Pakistan’s position in global climate risk rankings reflects a problem that is increasingly visible in everyday governance. In the Climate Risk Index 2025, Pakistan ranked first among countries most affected by climate-related extreme weather events in 2022, largely reflecting the scale of the devastating floods that year. Over the longer period from 1993 to 2022, Pakistan ranked 56th, showing that the 2022 disaster was part of a wider pattern of recurring climate-related losses. 

The 2022 floods affected around 33 million people, caused US$14.9 billion in damages and US$15.2 billion in economic losses, and created reconstruction needs estimated at more than US$16 billion. Pakistan has continued to experience extreme climate events since then, with the 2025 floods again causing widespread deaths, displacement and infrastructure damage.

The country’s exposure extends beyond floods. Rising temperatures, droughts, glacier melt, glacial lake outburst floods and sea-level rise are placing pressure on agriculture, water, ecosystems, infrastructure and livelihoods. Pakistan’s NDC 3.0 identifies these hazards as major threats to lives, livelihoods and critical infrastructure.

Pakistan has developed an extensive policy and institutional framework for responding to these risks. The National Climate Change Policy 2021 provides the overarching framework for climate adaptation and mitigation, covering sectors including water, agriculture, energy, forestry, biodiversity, health and disaster risk reduction. 

The Pakistan Climate Change Act 2017 established the Pakistan Climate Change Council, Climate Change Authority and Climate Change Fund to provide institutional coordination, technical oversight and financing for climate action. The National Adaptation Plan 2023 then provided a strategic framework for integrating adaptation into development planning, with priorities spanning agriculture, water, urban resilience, ecosystems and human development. 

Pakistan’s international climate commitments are articulated through its Nationally Determined Contributions. The latest NDC 3.0, submitted in 2025, sets a target to reduce projected greenhouse gas emissions in 2035 by 50 percent, with 17 percent unconditional and 33 percent conditional on international support.

These frameworks are supported by the National Disaster Management Act 2010. On paper, therefore, Pakistan has developed the basic architecture required for climate governance. The difficulty lies in translating this architecture into sustained implementation.

One of the central challenges emerged after the 18th Constitutional Amendment in 2010, which devolved climate-sensitive areas including agriculture, irrigation, water management, forestry, land use and environmental protection to the provinces. Yet Pakistan’s climate commitments continue to be made largely at the federal level. The gap is visible in the country’s Nationally Determined Contributions (NDCs): the mitigation target increased from a conditional 20% reduction below business-as-usual emissions in NDC 1.0 in 2016 to a 50% reduction by 2035 under NDC 3.0 in 2025. 

The difficulty is that many of the actions required to deliver these commitments now fall within provincial jurisdiction, while the fiscal system does not require provinces to align their development spending with national climate targets. Provincial development budgets are largely financed through transfers under the National Finance Commission (NFC) Award, but climate action is neither explicitly recognised nor incentivised in its allocation framework. There is therefore no binding requirement for provinces to set aside a defined share of these resources for NDC-aligned projects. This leaves the federal government making increasingly ambitious commitments without having corresponding authority over the provincial budgets and institutions needed to implement them. The result is an implementation gap between national climate ambition and the spending decisions through which much of that ambition must ultimately be delivered.

The weakest link is often found at the local level. Article 140-A requires provinces to establish local governments and devolve political, administrative and financial authority to elected representatives. Yet Pakistan has struggled to maintain stable and adequately empowered local governments. A 2026 task force report found that none of the provinces had sustained a local government system fully compliant with Article 140-A and highlighted weak fiscal transfers and limited administrative authority. 

This matters directly for climate resilience. Drainage, waste management, land-use planning, water supply, local roads, heat management and community-level disaster preparedness are experienced at the local level. A recent Jinnah Institute assessment reported by Dawn found that the absence of effective local governments leaves communities with weak channels for communicating their needs and accessing grievance mechanisms during climate disasters. 

The institutional structure has also developed more slowly than the policy framework. The Climate Change Act was passed in 2017, but key institutions established under the law took years to become operational. This gap between legislation and institutional functioning illustrates a wider problem in Pakistan’s climate governance: creating a policy does not automatically create the administrative capacity needed to deliver it. 

Financing is another major constraint. Pakistan’s adaptation needs have been estimated at US$7–14 billion annually, far exceeding the resources available through domestic public financing. Accessing international climate finance also requires strong project preparation, technical expertise, data, monitoring and financial management, areas where institutional capacity remains uneven.

Climate governance is consequently shaped by more than the quality of national policies. Poor land-use regulation can increase flood exposure. Weak enforcement can allow construction in vulnerable areas. Degraded wetlands and inadequate drainage can intensify urban flooding. Weak local institutions can delay preparedness and response. These governance failures can turn a climate hazard into a much larger social and economic disaster. 

Pakistan therefore faces a distinct implementation gap. The country has policies, legislation, climate commitments and institutions, but their effectiveness depends on coordination across levels of government, predictable financing, administrative continuity and capable local institutions. The next phase of climate governance requires greater attention to these connections.

About the Author:

Momal Nawab is Program Officer at Accountability Lab Pakistan and can be reached at momal@accountabilitylab.org