Pakistan formally committed to the IMF in writing on Tuesday to publish asset declarations of all high-level federal civil servants by December 2026 and grant the National Accountability Bureau (NAB) institutional autonomy through a transparent appointment process for its chairman by January 2027 — both now designated as Structural Benchmarks under Pakistan’s $7 billion Extended Fund Facility. The commitments form part of the governance and anti-corruption framework agreed during the third EFF review, whose staff-level agreement was reached on 28 March 2026.
To provide independence and operational autonomy to NAB, the government committed to ensuring NAB’s institutional independence through a transparent selection process for senior management and the publication of operating rules and statistics, under a new Structural Benchmark set for end-January 2027.
The government committed to reviewing and improving the appointment process for the NAB chairman. Under the guidance of the Anti-Corruption and AML/CFT Committee, proposed amendments to the NAB Ordinance will be developed and laid before Parliament to adopt pre-determined qualification criteria — including years of experience and integrity standards — establish a merit-based, open and competitive selection process, and designate a multi-sectoral stakeholder commission with representatives from the government, opposition, judiciary, civil service, academia, and civil society to conduct a rules-based, rigorous, and transparent recruitment process.
The IMF believes NAB’s institutional independence plays a key role in building public trust and institutional credibility. The deadline to complete the task is January 2027, as changes to the appointment process will require amendments to the National Accountability Ordinance.
NAB has been designated to lead the development of an action plan to mitigate corruption vulnerabilities in the top ten government departments identified as having the highest corruption risks. This plan is to be completed by the end of October 2026 as a Structural Benchmark.
By the end of June 2026, the Anti-Corruption and AML/CFT Committee will develop and publish a methodology for assessing and prioritising agency-level corruption risks, along with protocols for conducting risk assessments and reporting results. The methodology must consider: the value of money at risk due to corruption vulnerabilities; typologies of corruption in the assessed agency; structural weaknesses that create vulnerabilities; and information on the frequency of corruption, including past and ongoing cases.
The assessment methodology must draw on relevant information held across government, including NAB, the Auditor General, the Competition Commission, the FBR, and the FIA.
The publication of asset declarations of high-level federal civil servants will be completed by end-December 2026, requiring centralised digital submission and collection of asset declarations, risk-based verification, and disclosure of declarations. The Establishment Division has revised the Civil Servant (Conduct) Rules, requiring centralised digital submission and collection of asset declarations, risk-based verification, and disclosure of declarations with limited restrictions on confidential personal information.
The Establishment Division will revise the declaration form to specify restrictions on confidential personal information by end-May 2026, and in coordination with the FBR, will develop a framework for risk-based verifications. The FBR will develop a dedicated digital platform for the submission of asset declarations by end-June 2026.
The FBR’s notification already expands banks’ access to asset declarations beyond BPS 17-22 federal officials — covering officers of all federal and provincial governments, autonomous bodies, corporations, and government-owned companies. By June 2026, the government will publish access statistics on the FBR’s website to enhance banks’ awareness.
| Commitment | Responsible Body | Deadline |
|---|---|---|
| Revise declaration form, confidentiality restrictions | Establishment Division | End-May 2026 |
| FBR digital platform for asset declarations | FBR | End-June 2026 |
| Methodology for agency-level corruption risk assessment | Anti-Corruption & AML/CFT Committee | End-June 2026 |
| Publish asset declarations of high-level federal civil servants | Establishment Division / FBR | End-December 2026 |
| PACEs designated as AML investigative agencies | Financial Monitoring Unit | End-December 2026 |
| NAB corruption-mitigation action plan for 10 departments | NAB | End-October 2026 |
| NAB Ordinance amendments — transparent chairman appointment | Ministry of Law and Justice | End-January 2027 |
Source: Pakistan’s Memorandum of Economic and Financial Policies, third EFF review, March 2026.
The government has established three committees to monitor progress under the recently published Economic Governance Reform (EGR) plan, which implements the priority recommendations of the GCD report. Progress reports will be prepared on a six-month basis to track implementation and published on the Ministry of Finance website.
A policy dialogue will be organised in April 2026 to discuss institutional and structural implementation issues, design of performance indicators, common challenges, and cross-cutting issues. Development partners, civil society organisations, and other stakeholders will be invited to participate. A second policy dialogue is planned for July 2026 to take stock of the six-month implementation of the EGR plan.
The government will continue enhancing the capacities of Provincial Anti-Corruption Establishments (PACEs) to conduct financial investigations related to corruption at the provincial level. A federal notification will be issued by the end of December 2026 designating the PACEs to investigate money laundering related to corruption offences within their jurisdiction and to request and receive financial intelligence from the FMU as an investigating agency.
The IMF’s Governance and Corruption Diagnostic Assessment (GCDA), released by the Ministry of Finance as a structural benchmark, described NAB as the result of a “political compromise” rather than an independent watchdog. The IMF argued that the current appointment process — based on consensus between the government and the opposition — encourages political bargaining instead of an open, merit-based selection.
The IMF also highlighted that qualification requirements for senior NAB positions restrict the pool of candidates by limiting eligibility largely to retired judges, senior civil servants, and military officers. It recommended a more transparent, competitive and multi-stakeholder selection process involving representatives from the administration, opposition, judiciary, civil society, and academia.