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 s