29th June 2021

Staff report


The Asia Internet Coalition (AIC) on Monday, June 28, issued a statement on its reservations regarding the third draft of the Federal Government’s proposed Removal and Blocking of Unlawful Online Content (Procedure, Oversight and Safeguards) Rules 2021.

The body noted that the government had largely retained many of the more problematic provisions of the previous draft while only introducing a handful of minor changes, which it points toward as evidence that the consultation process was never meant to undertake substantive changes in the proposed law.

Worryingly still, the AIC noted that in some ways the latest draft which was made public by the Ministry of Information Technology and Telecommunication (MoITT) earlier this month has regressed in comparison to the initial drafts. In particular, the latest draft appears to have expanded the extent of regulation with the requirement for a dedicated grievance officer based in Pakistan.

The AIC is an industry association with the aim of promoting the understanding and resolution of internet policy issues in the Asia Pacific region by representing the internet industry, promoting and participating in stakeholder dialogue between the public and private sectors, and sharing best practices on internet technology and the digital economy.

Its members are leading firms in the internet and technology industries, including but not limited to Apple, Facebook, Twitter, Amazon, Yahoo (Oath) and LinkedIn. The body in its letter to the MoITT reiterated that Pakistan has the opportunity to take the lead in digital transformation and regulation in the South Asian region should it choose to adopt balanced rules and consider industry feedback.

Read more: Big tech outlines objections to Social Media Rules in new letter to PM


While the new draft has doubled the turnaround times for blocking content, the AIC pointed out that the exact time frame allowed for complying with a notice upon its receipt has not been stipulated. Furthermore, as the time needed to complete a review may vary from case to case, the body recommends that social media firms be instead required to submit their acknowledgement of the Pakistan Telecommunication Authority’s (PTA) requests within the stipulated time frame while a reasonable window is allowed to process said requests.

The AIC reiterated its concern with the draft bill’s requirement that social media companies establish and register offices in Pakistan. The body states that most of its members are registered under US laws, and any requirements by Pakistan to establish permanent offices may result in conflicts with US laws and taxation. Moreover, the association understands that physical offices and local registration have nothing to do with online content regulation, and is a requirement which is beyond the purview of the bill’s parent legislation the Prevention of Electronic Crimes Act (PECA) 2016.

In addition to physical offices in Pakistan, the bill also requires the appointment of locally-based authorized compliance and dedicated grievance officers which the AIC reiterates will not facilitate content moderation. However, the group recommended that a focal person can be appointed rather than a compliance officer, without needing them to be locally-based, for improved coordination between the PTA and the relevant social media firm. With regards to grievance officers, the AIC stated that it was simply impractical for a single officer to manage all content uploaded to social media, and that firms should instead create transparent frameworks for the review and removal of online content on their platforms.

Read more: Big tech threaten pull-out, saying new rules violate users’ privacy and free speech

The AIC expressed its deep concern with the extent of the powers the regulation confers upon the PTA. The Rules allow the PTA to make legally binding determinations on the lawfulness of online content, and issue orders to social media platforms for removal. The Rules do not ensure that the Authority’s actions and decisions will be transparent.

In addition to the PTA, the new social media rules award overreaching powers to state agencies to access user data and make confidential requests for removal of online content. The AIC highlights that the disclosure of user data, held by global social media firms, violates established international laws and procedures. The association also notes that confidential review and removal requests are in opposition to values of transparency.

Lastly, the group makes known its concerns in regards to definitions contained in the latest draft of the bill, in particular the broadness and vagueness of “emergency” and unclear conditions that may warrant the removal of online content that is detrimental to the “security or integrity of Pakistan.”


The AIC reiterated the difficulty its members may face in light of these proposed regulations to make their platforms, products and services available to Pakistani users and businesses. The association expressed hope and commitment to working together with the Federal Government on a balanced regulation on further consultation rounds.


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