesses; a sludge audit maps a particular transaction; the guillotine reviews the stock of rules; and SCM estimates the administrative cost of complying with information obligations. Used together, they can turn an abstract complaint about red tape into a more disciplined reform programme.
The brief's most revealing figure, however, also tests its thesis. Of 558 reforms endorsed by the Cabinet Committee on Regulatory Reforms under the REMIT programme, only 79 had been implemented—an execution rate of 14 per cent. Pakistan is not short of diagnoses or reform vocabulary. It lacks institutions able to overcome the incentives that preserve complexity. The comparison contains a technical error that matters. It says B-READY scores are aggregated into an “overall composite index” for each economy. The World Bank’s methodology expressly says there is no aggregate economy score. B-READY reports results for three pillars and 10 topics, placing economies in quintiles within each. Reformers should not convert a diagnostic dashboard into the league table the World Bank chose not to produce.
The brief also says B-READY data tend to represent registered firms in major cities. Excluding informal enterprises is indeed a serious limitation in Pakistan. Still, the Enterprise Survey component samples registered firms across sizes, sectors and locations; it is mainly some expert-based modules that use standardised scenarios, including the largest business city. A fair critique must distinguish the survey from those expert assessments.
PIDE’s sludge work is more granular. By following each step in an official process, it can expose the repeat visit, needless certificate or discretionary signature that a high-level benchmark misses. The numerical precision attached to it deserves caution. The model reproduced in the PRIME brief calls hypothetical digitisation and document-removal scenarios “difference-in-differences”. A genuine difference-in-differences study observes treatment and comparison groups before and after an intervention. Estimating savings from an imagined reform applied to one baseline is scenario analysis, not causal evaluation.
Assumptions such as a 45-minute journey, a Rs. 500 one-way fare, successful access to an official on each visit and the use of per-capita national income to value everyone’s time can illustrate scale. They cannot prove the gains a reform will deliver. Representative user samples, administrative timestamps and measurement after implementation are needed. The larger omission is political. The brief treats discretionary enforcement mainly as a measurement gap and proposes standard operating procedures, digital traceability, fixed timelines and complaint channels. Those are useful controls. Discretion, however, is not always accidental variation between offices.
The proper scorecard is not the number of rules catalogued, repealed or moved online. It is lower median time, cost and inter-office variation; fewer duplicate audits and decisions reversed on appeal; greater formalisation and entry; stronger competition; and better outcomes for workers, consumers, health, safety and the environment.
The IMF's Governance and Corruption Diagnostic describes overwhelming regulation, intrusive state action, insufficiently independent regulators, bribery in routine transactions and elite influence over policy. A delay may reflect weak capacity. It may also create leverage to extract payment or favour. An electronic workflow can record that power; it cannot, by itself, dismantle the coalition benefiting from it. This is where the proposed sequence—diagnose, redesign, implement, control—becomes too tidy. The Regulatory Guillotine is itself diagnostic because agencies must inventory rules and justify their legality and necessity. It also meets legal limits. Primary legislation still requires Parliament to amend or repeal it. Under section 9(4) of the Asaan Karobar Act, 2025, unregistered regulatory instruments cease to operate only after an agency transmits a certificate that its registry entry is complete. An obstructive agency can delay the trigger. The Act is predominantly federal, while provincial portal integration depends on provincial concurrence. A federal registry cannot erase provincial or municipal authority.
Federalism is central. A manufacturer may face federal tax, standards and corporate authorities; provincial labour, environmental, food and sales-tax administrations; and municipal land-use, fire and licensing offices. Provinces need not surrender constitutional powers to an Islamabad portal. They can agree on common data definitions, mutual recognition, a single business identifier, joint inspections and interoperable systems. Local governments must be included, because much of the daily burden arises there.
SCM is useful but narrow. It can price forms, reports and other information duties. It does not adequately capture equipment needed for compliance, financing costs caused by delayed approvals or refunds, market exclusion, uncertainty, litigation or the harm caused when essential regulation is not enforced. A rule with little paperwork may protect a monopoly. A costly food-safety rule may deliver benefits well above its expense. The conspicuous missing instrument is Regulatory Impact Assessment (RIA), even though the Asaan Karobar Act defines it and includes it among the review parameters.
RIA asks whether a demonstrable problem exists, whether regulation is necessary, which alternative carries the lowest total social cost, who gains and loses, how competition and fundamental rights are affected, and whether the public benefit justifies the private burden. B-READY and SCM can supply evidence; neither can answer those questions alone. Pakistan needs three simultaneous tracks. The existing stock of rules should be reviewed sector by sector, prioritising areas with evidence of both economic burden and public harm. Every significant new rule should face an independent, published RIA. Enforcement should be audited in real time. Each application, inspection and demand for another document should carry a digital identifier, legal citation, officer trail and reason code. Public dashboards should report median and outlier processing times, variation across offices, complaints, appeals, reversals and repeat inspections, disaggregated by province, firm size and gender. Mystery shopping and statistically designed user surveys can expose demands that official portals never record.
Institutional safeguards must accompany these metrics. No unpublished regulatory instrument should be enforceable. Low-risk permissions should become registrations or declarations, with deemed approval after a binding deadline; high-risk activities should receive targeted, risk-based inspection. An independent body should scrutinise major RIAs, while parliamentary committees and the Auditor-General verify whether claimed savings materialised. Section 20 of the Asaan Karobar Act, which penalises unauthorised disclosure, also needs narrow rules so confidentiality does not defeat Article 19A of the Constitution and the Act’s promises of consultation and transparency.
The proper scorecard is not the number of rules catalogued, repealed or moved online. It is lower median time, cost and inter-office variation; fewer duplicate audits and decisions reversed on appeal; greater formalisation and entry; stronger competition; and better outcomes for workers, consumers, health, safety and the environment. The OECD’s 2025 Regulatory Policy Outlook similarly stresses risk-based enforcement, distributional analysis and continuous review while preserving necessary protections. PRIME has supplied a useful map. It becomes credible only when the missing terrain is added: causal evidence, RIA, federalism, public-interest outcomes and the political economy of enforcement. Pakistan’s regulatory malaise is not a machine waiting for the correct toolkit. It is a structure of power. Reform will begin when discretion becomes visible, privilege contestable and every regulator answerable for both the burden imposed and the public purpose achieved.