Pakistan

MODERATE ADVANCEMENT
In 2019, Pakistan made a moderate advancement
in efforts to eliminate the worst forms of child labor.
Punjab Province adopted the Punjab Domestic
Workers Act of 2019, which prohibits children under
age 15 from working in any domestic service capacity.
The Pakistan National Assembly also passed the
Islamabad Capital Territory Prohibition of Employment
of Children Act. In addition, the Islamabad Capital
Territory established its Child Protection Advisory
Board, and the Khyber Pakhtunkhwa and Balochistan
provincial labor departments earmarked specific funds
from their budgets to conduct child labor surveys.
Khyber Pakhtunkhwa Province also established a
dedicated child labor unit. Children in Pakistan are
engaged in the worst forms of child labor, including
in commercial sexual exploitation and domestic
work, each sometimes as a result of human
trafficking. Children also engage in forced labor in
brick kilns and agriculture.The federal government
and Balochistan Province have not established a minimum age for work or hazardous work in compliance
with international standards. In addition, provincial labor inspectorates do not receive sufficient resources to
adequately enforce laws prohibiting child labor, and the federal and provincial governments failed to publish data
on their efforts to enforce criminal or labor laws related to child labor. Further, police corruption, particularly
the taking of bribes from suspected perpetrators to ignore child labor crimes and lack of willingness to conduct
investigations, hindered Pakistan’s ability to address the problem throughout the country.

I. PREVALENCE AND SECTORAL DISTRIBUTION OF CHILD LABOR

Children in Pakistan are engaged in the worst forms of child labor, including in commercial sexual exploitation
and domestic work, each sometimes as a result of human trafficking. Children also engage in forced labor in brick
kilns and agriculture. (1-4) Table 1 provides key indicators on children’s work and education in Pakistan. Data on
some of these indicators are not available from the sources used in this report.
Table 1. Statistics on Children’s Work and Figure 1. Working Children by Sector,
Education Ages 10-14
Children Related Entity Age Percent
Working All Pakistan 10 to 14 9.8 (2,261,704)
(% and Punjab Province 5 to 14 12.4 Services
population) 19.7%
Sindh Province 5 to 14 21.5
Attending All Pakistan 10 to 14 78.0
School (%) Industry
Punjab Province 5 to 14 77.1 10.9%
Sindh Province 5 to 14 60.6 Agriculture
69.4%
Combining All Pakistan 10 to 14 0.8
Work and Punjab Province 7 to 14 8.2
School (%)
Sindh Province 7 to 14 11.6
Primary All Pakistan 71.1
Completion Punjab Province Unavailable
Rate (%)
Sindh Province Unavailable
Source for primary completion rate: Data from 2018, published by the UNESCO
Institute for Statistics, 2020. (5)
Source for all other data: International Labor Organization’s analysis of statistics
from Labour Force Study (LFS), 2017–2018; and Multiple Indicator Cluster Survey
5 (MICS 5), 2014. (6)

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Based on a review of available information, Table 2 provides an overview of children’s work by sector and activity.

Table 2. Overview of Children’s Work by Sector and Activity

Sector/Industry Activity
Agriculture Farming, including harvesting cotton, wheat, and sugarcane (3,7-11)
Fishing, including deep sea fishing (12,13)
Industry Manufacturing glass bangles,† surgical instruments,† and jewelry (3,4,10,12,14-19)
Weaving carpets,† producing garments, and tanning leather,† (3,12,17,19-22)
Producing bricks (1,3,4,19,21-26)
Mining coal† and gemstones, and crushing stone† (12,21,24,27,28)
Services Domestic work (2,4,29-31)  
Working in hotels, restaurants, gas stations, and automobile repair (3,4,8,21,32-35)  
Scavenging† and sorting garbage and recyclables, begging, and street vending (3,7,32,36-38)
Categorical Worst Forms of Forced labor in agriculture, brickmaking, carpet weaving, and coal mining (1,3,39-41)
Child Labor‡ Forced domestic work, sometimes as a result of human trafficking (2,3,29,41)
Commercial sexual exploitation, including use in the production of pornography, sometimes as a result of
human trafficking (3,4,19,41-45)
Forced begging, sometimes as a result of human trafficking (3,8,41)
Forced recruitment of children by non-state armed groups for use in armed conflict (41)
Use in illicit activities, including trafficking and producing drugs (3,38)
† Determined by national law or regulation as hazardous and, as such, relevant to Article 3(d) of ILO C. 182.
‡ Child labor understood as the worst forms of child labor per se under Article 3(a)–(c) of ILO C. 182.

Pakistan consists of the Islamabad Capital Territory (ICT), which is governed by federal law, as well as four
provinces—Balochistan, Khyber Pakhtunkhwa, Punjab, and Sindh—each of which is responsible for all social
services, including those related to labor, within their areas. Law enforcement responsibilities are shared between
the federal and provincial governments. (46) When available, data and information are included for the federal
and provincial governments in this report. In 2019, Pakistan’s federal and provincial governments, with technical
assistance provided by UNICEF, continued conducting nationwide child labor surveys. These surveys—the first
conducted since 1996—are expected to address the lack of available child labor data that has hampered the
federal and provincial governments’ ability to accurately assess the scope and prevalence of child labor. (3,29)  

Many child domestic workers work under conditions of forced labor, including debt bondage, sexual assault,
and extreme physical abuse. (2,3,29,31) Indeed, reports estimate that 70 percent of bonded laborers in Pakistan
are children. (46,47) Poor rural families sometimes sold their children into domestic servitude or other
types of work, or paid agents to arrange for such work, often believing their child would work under decent
conditions. Children were also kidnapped or sold into organized begging rings, domestic servitude, gangs, and
child sex trafficking. (46,48) Some children work with their families as bonded laborers in the production of
bricks. (3,4,8,26,41,49)

Begging ringmasters sometimes maim children to earn more money and sometimes force children to steal, and
organized criminal groups force children into drug trafficking in Sindh and Balochistan. Research found that due
to the consistent lack of law enforcement efforts against those who exploited street children, including in forced
labor and sex trafficking, traffickers operated openly and with impunity. (3,46,50)

Child laborers in Pakistan, particularly boys, are frequently subjected to sexual exploitation at their places of
employment, including in factories, workshops, mines, or while scavenging on the streets. (51) They are also
sometimes subjected to sexual exploitation in order to obtain or keep a job or for accommodations. Research
indicates that in Kasur, a city in the Punjab Province where sexual exploitation of children is considered to be
among the highest in the country, 90 percent of working children under age 14 have been sexually harassed or
exploited. (3,41,52,51) The practice of bacha bazi, or boy play, in which boys are forced to provide social and
sexual entertainment for older men, is common within Pakistan. Traffickers in Pakistan also promise Pakistani
boys admission to Afghani religious schools only to instead sell them to Afghan security forces for the purpose of
sexual exploitation. (41,53)
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Children in Pakistan face several barriers to education. Of significant concern is the sexual abuse of children
in Pakistan’s madrassas—Islamic religious schools that provide free education and meals to Pakistan’s poorest
children. (52,54,55) There are more than 22,000 registered madrassas in the country, in addition to an estimated
2,000-3,000 unregistered madrassas; sexual abuse in madrassas significantly hinders the ability of a large number
of Pakistani children to attend school and receive an education. (52,54) In addition, non-state armed militant
groups—Tehreek-e-Taliban Pakistan, its splinter groups, and ISIL-KP—forcibly recruited and used children in
terrorist activities, including suicide attacks. Further, while research found that the total number of terrorist
attacks against schools have continued to decrease since 2009, schools in Pakistan may still be vulnerable
to attacks by unknown armed groups, disrupting children’s access to education. (3,10,19,46,56-61) Many
other children face barriers to accessing education including high rates of teacher absenteeism, inadequate
facilities, lack of transportation, school fees, and corporal punishment, which may deter children from attending
school. (3,10,57,60,62-64) Lastly, while children not are legally required to have a birth certificate to enroll in
public or private school, research indicates that some private schools may still require children’s birth certificate
in order to enroll. (3,46) Research also found only 31 percent of births are officially registered. Children without
a birth certificate who cannot enroll in school are at much higher risk of becoming victims of exploitative labor
conditions. (65)

II. LEGAL FRAMEWORK FOR CHILD LABOR

Pakistan has ratified most key international conventions concerning child labor (Table 3).
Table 3. Ratification of International Conventions on Child Labor
Convention Ratification
ILO C. 138, Minimum Age

ILO C. 182, Worst Forms of Child Labor

UN CRC
UN CRC Optional Protocol on Armed Conflict
UN CRC Optional Protocol on the Sale of Children, Child Prostitution and Child Pornography

Palermo Protocol on Trafficking in Persons

The government has established laws and regulations related to child labor (Table 4). However, gaps exist in
Pakistan’s legal framework to adequately protect children from the worst forms of child labor, including the
minimum age for work and for hazardous work.

Table 4. Laws and Regulations on Child Labor

Meets
Related
Standard International Age Legislation
Entity
Standards
Minimum Age for Work Federal No† 14 Section 50 of the Factories Act; Section 20 of the
Shops and Establishments Ordinance; Section 26
of the Mines Act; Section 3 of the Road Transport
Workers Ordinance (66-69)
Balochistan No Section 50 of the Factories Act; Section 20 of the
Shops and Establishments Ordinance; Section 26
of the Mines Act; Section 3 of the Road Transport
Workers Ordinance (66-69)
Khyber No 14 Sections 2(1)(b) and 3(1) of the Khyber
Pakhtunkhwa Pakhtunkhwa Prohibition of Employment of Children
Act; Section 21 of the Khyber Pakhtunkhwa Shops
and Establishments Act; Section 49 of the Khyber
Pakhtunkhwa Factories Act (70-72)  

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Table 4. Laws and Regulations on Child Labor (Cont.)
Meets
Related
Standard International Age Legislation
Entity
Standards
Minimum Age for Work Punjab Yes‡ 14 Section 3(1) of the Punjab Restriction on
Employment of Children Ordinance; Section 5 of
the Punjab Prohibition of Child Labor at Brick Kilns
Act; Section 3 of the Punjab Domestic Workers
Act (73,74,154)  
Sindh No 14 Section 3(1) of the Sindh Prohibition of Employment
of Children Act; Section 81 of the Sindh Factories
Act; Section 20 of the Sindh Shops and Commercial
Establishment Act (75-77)  
Minimum Age for Hazardous Work Federal No 14 Sections 2–3 of the Employment of Children
Act (78)  
Balochistan No 14 Sections 2–3 of the Employment of Children
Act (78)  
Khyber Yes 18 Sections 2(1)(a) and 3(2) of the Khyber
Pakhtunkhwa Pakhtunkhwa Prohibition of Employment of Children
Act (70)  
Punjab Yes 18 Section 3(2) of the Punjab Restriction on
Employment of Children Ordinance (74)
Sindh Yes 18 Section 3(2) of the Sindh Prohibition of Employment
of Children Act (77)
Identification of Hazardous Occupations or Federal Yes Parts 1–2 of the Schedule of the Employment of
Activities Prohibited for Children Children Act (78)  
Balochistan Yes Parts 1-2 of the Schedule of the Employment of
Children Act (78)  
Khyber Yes Parts 1–2 of the Schedule of the Khyber
Pakhtunkhwa Pakhtunkhwa Prohibition of Employment of Children
Act (70)
Punjab Yes Schedule of Hazardous Work of the Punjab
Restriction on Employment of Children
Ordinance (76)
Sindh Yes Schedule of Hazardous Work of the Sindh
Prohibition of Employment of Children Act (77)
Prohibition of Forced Labor Federal Yes Sections 3 and 7 of the Prevention of Trafficking in
Persons Act; Section 4 of the Bonded Labor System
(Abolition) Act; Sections 367, 370, 371A–371B, and
374 of the Penal Code (79-81)
Balochistan Yes Sections 3 and 7 of the Prevention of Trafficking in
Persons Act; Section 4 of the Bonded Labor System
(Abolition) Act; Sections 367, 370, 371A–371B, and
374 of the Penal Code (79-81)
Khyber Yes Sections 2(j) and 3 of the Khyber Pakhtunkhwa
Pakhtunkhwa Bonded Labor System (Abolition) Act; Sections 367,
370, 371A–371B, and 374 of the Penal Code (80,82)  
Punjab Yes Section 11(3) of the Punjab Restriction on
Employment of Children Ordinance; Section 4
of the Punjab Bonded Labor System (Abolition)
Act (74,83)  
Sindh Yes Section 4 of the Sindh Bonded Labor System
(Abolition) Act; Section 14.1(a) of the Sindh
Prohibition of Children Act (77,84)
Prohibition of Child Trafficking Federal No Sections 3 and 7 of the Prevention of Trafficking in
Persons Act; Sections 366A–366B of the Penal Code;
Sections 2(g), 3 of the Prevention and Control of
Human Trafficking Ordinance (80,81,85)
Balochistan No Sections 3 and 7 of the Prevention of Trafficking
in Persons Act; Sections 369A of the Penal Code;
Sections 2(g), 3 of the Prevention and Control of
Human Trafficking Ordinance (80,81,85)

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Table 4. Laws and Regulations on Child Labor (Cont.)
Meets
Related
Standard International Age Legislation
Entity
Standards
Prohibition of Child Trafficking Khyber No Sections 2 and 52 of the Khyber Pakhtunkhwa Child
Pakhtunkhwa Protection and Welfare Act (86)
Punjab No Sections 3 and 7 of the Prevention of Trafficking in
Persons Act; Sections 366A–366B of the Penal Code;
Sections 2(g), 3 of the Prevention and Control of
Human Trafficking Ordinance (80,81,85)
Sindh No Sections 3 and 7 of the Prevention of Trafficking in
Persons Act; Sections 366A–366B of the Penal Code;
Sections 2(g), 3 of the Prevention and Control of
Human Trafficking Ordinance (80,81,85)
Prohibition of Commercial Sexual Federal No Sections 292(B)–292(C), 366A–366B, and
Exploitation of Children 371A–371B of the Penal Code; Sections 2, 3, and 7 of
the Prevention of Trafficking in Persons Act; Second
Amendment to the Criminal Code, Section 377A,
292B (2016) (80,81,87)  
Balochistan No Sections 292(B)–292(C), 366A–366B, and
371A–371B of the Penal Code; Sections 2, 3, and 7 of
the Prevention of Trafficking in Persons Act; Second
Amendment to the Criminal Code, Section 377A,
292B (2016) (80,81,87)  
Khyber No Sections 2, 48, and 53 of the Khyber Pakhtunkhwa
Pakhtunkhwa Child Protection and Welfare Act (86)
Punjab Yes Section 11(3)(b) of the Punjab Restriction on
Employment of Children Ordinance; Section 40
of the Punjab Destitute and Neglected Children
Act (74,88)  
Sindh Yes Section 14.1(b) of the Prohibition of Employment of
Children Act (77)
Prohibition of Using Children in Illicit Federal No
Activities Balochistan No
Khyber No Sections 35, 38, and 45 of the Khyber Pakhtunkhwa
Pakhtunkhwa Child Protection and Welfare Act (86)  
Punjab Yes Section 11(3)(c) of the Punjab Restriction on
Employment of Children Ordinance; Section 36 and
36A of the Punjab Destitute and Neglected Children
Act (74,88)
Sindh Yes Section 14.1(c) of the Prohibition of Employment of
Children Act (77)
Minimum Age for Voluntary State Military Federal Yes 18 Section 3 of the National Service Ordinance (89)  
Recruitment
Prohibition of Compulsory Recruitment of Federal N/A*
Children by (State) Military
Prohibition of Military Recruitment by Non- Federal No
state Armed Groups Balochistan No
Khyber No
Pakhtunkhwa
Punjab Yes Section 11(3)(a) of the Punjab Restriction on
Employment of Children Ordinance (74)
Sindh Yes Section 14.1(c) of the Sindh Prohibition of
Employment of Children Act (77)
Compulsory Education Age Federal Yes 16 Section 3 of the Right to Free and Compulsory
Education Act (90)
Balochistan Yes 16 Section 3 of the Balochistan Compulsory Education
Act (91)  
Khyber Yes 16 Section 3 of the Khyber Pakhtunkhwa Free
Pakhtunkhwa Compulsory Primary and Secondary Education
Act (70)  

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Table 4. Laws and Regulations on Child Labor (Cont.)
Meets
Related
Standard International Age Legislation
Entity
Standards
Compulsory Education Age Punjab Yes 16 The Punjab Free and Compulsory Education
Ordinance (92)  
Sindh Yes 16 Section 3(1) of the Sindh Right of Children to Free
and Compulsory Education Act (93)  
Free Public Education Federal Yes Section 3 of the Right to Free and Compulsory
Education Act (90)  
Balochistan Yes Section 2(f) of the Balochistan Compulsory
Education Act (91)  
Khyber Yes Section 3 of the Khyber Pakhtunkhwa Free
Pakhtunkhwa Compulsory Primary and Secondary Education
Act (70)  
Punjab Yes The Punjab Free and Compulsory Education Act (92)
Sindh Yes Section 3(1) of the Sindh Right of Children to Free
and Compulsory Education Act (93)  
* No conscription (89)
† The minimum age for work in shops and establishments is 14 years old. The minimum age for work in factories and mines is 15 years old (66-68)
‡ The minimum age for work in brick kilns is 14 years old. The minimum age for work in domestic work is 15 years old (73,75)

The Eighteenth Amendment to the Pakistani Constitution permits provinces to pass laws that govern labor
law and children’s welfare. (94,153) Federal law applies only until the province passes a law on the same
subject. (26,96)

In 2019, the Pakistan National Assembly passed the Islamabad Capital Territory Prohibition of Employment
of Children Act, which would prohibit the employment of children age 14 and younger in any establishment,
including agricultural and household establishments; would prohibit the employment of children ages 15 to
18 in hazardous work; and would establish a hazardous work list prohibited for children. However, the Senate
had not approved the bill at the close of the reporting period. (3,96) The Balochistan Employment of Children
(Prohibition and Regulation) Bill, which would include an updated list of hazardous work prohibited for children;
prohibit hazardous work for children under 18 years of age; and establish a minimum age of 14 years of age was
sent to the cabinet for consideration. (21)  

Pakistan’s federal and provincial laws are not completely in compliance with international standards on child
labor. The federal minimum age for work provisions, as well as the minimum age for work laws in Balochistan,
Khyber Pakhtunkhwa, and Sindh Provinces are not in compliance with international standards because they do
not extend to informal employment, such as household work. (66-77,154)

The federal government’s minimum age for hazardous work is currently 14 years old, which does not comply
with international standards. (78) The federal minimum age for hazardous work still applies in Balochistan
Province, as Balochistan has not established a minimum age for hazardous work. (29,78,98)

Hazardous work prohibitions for the federal government and the four provinces do not cover brickmaking, for
which there is evidence that children are exposed to environmental health hazards. Hazardous work prohibitions
for the federal government and every province except Punjab do not cover domestic work, for which there is
evidence that children are exposed to physical abuse. (8,23,78) In 2019, Punjab Province adopted the Punjab
Domestic Workers Act of 2019, which bans children under age 15 from working in any domestic service capacity,
and permits only children under age 18 to perform light work that does not harm the child’s health and safety or
affect their education. (3,4,97,154) Although laws in Khyber Pakhtunkhwa, Punjab, and Sindh Provinces prohibit
children under age 18 from working in underground mines or above-ground quarries, federal law—which also
still applies in Balochistan—does not prohibit children ages 15 to 18 from working in mines. There is evidence
that children in Balochistan are engaged in coal mining, which involves exposure to hazardous substances, work
underground, and lethal accidents. (27,28,68,70,74,77,78,98)

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Federal law, which also applies in all the provinces except Khyber Pakhtunkhwa, does not comply with
international standards on child trafficking, as it does not omit the requirement of force, fraud, or coercion
as elements of the crime. (80,81,85) Khyber Pakhtunkhwa Province’s human trafficking law also requires the
additional element of kidnapping, coercion, or receipt or giving of a benefit. (86)

Federal law, which also applies in Balochistan, does not prohibit the use of children for prostitution or
the procuring and offering of children in commercial sexual exploitation, nor does Khyber Pakhtunkhwa’s
law. (80,81,86,87)

Federal and provincial laws, with the exception of Punjab and Sindh provinces, do not prohibit the use of children
in drug production and drug trafficking. (74,77,86)

The federal and provincial governments, with the exception of Punjab and Sindh Provinces, have not enacted laws
that prohibit the recruitment and use of children by non-state groups for armed conflict. (13,70,73)  

As the minimum age for work is lower than the compulsory education age, children may be encouraged to leave
school before the completion of compulsory education. (70,90-93)

III. ENFORCEMENT OF LAWS ON CHILD LABOR

The government has established institutional mechanisms for the enforcement of laws and regulations on child
labor (Table 5). However, gaps exist within the operations of provincial labor inspectorates that may hinder
adequate labor law enforcement.

Table 5. Agencies Responsible for Child Labor Law Enforcement

Organization/Agency Role
Provincial and Regional Enforce violations of federal and provincial laws concerning the worst forms of child labor, including the Pakistan
Police Penal Code, Prevention of Trafficking in Persons Act, and the Bonded Labor System (Abolition) Act. Refer children
taken into custody to Child Protection Officers. (13,97)
Provincial Labor Inspect industrial areas and markets to identify child labor violations, enforce provincial labor laws, and pursue
Inspectors legal action against employers. (13)
Federal Investigation Enforces transnational human trafficking-related laws, particularly the Prevention of Trafficking in Persons Act.
Agency (FIA), Anti- Cooperates with other governments on human trafficking cases, operates a hotline for victims, and publishes
Trafficking Unit information on anti-trafficking efforts on its website. (3,4,10,41) Operates under the Ministry of the Interior. (4)
In 2019, the FIA—in collaboration with UNODC—conducted a Regional Conference on Trafficking in Persons
that enhanced regional cooperation and information sharing related to combating trafficking in persons. (102)  
Labor Courts Assesses penalties for labor violations. Located in each province and the Islamabad Capital
Territory. (3,46,103-105)  
District Vigilance Implement the Bonded Labor System (Abolition) Act and assist in rehabilitating bonded laborers via monitoring
Committees bodies. Consists of members of the public, civil society groups, lawyers, members of the media, and local
government officials. Report to the District Magistrate. (13,41,46,79) Exists in all provinces except Balochistan
and Khyber Paktunkhwa. (46)
Child Protection Units Take into custody at-risk children, including those rescued from exploitative labor situations. Present cases of
(CPU) children taken into custody to the Child Protection Court or the appropriate authority. Established in Punjab,
Khyber Pakhtunkhwa, and Sindh Provinces. (86,88,102,106-108)  

In 2019, the Punjab Provincial court ordered the provincial government to pay school fees for children working
at brick kilns. (109) In addition, District Vigilance Committees (DVCs) are functioning in all of Punjab Province’s
36 districts, as well in 29 districts in Sindh Province. (41,46,102) The ICT DVCs have begun taking legal efforts
against brick kilns using child labor by imposing heavy fines issued under the supervision of the District
Magistrate. (19)

Labor Law Enforcement

In 2019, labor law enforcement agencies in Pakistan took actions to combat child labor (Table 6). However, gaps
exist within the operations of provincial labor inspectorates that may hinder adequate labor law enforcement,
including limited financial and human resource allocation.
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Table 6. Labor Law Enforcement Efforts Related to Child Labor
Overview of Labor Law Enforcement Related Entity 2018 2019
Labor Inspectorate Funding Unknown (10)   Unknown (3)  
Number of Labor Inspectors National Total Unknown (10)   Unknown (3)  
Balochistan Unknown (10)   Unknown (3)  
Khyber Pakhtunkhwa Unknown (10)   Unknown (3)  
Punjab Unknown (10)   80 (3)  
Sindh 152(10)   120 (3)  
Inspectorate Authorized to Assess Penalties Balochistan Unknown No (3)
Khyber Pakhtunkhwa No (10)   No (3)
Punjab No (10)   No (3)  
Sindh No (10)   No (3)  
Initial Training for New Labor Inspectors National Yes (10)   Unknown (3)
Balochistan N/A No (3)
Khyber Pakhtunkhwa Unknown No (3)
Punjab Yes (10) Yes (3)  
Sindh N/A Yes (3)  
Training on New Laws Related to Child Labor National Yes (10) Yes (3)
Training on New Laws Related to Child Labor Khyber Pakhtunkhwa Unknown Unknown
Training on New Laws Related to Child Labor Punjab Unknown Yes (3)
Refresher Courses Provided National Yes (10) Yes (3)
Refresher Courses Provided Khyber Pakhtunkhwa Unknown Unknown
Refresher Courses Provided Punjab Yes (10) Yes (46)
Number of Labor Inspections Conducted National Total 11,910 (110) Unknown (3)
Balochistan Unknown (10) Unknown (3)
Khyber Pakhtunkhwa Unknown (10) Unknown (3)
Punjab 51,798† (111) Unknown (3)
Sindh Unknown (10) Unknown (3)
Number Conducted at Worksite Khyber Pakhtunkhwa Unknown (10) Unknown (3)
Number Conducted at Worksite Punjab Unknown (10) Unknown (3)
Number of Child Labor Violations Found National Total Unknown (10) Unknown (3)
Punjab 98† (111) 940 (46)
Khyber Pakhtunkhwa Unknown (10)   Unknown (3)
Sindh Unknown (10) Unknown (3)
Number of Child Labor Violations for Which Penalties Were Imposed National Total Unknown (10) Unknown (3)  
Number of Child Labor Violations for Which Penalties Were Imposed Khyber Pakhtunkhwa Unknown (10) Unknown (3)
Number of Child Labor Violations for Which Penalties Were Imposed Punjab Unknown (10) Unknown (3)
Number of Child Labor Penalties Imposed that Were Collected Khyber Pakhtunkhwa Unknown (10) Unknown (3)
Number of Child Labor Penalties Imposed that Were Collected Punjab Unknown (10) Unknown (3)  
Routine Inspections Conducted Federal N/A Unknown
Balochistan N/A Yes (3)  
Khyber Pakhtunkhwa Yes (10) Yes (3)
Punjab Yes (10) Yes (3)
Sindh N/A Yes (3)  
Routine Inspections Targeted Khyber Pakhtunkhwa Unknown (10) Unknown
Routine Inspections Targeted Punjab Unknown (10) Unknown
Unannounced Inspections Permitted Federal Yes (112)   Yes (112)
Balochistan N/A Yes (113)
Khyber Pakhtunkhwa Yes (114) Yes (114)  
Punjab Yes (115)   Yes (115)
Sindh Yes (116) Yes (116)

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Table 6. Labor Law Enforcement Efforts Related to Child Labor (Cont.)
Overview of Labor Law Enforcement Related Entity 2018 2019
Unannounced Inspections Conducted Khyber Pakhtunkhwa Unknown (10) Unknown
Unannounced Inspections Conducted Punjab Unknown (10) Unknown
Unannounced Inspections Conducted Sindh Unknown (10) Unknown
Complaint Mechanism Exists Balochistan N/A Yes (3)
Khyber Pakhtunkhwa Yes (10) Yes (3)
Punjab Yes (10) Yes (3)
Sindh N/A Yes (3)
Reciprocal Referral Mechanism Exists Between Labor Authorities and Social Khyber Pakhtunkhwa No (10) No (3)
Services Punjab No (10) No (3)
† Data are from January–September 5, 2018 (111)  

Pakistan’s provinces are responsible for enforcing labor laws, including those relevant to child labor law. (13)
Provincial labor departments collect comprehensive data on labor law enforcement at the district level.
However, there is neither a centralized federal repository for the data nor any regular mechanism for reporting it
to the federal government; therefore, limited labor inspection data were available for inclusion in this report. (10)

Based on 2017 data, the number of labor inspectors is likely insufficient for the size of Pakistan’s workforce,
which includes approximately 64 million workers. According to the ILO’s technical advice of a ratio approaching
1 inspector for every 15,000 workers in developing economies, Pakistan should employ about 4,259 labor
inspectors. (118,119) Provincial labor inspectorates do not receive sufficient resources, which may hamper
labor inspectors’ ability to inspect workplaces. For example, labor departments in Khyber Pakhtunkhwa, Punjab,
and Sindh Provinces did not provide funds to cover the cost of transportation to conduct inspections. (3,10)
Furthermore, while labor inspectors do receive some initial training depending on their assigned province,
this training is insufficient, as there is very little information provided that is specific to child labor issues and
laws. (3,21,97,120,121)

The Punjab labor inspectorate conducted 10 training sessions for 185 labor inspectors at the Industrial Relations
Institute. Further, the Punjab Labor Welfare Department registered 1,441 first investigative reports (FIRs), which
are prepared by the police upon receiving information on violations of Punjab’s child employment restrictions,
and 616 FIRs for violations prohibiting child labor in brick kilns. (3,102) In Sindh Province, research found that
inspectors stopped conducting unannounced inspections due to complaints of harassment filed against inspectors
by employers. (124) Only labor courts can assess penalties for labor law violations; labor inspectors can only
note the labor violation. (3,21)

Criminal Law Enforcement

In 2019, criminal law enforcement agencies in Pakistan took actions to combat child labor (Table 7). However,
gaps exist within the operations of the criminal enforcement agencies that may hinder adequate criminal law
enforcement, including reports of corruption and indifference on the part of investigative officials.

Table 7. Criminal Law Enforcement Efforts Related to Child Labor

Overview of Criminal Law Enforcement 2018 2019
Initial Training for New Criminal Investigators Unknown (10) Yes (3)
Training on New Laws Related to the Worst Forms of Child Labor Unknown (10) Unknown (3)
Refresher Courses Provided Yes (110) Unknown (3)
Number of Investigations Unknown (10) Unknown (3)
Number of Violations Found Unknown (10) Unknown (3)
Number of Prosecutions Initiated Unknown (10) Unknown (3)
Number of Convictions Unknown (10)   Unknown (3)
Imposed Penalties for Violations Related to The Worst Forms of Child Labor Unknown Unknown (3)
Reciprocal Referral Mechanism Exists Between Criminal Authorities and Social Services Unknown (10) No (3)

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In 2019, Pakistan’s Prime Minister directed the government to launch a new mobile application, “Mera Bacha
Alert,” to improve reporting and reduce the number of abductions and sexual exploitation cases perpetrated
against children. (125) The federal and provincial governments do not publish data on efforts to enforce criminal
laws prohibiting the worst forms of child labor; it is unknown whether investigations, prosecutions, or convictions
were undertaken or achieved for child labor crimes in 2019. (3) While training is provided to new criminal
investigators, the training is inconsistent across Pakistan, and the training might not include information on child
labor, child trafficking, or sexual exploitation of children. (3)

Research indicates that police corruption, particularly the taking of bribes from suspected perpetrators to
ignore alleged crimes, continues to hamper Pakistan’s ability to eliminate child labor, especially in the brick
kiln industry, factories, street scavenging, and the sexual abuse of children in madrassas. In addition, children,
parents, or family members who report child labor incidents often lack faith that police will act in pursuit of
justice. (26,54,52-51) Research also found that police sometimes act indifferently to reports of child labor
or sexual exploitation, pointing to cultural differences as a rationale for abuse. Further, some police are
reportedly afraid of being accused of blasphemy by religious clerics if they take action against the sexual abuse of
children in madrassas. (26,54,126)

Of particular concern, in July 2019, a 14-year-old domestic worker reported substantial indicators of trafficking
by her employer, a parliamentarian in Punjab, including sexual abuse and torture. While police registered the
charges, they did not arrest the parliamentarian, allegedly because the provincial government did not allow them
to do so. (46,127) The parliamentarian continued to pressure the victim to drop the charges. In January 2020,
the Supreme Court set aside the extended three-year sentence imposed on a judge and his wife for cruelty
to a child for subjecting a 10-year-old girl to torture and domestic servitude—the government’s first reported
conviction of an official complicit in trafficking-related offenses in 10 years—and reinstated the initial sentence of
one year’s imprisonment. (46,127)

IV. COORDINATION OF GOVERNMENT EFFORTS ON CHILD LABOR

The government has established mechanisms to coordinate its efforts to address child labor (Table 8). However,
gaps exist that hinder the effective coordination of efforts to address child labor, including fulfilling mandates to
establish coordinating mechanisms.

Table 8. Key Mechanisms to Coordinate Government Efforts on Child Labor

Coordinating Body Role & Description
Provincial and Federal Advise on the enforcement of labor laws, including child labor laws, and monitor the functioning of labor
Tripartite Consultative departments at the provincial level. Monitor the implementation of provinces’ proposed interventions on child and
Committees forced labor at the federal level. (128) Research was unable to determine whether these coordinating bodies were
active during the reporting period.
Inter-Agency Task Force Coordinates the anti-human trafficking efforts of the Ministry of the Interior, intelligence and law enforcement
agencies, the Ministry of Law and Justice, and the Ministry of Foreign Affairs. Supports 27 FIA anti-trafficking units
that work with provincial and district police officers to monitor and combat domestic and transnational human
trafficking. (129,130) Maintains an Integrated Border Management System. In 2019, the Inter-agency Task Force
logged a total of 1,539 human trafficking border interceptions. (3,102)

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Table 8. Key Mechanisms to Coordinate Government Efforts on Child Labor (Cont.)
Coordinating Body Role & Description
Child Protection Bodies Balochistan Child Protection Commission: Coordinates efforts related to child protection at the provincial
and district levels, advises on relevant policies and legislation, and supports the implementation of child protection
referral mechanisms. Led by the Balochistan Social Welfare Department, various government departments, including
the Education, Health and Labor departments, and law enforcement agencies. (108) In 2019, the Balochistan
Provincial Government launched the first CPU in Quetta in partnership with UNICEF. (3)
Khyber Pakhtunkhwa Child Protection and Welfare Commission: Coordinates efforts to enhance the
safety, welfare, and well-being of children at the provincial and local levels. Reviews and monitors implementation
of provincial laws and regulations related to child labor and those that affect the rights of children. (86) Led by the
Province’s Social Welfare, Special Education and Women Empowerment Department. (131) In 2019, the Khyber
Pakhtunkhwa Government operated 10 welfare homes for exploited children. (46)
Punjab Child Protection and Welfare Bureau: Coordinates the protection of destitute and neglected
children by appointing child protection officers, supervising CPUs, and establishing child protection institutions
and child protection courts. Chaired by an elected member of the board, which consists of three department
secretaries, three members of the provincial assembly, and representatives from NGOs and academia. (88) In 2019,
the Punjab Provincial Government collaborated with a mobile application developer to publish a mobile application
that allows information sharing when children run away from home. It also established eight CPUs. (3,102) In
2019, the Punjab CPWB operated open reception centers to identify and register children living on the street and
identified and assisted 8,114 children, a decrease from 10,203 in the previous reporting period. It also filed 616 First
Information Reports (FIRs) under the Punjab Prohibition of Child Labour from Brick Kilns Act. (127)
Sindh Child Protection Authority: Coordinates efforts to ensure the rights of children in need of special
protection, including child laborers, by establishing CPUs and appointing child protection officers. Reviews and
proposes amendments to existing laws and monitors the implementation of laws relevant to the protection of
children. Headed by the provincial minister, members include two parliamentarians, lawyers, social activists, and
representatives from departments that deal with children›s issues. (107) In 2019, was in the process of launching a
database that tracks child abuse cases, including the worst forms of child labor, in all 29 districts. It also established
12 CPUs and operated a 24-hour child protection hotline. (3,102)
Provincial CPUs: Take into custody at-risk children, including those rescued from exploitative labor situations.
Present cases of children taken into custody to the Child Protection Court or the appropriate authority.
Established in Punjab, Khyber Pakhtunkhwa, and Sindh Provinces. (86,88,102,106-108) Coordinate and initiate
interventions against child labor at the provincial level. (128) Each CPU is led by a Child Protection Officer and
supported by social workers and psychologists. Operates under the District Administrator. (46) Established in
Punjab, Khyber Paktunkhwa, and Sindh Provinces. (46) In 2019, the Government of Khyber Pakhtunkhwa established
a specialized Child and Bonded Labor Unit; the rules and regulations by which this unit will operate have not yet
been established. (102) Balochistan and Sindh Provinces and the Islamabad Capital Territory (ICT) made efforts to
establish specialized Child and Bonded Labor Units. (132) Research was unable to determine whether the Punjab
Provincial Child Labor Unit was active during the reporting period.
Child Protection Coordinates ICT’s implementation of the Child Protection System Act of 2018, including advising the government
Advisory Board* on implementing laws and policies, maintaining a case management system, and ensuring that a child protection
mechanism is functioning. Chaired by the Secretary of the Division of Child Protection and comprises high-level
government officials, plus an NGO representative, a social science expert, an Islamabad High Court Bar Association
representative, and one person representing minorities. (3,133) In 2019, 12 Child Protection Committees were
established at the ICT level and began receiving orientation training on child trafficking laws. Further, the board met
for the first time, chaired by the Minister for Human Rights, and agreed to form a subcommittee to plan long- and
short-term policies to improve child protection issues in the ICT. (3,102,134)  
* Coordinating body responsible for coordinating government efforts on child labor was created during the reporting period.

The federal government had not established the National Commission on the Rights of the Child as mandated
by law at the end of the reporting period. (3,46) Khyber Pakhtunkhwa has 12 CPUs, however, none were active
during the reporting period due to a lack of finances. Balochistan established one CPU in Quetta, however,
they have not yet instituted the remaining 33 CPUs despite passing legislation in 2016 to establish units in each
district. (41,46)  

V. GOVERNMENT POLICIES ON CHILD LABOR

The government has established policies related to child labor (Table 9). However, policy gaps exist that hinder
efforts to address child labor, including mainstreaming child labor issues into relevant policies.

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Table 9. Key Policies Related to Child Labor
Policy Description
Khyber Pakhtunkhwa Seeks to gradually eradicate child labor, collect child labor statistics, enforce the compulsory education law, assist
Labor Policy children through referral mechanisms, educate families and key stakeholders about the negative effects of child labor,
and collaborate with organizations to research and develop solutions to eliminate child labor. (136) In 2019, an
exclusive child labor unit was established under the Directorate of Labor. (21)
Punjab Labor Policy Seeks to improve working conditions, eradicate child and bonded labor, and establish social safety for workers and
their families. Includes the goal of ending all child labor in brick kilns, in addition to the construction of schools,
hospitals, and residences for workers. (137) This policy led to the implementation of the Punjab Domestic Workers Act
2019 during the reporting period. (46)
Sindh Labor Policy Seeks to protect vulnerable workers, including children. Includes goals to enforce laws dealing with hazardous child
labor, extend the minimum age for employment in domestic and home-based work, ensure minimum wages for
working children, and increase access to education and training. (138) While this policy was being instituted through
labor inspector trainings during the reporting period, research found that labor inspectors were not provided funding
to travel outside of major cities to conduct inspections and were repeatedly denied access to inspect factories by
owners. (3)
‡ The government had other policies that may have addressed child labor issues or had an impact on child labor. (140-144)

Research was unable to determine whether the provincial or federal governments have educational policies and,
if so, whether such policies include child labor elimination and prevention strategies. (140-143)

VI. SOCIAL PROGRAMS TO ADDRESS CHILD LABOR

In 2019, the government funded and participated in programs that include the goal of eliminating or preventing
child labor (Table 10). However, gaps exist in these social programs, including the adequacy of programs to
address the full scope of the problem.

Table 10. Key Social Programs to Address Child Labor

Program Description
Bait-ul-Mal Programs† Government-funded programs that aim to remove children from child labor, including its worst forms,
and to increase vulnerable children’s access to education. Programs include the National Centers for
Rehabilitation of Child Labor and the Child Support Program. (145,146) These programs were active in
2019. (3)
Hotlines FIA operates a 24/7 hotline to combat human trafficking, including child trafficking, in Pakistan at the
headquarters, ICT, and district levels. (4,102) The Ministry of Human Rights (MOHR) also operates a hotline
for reporting human rights violations, including child labor violations. In 2019, the MOHR hotline received
between 4,000–15,500 calls per month. (4) The Punjab Child Protection and Welfare Bureau and Sindh
Social Welfare Department also operate hotlines in their respective provinces to combat child exploitation.
Both hotlines were operational in 2019. (4) Other provinces maintain functioning hotlines to report human
trafficking incidents, including the commercial sexual exploitation of children. (102)
Elimination of Child Labor Punjab Province-funded programs that aim to provide education to vulnerable children, rehabilitate bonded
and Bonded Labor Project laborers working in brick kilns, promote integration and coordination of government responses, strengthen
(Integrated Project for legislation, increase the capacity of law enforcement and service providers, and increase the knowledge
Promotion of “Decent Work for base on these issues. (49,147,148) In 2019, this project provided children working in brick kilns with free
Vulnerable Workers” in Punjab education. (46)
Province)†
ILO-Funded Projects ILO projects in Pakistan that aim to eliminate child labor by improving the capacity of the national
government to develop strong monitoring mechanisms and strengthen data collection strategies.
The Sustaining Strengthened National Capacities to Improve ILS Compliance and Reporting in Relevant EU
Trading Partners (2018–2020) works with provincial labor departments, with a focus on Balochistan, to use
analytical and evidence-based initiatives to guide child labor elimination programs. (149) The Clear Cotton
Project (2018–2022) works with local governments to eliminate child labor in cotton-growing districts
and in the textile and garment sectors. (150) Research was unable to determine whether activities were
undertaken to implement these projects during the reporting period.
Khdmat ATM Cards† Government-funded program to increase enrollment in schools that focuses on low income families.
Provides approximately $12.50 to a family whose child enrolls in school and then approximately $6.25 per
month to each child enrolled after verifying school attendance records. (132) This program was active
in 2019.

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Table 10. Key Social Programs to Address Child Labor (Cont.)
Program Description
Sabaoon Rehabilitation Center† NGO-run, federal government-funded center that rehabilitates children who were recruited and
ideologically influenced by terrorist organizations and militant groups. Reintegrates youth into society by
providing psychological treatment, education, and vocational training. (10,130,151) Research was unable to
determine whether activities were undertaken to implement this program during the reporting period.
† Program is funded by the Government of Pakistan.

In 2019, the Provincial labor departments of Khyber Paktunkhwa and Balochistan dedicated approximately
$1.53 million and $1.37 million of their budgets, respectively, to conduct surveys on child labor. The Khyber
Paktunkhwa labor department began conducting its child labor survey Child labor survey during the reporting
period. (46,102) Child labor surveys are also being carried out in Sindh and the ICT, while the child labor
survey project in Balochistan is still being planned. (21) In addition, Khyber Pakhtunkhwa, Punjab, and Sindh
Provinces established rehabilitation service centers for street children in 2019. These centers provided street
children with education, health, career, and psychological counseling services. (46,132)

The social programs of the federal and provincial governments are insufficient to address the prevalence
and scope of Pakistan’s child labor problem. Existing programs also do not provide enough protection and
rehabilitation services for bonded child laborers and victims of human trafficking. (110,129) Government
initiatives are needed to specifically target child labor in the informal sector, including child labor and forced child
labor in domestic work. (121) Furthermore, additional social programs are necessary to raise awareness and
provide assistance to children used by non-state militant groups to engage in armed conflict. (152) In addition,
there is no significant social program to address sexual abuse of child workers or children learning in madrassas
in Pakistan.

VII. SUGGESTED GOVERNMENT ACTIONS TO ELIMINATE CHILD LABOR

Based on the reporting above, suggested actions are identified that would advance the elimination of child labor
in Pakistan (Table 11).

Table 11. Suggested Government Actions to Eliminate Child Labor

Year(s)
Area Suggested Action
Suggested
Legal Accede to the Palermo Protocol on Trafficking in Persons. 2013 – 2019
Framework Establish a minimum age for work of at least 14 in all sectors and informal employment, regardless of the 2011-2019
number of employees, including in federal law and the provinces.
Ensure that the law prohibits the employment of children under age 18 in hazardous work, including in federal 2009 – 2019
law and Balochistan Province.
Ensure that the federal and provincial lists of hazardous work prohibited for children are comprehensive, 2009 – 2019
including brickmaking, domestic work, and mining.
Ensure that federal and provincial law criminally prohibits child trafficking without requiring an element of 2019
force, fraud, or coercion.
Ensure that the law prohibits the use of children in illicit activities, including in the production and trafficking 2011 – 2019
of drugs, including in federal law and Balochistan and Khyber Pakhtunkhwa Provinces.
Ensure that the law criminalizes the use, procurement, and offering of children in prostitution, pornography, 2011 – 2019
and pornographic performances, including in federal law and Balochistan and Khyber Pakhtunkhwa Provinces.
Ensure that the law criminally prohibits the recruitment and use of children under age 18 by non-state groups 2015 – 2019
for armed conflict, including in federal law and Balochistan and Khyber Pakhtunkhwa Provinces.
Raise the minimum age for work to the age up to which education is compulsory. 2019

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Table 11. Suggested Government Actions to Eliminate Child Labor (Cont.)
Year(s)
Area Suggested Action
Suggested
Enforcement Ensure there are a sufficient number of inspectors trained and responsible for providing enforcement of child 2019
labor laws to meet international standards in Punjab Province.
Provide the funding necessary to adequately hire, train, equip, and cover the cost of transportation 2010-2019
for inspectors to enforce child labor laws, especially in Khyber Paktunkhwa, Punjab and Sindh provinces.
Ensure labor inspectors are permitted to conduct unannounced inspections in Sindh Province without 2019
harassment, as mandated by Sindh’s labor code.
Ensure that District Vigilance Committees that seek to ensure enforcement and implementation of bonded 2013-2019
labor prohibitions are established in Khyber Pakhtunkhwa and Balochistan Provinces.
Ensure all allegations of sexual abuse, including allegations of bacha bazi and trafficking of boys into 2019
Afghanistan, are thoroughly investigated and, where appropriate, prosecuted.
Allow labor inspectors to assess penalties. 2011 – 2019
Create a centralized repository of labor law enforcement data and a regular mechanism for reporting it to 2018 – 2019
the federal government, and make the data publicly available.
Increase the number of labor inspectors to meet the ILO’s technical advice. 2016 – 2019
Publish enforcement data for child labor law violations, penalties imposed, and penalties collected for 2010 – 2019
all provinces. In addition, publish information about labor inspectorate funding, the number of labor
inspectors, the number of labor inspections conducted at the worksite, whether routine inspections were
targeted, and whether unannounced inspections were conducted for all provinces.
Establish sufficient laws to end police corruption, particularly the taking of bribes from suspected 2019
perpetrators to ignore alleged crimes.
Establish a referral mechanism between criminal law enforcement agencies and social services in all provinces. 2018 – 2019
Publish information about criminal law investigations, violations found, prosecutions initiated, and the number 2016 – 2019
of convictions, as well as initial training, training on the worst forms of child labor, refresher courses, and
penalties imposed and collected in all provinces.
Establish a referral mechanism between labor authorities and social services in all provinces. 2017 – 2019
Coordination Establish a National Commission on the Rights of the Child Act, as mandated by federal law. 2018 – 2019
Publish information on the activities undertaken by the Provincial and Federal Tripartite Consultative 2017 – 2019
Committees.
Establish the remaining 32 CPUs in Balochistan as required by law. 2019
Government Ensure inspectors are provided with sufficient resources and are not stymied from executing Sindh Province’s 2019
Policies Labor Policy by factory owners.
Integrate child labor elimination and prevention strategies in the education policies of the provincial 2014 – 2019
governments.
Social Complete and publish child labor surveys at the federal and provincial levels. 2009 – 2019
Programs Publish information on activities undertaken during the reporting period to implement the ILO-funded 2019
programs Sustaining Strengthened National Capacities to Improve ILS Compliance and Reporting in Relevant
EU Trading Partners (2018–2020) and The Clear Cotton Project (2018-2022).
Publish information on activities undertaken by Sabaoon Rehabilitation Center during the reporting period. 2019
Implement programs to address and eliminate the sexual abuse of children, especially in madrassas, 2019
workplaces, and on the street.
Improve existing programs and increase the size and scope of government programs to reach children 2009 – 2019
working in the informal sector and in the worst forms of child labor, including domestic workers, bonded
child laborers, and other victims of human trafficking.
Implement programs to address high rates of teacher absenteeism, inadequate facilities, lack of transportation, 2011 – 2019
and use of corporal punishment to ensure that all children have access to free and compulsory education,
as required by law. Increase security for schools to protect children and teachers from attacks by non-state
armed and extremist groups.
Implement programs to raise awareness of and provide assistance to children used by non-state militant 2011 – 2019
groups to engage in armed conflict.

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2016-Autosaved1-edited111.pdf. 63 Pakistan Observer. Street children soon to outnumber schoolchildren:
43 The Express Tribune. Sargodha child porn case. April 14, 2017. Shakoor. July 29, 2019.
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44 Ali, Imtiaz. FIA arrests suspect involved in child pornography from schoolchildren-shakoor/.
Karachi. Dawn, November 30, 2018. 64 Ijaz, Saroop. End corporal punishment in Pakistan’s schools. Human
https://www.dawn.com/news/1448610. Rights Watch, September 16, 2019.
45 Daily Times. FIA arrests man for sexually molesting children and filming https://www.hrw.org/news/2019/09/16/end-corporal-punishment-
them. December 27, 2018. pakistans-schools.
https://dailytimes.com.pk/337843/fia-arrests-man-for-sexually-molesting- 65 Shah, Aamir. One million children of unknown parentage face identity
children-and-filming-them/. crisis in Pakistan. Arab News, January 30, 2018. https://www.arabnews.
46 U.S. Embassy Islamabad official. E-mail communication to USDOL com/node/1236296/world.
official. July 12, 2020. 66 Government of Pakistan. The Factories Act. Enacted: January 1, 1935.
47 Ghani, Faras. The spiralling debt trapping Pakistan’s brick kiln workers. Al http://www.ilo.org/dyn/natlex/docs/WEBTEXT/35384/64903/E97PAK01.
Jazeera. October 21, 2019. htm.
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48 U.S. Department of State. Human Rights Report- 2020: http://www.ilo.org/dyn/travail/docs/1008/West Pakistan Shops and
Pakistan. Washington, DC, May 9, 2020. Establishments Ordinance 1969.pdf.
https://www.state.gov/wp-content/uploads/2020/03/PAKISTAN-2019- 68 Government of Pakistan. The Mines Act. Enacted: 1923.
HUMAN-RIGHTS-REPORT.pdf http://extwprlegs1.fao.org/docs/pdf/pak64462.pdf.
49 Pakistan Observer. “Minister for eliminating menace of child labour from 69 Government of Pakistan. Road Transport Workers Ordinance. 1961.
society.” October 25, 2016. Source on file. http://www.ilo.org/dyn/travail/docs/1005/Road Transport Workers
50 U.S. Department of State. Trafficking in Persons Report- 2020: Ordinance 1961.pdf.
Pakistan. Washington, DC, June 25, 2020. 70 Government of Khyber Pakhtunkhwa Province. Khyber Pakhtunkhwa
https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report- Prohibition of Employment Children Act. Enacted: May 2015.
Complete-062420-FINAL.pdf http://www.pakp.gov.pk/2013/wp-content/uploads/Prohibition-of-
51 Nazish, Kiran. Pakistan’s shame: the open secret of child sex abuse in the Employment-of-Children-Bill-2015-S.pdf.
workplace. The Guardian, June 15, 2018. 71 Government of Khyber Pakhtunkhwa Province. The Khyber
https://www.theguardian.com/global-development/2018/jun/15/pakistan- Pakhtunkhwa Factories Act. 2013.
shame-open-secret-child-sex-abuse-workplace-kasur. http://kp.gov.pk/uploads/2016/02/5._Factories_Act,_2013_.pdf.
52 Ganon, Kathy. Child sex abuse in Pakistan’s religious schools is 72 Government of Khyber Pakhtunkhwa Province. Government of Khyber
endemic. Associated Press, May 11, 2020. Pakhtunkhwa Shops and Establishments Act. 2015. http://kp.gov.pk/
https://apnews.com/8fe530dc76beb1893b3b52af88cf99dd. uploads/2016/02/12._Shops_and_Establishments_Act,_2015_.pdf.
53 Anoosha. Bacha Bazi - Pedophilic Boy Play. Runway Pakistan, October 2, 73 Government of Punjab Province. The Punjab Prohibition of Child Labor
2019. at Brick Kilns Ordinance. Enacted: January 14, 2016.
https://runwaypakistan.com/bacha-bazi-pedophilic-boy-play/. http://www.ilo.org/dyn/natlex/docs/ELECTRONIC/102087/123287/
54 Ganon, Kathy. Islamic schools in Pakistan plagued by sex abuse of F1018921745/PAK102087.pdf.
children. Associated Press, November 21, 2017. 74 Government of Punjab Province. Punjab Restriction on Employment of
https://apnews.com/ddd9660f63ae4433966684823f79d3e9/Islamic- Children Ordinance. Enacted: July 13, 2016.
schools-in-Pakistan-plagued-by-sex-abuse-of-children. http://www.punjabcode.punjab.gov.pk/public/dr/PUNJAB RESTRICTION
55 Ganon, Kathy. Fear, shame preserve silence of abuse by clerics in ON EMPLOYMENT OF CHILDREN ORDINANCE 2016.doc.pdf.
Pakistan. Associated Press, December 16, 2017. 75 Government of Sindh Province. Sindh Shops and Commercial
https://apnews.com/991960af1b984958bc6727ef62812aee/Fear,-shame- Establishment Act. Enacted: April 29, 2016.
preserve-silence-of-abuse-by-clerics-in-Pakistan. http://www.ilo.org/dyn/natlex/docs/ELECTRONIC/102142/123388
56 UN General Assembly. Children and Armed Conflict: Report of the /F-1352480253/PAK102142.pdf.
Secretary-General. May 16, 2018: A/72/865–S/2018/465. 76 Government of Sindh Province. Sindh Factories Act. Enacted: April 29,
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&Area=UNDOC. https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/102141/123387/
57 Society for the Protection of the Rights of the Child State of Pakistan’s F839757544/PAK102141.pdf.
Children.Violence Against Children. 2017. http://www.sparcpk.org/ 77 Government of Sindh Province. Sindh Prohibition of Employment of
sopc2017/2-Violence Against Children.pdf. Children Act. Enacted: January 25, 2017.
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Students, Teachers, and Schools in Pakistan. March 27, 2017. 78 Government of Pakistan. Pakistan Employment of Children Act, Act No.
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search/view_doc.asp?symbol=S/2019/509&Lang=E. 79 Government of Pakistan. Bonded Labour System (Abolition)
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her? November 12, 2018.
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pdf.

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 Pakistan
MODERATE ADVANCEMENT
http://www.na.gov.pk/uploads/documents/1334287962_481.pdf. 99 Government of Balochistan Province. Resolution no. 55. August 16,
80 Government of Pakistan. Pakistan Penal Code, XLV of 1860. Enacted: 2019. Source on file.
October 6, 1860. 100 Zafar, Mohammad. Lawmakers pass resolution against child labour. The
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81 Government of Pakistan. Prevention of Trafficking in Persons https://tribune.com.pk/story/2102868/1-lawmakers-pass-resolution-
Act. Enacted: 2018. child-labour.
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82 Government of Khyber Pakhtunkhwa Province. Khyber Pakhtunkhwa abuse. Dawn. November 20, 2019.
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System-Abolition-ACT-2015.pdf. 102 Government of Pakistan Inputs for the US TIP Report 2019–
83 Government of Punjab Province. The Punjab Bonded Labor System 2020. March 11, 2020. Source on file.
(Abolition) (Amendment) Act. Enacted: 2012. 103 Government of Punjab Province. Labour Courts. Accessed January 18,
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/F-1719753875/PAK102096.pdf. https://www.punjab.gov.pk/provincialdepartments_labour_lc.
84 Government of Sindh Province. Sindh Bonded Labor System (Abolition) 104 Government of Sindh Province. Labour Courts. Accessed January 18,
Act. Enacted: 2016. Source on file. 2019.
85 Government of Pakistan. Prevention and Control of Human Trafficking http://sindh.gov.pk/dpt/Labour_HRM/l.courts.htm.
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86 Government of Khyber Pakhtunkhwa Province. Khyber Pakhtunkhwa Khyber_Pakhtunkhwa.html.
Child Protection and Welfare Act. Enacted: 2010. 106 Child Protection & Welfare Bureau. Child Protection Unit, Government
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F1592784103/PAK92232.pdf. https://cpwb.punjab.gov.pk/functional_unit.
87 Government of Pakistan. The Criminal Law (Second Amendment) Act, 107 Government of Sindh Province. The Sindh Child Protection Authority
amending the Pakistan Penal Code. Enacted: March 22, 2016. Act, XIV of 2011. Enacted: June 9, 2011.
http://www.na.gov.pk/uploads/documents/1467011388_916.pdf. http://www.pas.gov.pk/uploads/acts/Sindh Act No.XIV of 2011.pdf.
88 Government of Punjab Province. Punjab Destitute and Neglected 108 Government of Balochistan Province. Balochistan Child Protection
Children (Amendment) Act. Enacted: 2004. Source on file. Act. Enacted: November 15, 2016.
89 Government of Pakistan. National Service Ordinance. Enacted: 1970. http://pabalochistan.gov.pk/uploads/acts/2016/Act072016.pdf.
http://molaw.bizz.pk/body.php?sg=&id=32190#4. 109 The Express Tribune. LHC orders govt to pay school fees of kiln
90 Government of Pakistan. The Right to Free and Compulsory Education workers. March 29, 2019.
Act, 2012, No. XXIV. Enacted: December 19, 2012. https://tribune.com.pk/story/1939614/1-lhc-orders-govt-pay-school-
http://www.na.gov.pk/uploads/documents/1357015194_179.pdf. fees-kiln-workers/.
91 Government of Balochistan Province. The Compulsory Education in the 110 U.S. Embassy- Islamabad. Reporting. April 12, 2019.
Province of Balochistan Act, No. 5 of 2014. Enacted: February 6, 2014. 111 The News. New labour policy soon, says minister. September 5, 2018.
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/F-955909891/PAK96221.pdf. minister.
92 Government of Punjab Province. Punjab Free and Compulsory 112 Government of Pakistan. Industrial Relations Act, 2012. Enacted: March
Education Act. Enacted: November 10, 2014. 14, 2012.
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F770068822/PAKD99329.pdf. 113 Government of Balochistan Province. Industrial Relations
93 Government of Sindh Province. The Sindh Right of Children to Free and Act. 2010. Source on file.
Compulsory Education Act. Enacted: March 6, 2013. 114 Government of Khyber Pakhtunkhwa Province. Indsutrial Relations
http://unesco.org.pk/education/documents/2013/rte_sindh_feb/Sindh_ Act. Enacted: 2013.
Act_RTFCE.pdf. http://kpcode.kp.gov.pk/uploads/2013_11_THE_KHYBER_
94 ILO. National Labour Law Profile: Islamic Republic of Pakistan. Accessed PAKHTUNKHWA_INDUSTRIAL_AND_COMMERCIAL_
August 1, 2019. EMPLOYMENT_STANDING_ORDERS_ACT_2013.pdf.
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95 UN Committee on the Rights of the Child. List of issues in relation to 116 Government of Sindh Province. Industrial Relations Act. Enacted: 2013.
the fifth periodic report of Pakistan - Addendum: Replies of Pakistan http://www.pas.gov.pk/uploads/acts/Sindh Act No.XXIX of 2013.pdf.
to the list of issues. Prepared by the Government of Pakistan. April 11, 117 Bhatti, Khalid. Banning labour inspection. The News. September 10, 2019.
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96 Government of Pakistan. Islamabad Capital Territory Prohibition of Materials section of this report.
Employment of Children Bill. 2018. https://www.cia.gov/library/publications/the-world-factbook/geos/
http://www.senate.gov.pk/uploads/documents/1527223531_751.pdf. pk.html
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official. June 27, 2019. Annex. 2017. Please see “Labor Law Enforcement: Sources and
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121 U.S. Embassy Islamabad official. E-mail communication to USDOL 139 Federally Administered Tribal Areas Secretariat. Child Protection
official. June 6, 2016. Policy. 2012. Source on file.
122 Government of Punjab Province. A Delegation of All Pakistan 140 Government of Sindh Province. Sindh Education Sector Plan, 2014–2018.
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129 U.S. Department of State. Trafficking in Persons Report- 2018: 148 Dawn. Project for Eradication of Child Labor Launched. August 26, 2016.
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134 Dawn. Child Advisory Board holds first meeting. August 30, 2019. 153 Government of Pakistan. Constitution (Eighteenth Amendment)
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islamabad/documents/publication/wcms_647697.pdf.

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