Is digital advertising regulated in Pakistan?

Updated for policy landscape as of late 2024. Always obtain legal advice for your specific campaign.

Short answer

Yes, digital advertising is regulated in Pakistan—but not by a single, dedicated “online advertising law.” Instead, it is governed by a patchwork of statutes, regulator-issued rules, sector-specific restrictions (e.g., health, tobacco, finance), provincial consumer-protection laws, competition law, telecom anti-spam rules, election rules, and platform policies. Online ads are also subject to general criminal, intellectual property, and decency laws. In practice, multiple authorities can enforce different aspects of the same campaign.

Why this matters

If you buy media on Facebook, Instagram, YouTube, Google, TikTok, programmatic exchanges, OTT/CTV, or run email/SMS/WhatsApp marketing in Pakistan, you need to ensure:

The product or service is lawful to advertise.
Your claims are substantiated and not misleading.
You respect content and cultural restrictions.
You have consent for direct marketing messages.
You handle user data responsibly.
You comply with taxation and disclosure rules.

Who regulates digital advertising in Pakistan?

Key public bodies and what they typically cover:

Pakistan Telecommunication Authority (PTA) – Oversees internet/telecom. Enforces the Prevention of Electronic Crimes Act 2016 (PECA) provisions on unlawful online content via rules notified in 2021. Can order removal/blocking of online content, including ads, that violate Pakistani law (e.g., obscenity, blasphemy, hate speech, gambling, illegal products).
Competition Commission of Pakistan (CCP) – Enforces the Competition Act 2010 and Deceptive Marketing Practices Regulations 2014. Targets misleading and false advertising, bait-and-switch, hidden charges, unsubstantiated “No.1” claims, and comparative ads that mislead consumers.
PEMRA (Pakistan Electronic Media Regulatory Authority) – Licenses and regulates broadcast (TV/FM). While PEMRA does not license generic online ads, its Code of Conduct 2015 influences standards for decency and prohibited categories, and applies to licensed broadcasters’ digital extensions.
Election Commission of Pakistan (ECP) – Issues Codes of Conduct during election periods that cover political advertising across media, including social media. Regulates spending ceilings, disclosures and content (e.g., bans on hate speech, incitement).
DRAP (Drug Regulatory Authority of Pakistan) – Regulates advertising for medicines, therapeutic goods, nutraceuticals, and medical devices. Many categories require prior approval; health claims must be accurate and within label approvals.
State Bank of Pakistan (SBP) & SECP (Securities & Exchange Commission of Pakistan) – Sectoral oversight. Banking/fintech marketing must avoid mis-selling; securities, mutual funds, insurance, and investment promotions are closely scrutinized for fair disclosure, risk warnings, and license status.
Provincial Consumer Protection Authorities and Courts – Punjab, Sindh, Khyber Pakhtunkhwa, Balochistan, and the Islamabad Capital Territory have consumer-protection statutes prohibiting unfair trade practices, including false and misleading online ads.
IPO-Pakistan (Intellectual Property Organization) – IP enforcement relevant to brand usage, copyright and trademarks in ads.
Tax authorities – Federal Board of Revenue (FBR) and provincial revenue authorities (PRA, SRB, KPRA, BRA) administer income tax, withholding tax and sales tax on advertising services and payments to foreign ad platforms.

Industry bodies such as the Pakistan Advertisers Society (PAS), the Pakistan Broadcasters Association (PBA), and APNS often promote self-regulatory standards, though these are not laws.

The legal framework that touches online advertising

These are the core laws and rules most relevant to digital marketing in Pakistan:

Prevention of Electronic Crimes Act, 2016 (PECA) and the 2021 Rules on removal/blocking of unlawful online content. These do not set ad-specific standards, but they empower the PTA to remove content—including ads—that is illegal under Pakistani law.
Competition Act, 2010 and the CCP Deceptive Marketing Practices Regulations, 2014 – The backbone of truth-in-advertising. Covers misleading claims, omissions, bait advertising, misleading price promotions, disparaging comparisons, and false endorsements.
Provincial Consumer Protection Acts – Prohibit unfair trade practices, false statements about quality, quantity, or price, and misleading warranties. Consumers can seek redress in consumer courts.
Intellectual property law – Copyright Ordinance 1962 and Trademarks Ordinance 2001 apply to creative, logos, music, images, and comparative advertising.
Telecom anti-spam regulations – PTA has long-standing rules to curb spam and obnoxious communications over telecom networks, and maintains a Do-Not-Call Register for telemarketing. Unsolicited bulk SMS/robocalls are restricted.
Political/election rules – The Elections Act 2017 and ECP’s Codes of Conduct regulate campaign advertising across media, including digital.
Sector-specific laws (apply online too):
- Tobacco – Comprehensive bans on advertising, promotion and sponsorship of tobacco products across media.
- Alcohol – Advertising of alcoholic beverages is prohibited.
- Drugs/therapeutics – The Drugs Act 1976, DRAP Act 2012 and DRAP rules strictly control advertising; many direct-to-consumer promotions are restricted or require approvals.
- Infant formula – Pakistan’s breastfeeding protection framework restricts promotion of breast-milk substitutes.
- Gambling/betting/lotteries – Generally illegal; promotion is prohibited.
- Financial services – Banking, insurance, investment and microfinance advertising must not mislead consumers about returns, risks, fees or license status; risk disclosures are expected.
- Food and nutrition – Claims must be accurate and in line with applicable food standards; avoid unsubstantiated health or halal claims.
Contests and promotions – Chance-based prize schemes can fall foul of anti-gambling laws unless structured carefully; skill-based contests are generally safer. Terms and conditions, eligibility, and no-purchase-necessary details should be clear.
Data and privacy – As of late 2024, Pakistan does not have a comprehensive data protection act in force. Drafts of a Personal Data Protection Bill have circulated, and future data-localization and consent requirements may affect ad tech. PECA and sectoral rules (e.g., banking) still constrain misuse of personal data.

Content rules: what you can and cannot advertise online

Digital advertising must comply with general Pakistani law on decency, religion, public order, and morality. In addition:

Prohibited categories – Alcohol, recreational drugs, gambling and betting, unlawful medical products, obscene or blasphemous content, and products/services illegal to sell are not permissible.
Tobacco – Advertising, promotion and sponsorship are largely banned, including on social media and influencer posts.
Medicines and health claims – DRAP enforces strict rules. Prescription drug advertising to the public is prohibited; over-the-counter, nutraceutical, cosmetic and device ads must be factual and may need prior clearance. Avoid disease-cure claims without approval.
Food and nutrition – Substantiate health or immunity claims; be cautious with claims aimed at children. Halal claims should be truthful and, where applicable, certified by recognized bodies.
Comparative and “No.1” claims – Allowed if true and not misleading. Keep evidence (e.g., independent surveys, audited data). Do not disparage competitors unfairly.
Pricing and “free” offers – Disclose all material terms, taxes, shipping, subscription auto-renewals, and minimum commitments. Hidden charges and dark patterns can be deemed deceptive marketing.
Decency and cultural sensitivity – Avoid vulgarity, stereotyping, or content offending religious sentiments. This applies to imagery, language, and user-generated creative.
Children and teens – No specific, comprehensive digital children’s advertising code exists, but general decency, harmful-product bans, and truth-in-advertising apply. Avoid profiling or targeting minors with age-inappropriate products.
Political advertising – Ensure compliance with ECP codes: no hate speech, sectarian content, or incitement; adhere to spending and disclosure rules.

Channel-specific considerations

Social media, influencers and creators

Disclosures – While Pakistan has no standalone influencer law, undisclosed sponsored content or paid endorsements can be considered deceptive under CCP rules. Use clear disclosures (e.g., “Paid partnership,” “#ad,” “Sponsored”).
Platform policies – Facebook, Instagram, YouTube, TikTok and X enforce their own ad and branded-content policies by market. Violations can lead to takedowns or account penalties even if local law is silent.
Sensitive categories – Health, finance, political and issues ads have stricter platform requirements (e.g., advertiser authorization, disclaimers).

Programmatic, display, CTV/OTT

Brand safety – Use inclusion/exclusion lists to avoid placements next to unlawful or culturally sensitive content; PTA can block pages or domains that repeatedly host unlawful material.
Audience targeting – Targeting based on inferred sensitive attributes (religion, health, political views) can be high-risk. Favor contextual or consent-based segments.
Web/OTT publishers – PEMRA’s licensing focuses on broadcast, but broader decency laws still apply to digital video. Watch evolving policy proposals for OTT regulation.

Email, SMS and WhatsApp marketing

Consent – Use opt-in lists. Unsolicited bulk SMS and robocalls are restricted under PTA rules; respect the Do-Not-Call Register for telemarketing.
Headers and identity – Don’t spoof sender IDs. Make it easy to opt out; honor opt-outs promptly.
Content – Avoid deceptive subject lines and hidden fees; retain proof of consent.

Data, tracking and cookies: where does Pakistan stand?

Pakistan has not yet enacted a GDPR-style, comprehensive privacy law as of late 2024, although drafts of a Personal Data Protection Bill have circulated and could introduce consent, data-subject rights, and data localization for certain categories in the future. Today:

Best practice – Use clear privacy notices, obtain consent for non-essential cookies and behavioral advertising where feasible, and provide opt-outs, especially if you target users in jurisdictions with extraterritorial privacy laws (e.g., EU GDPR).
PECA risks – Unauthorized access, identity misuse, and harmful use of personal data can attract criminal liability. Do not scrape or buy illicit data sets.
Cross-border transfer – Many ad-tech tools transfer data overseas. Monitor forthcoming laws for localization or transfer restrictions and adapt your vendor contracts (DPA, SCCs where applicable).

Substantiation and disclosure standards

To avoid CCP and consumer-protection risk, build a substantiation file before you go live:

Evidence – Keep test results, lab reports, third-party audits, survey methodologies, and source data for claims such as “No.1,” “fastest,” “clinically proven,” “kills 99.9%.”
Disclaimers – Ensure disclaimers are clear, conspicuous, and in a readable language for your audience (Urdu/English). Avoid burying material terms in fine print or on a separate page only.
Translations – If you translate claims, ensure meaning and strength are preserved; mistranslations can mislead.
Endorsements – Influencer testimonials must reflect genuine experience and typical results. Disclose material connections.

Taxes and invoicing for digital advertising

Sales tax on services – Provincial authorities (PRA, SRB, KPRA, BRA) typically levy sales tax on advertising services provided in their jurisdiction. Agencies and media houses register and charge tax accordingly.
Withholding tax – Payments to non-resident ad platforms (e.g., Meta, Google) may be subject to withholding tax under Pakistan’s Income Tax Ordinance. Consult a tax adviser to determine applicable rates, double-tax treaty relief, and documentation.
Record-keeping – Maintain invoices, contracts, and proof of services rendered for audits. Clarify whether invoices are from local resellers or foreign entities.

Enforcement: how rules are applied

CCP actions – The CCP has investigated and fined advertisers (including telecoms, FMCG, and e-commerce) for deceptive marketing—e.g., exaggerated speed/coverage claims or undisclosed charges.
PTA takedowns – PTA can order removal or blocking of unlawful online content. Ads promoting illegal products or violating decency norms risk fast takedown.
DRAP crackdowns – Online promotions of unregistered drugs, miracle cures, and unauthorized health claims attract DRAP notices, seizures, and possible prosecution.
Consumer courts – Consumers can file complaints for misleading ads, especially around pricing, product quality, and failure to honor promotions.
ECP penalties – During election periods, political actors and media buyers face penalties for non-compliant online campaigning.

Compliance checklist for digital campaigns in Pakistan

Confirm the product/service is legal to advertise; obtain sectoral approvals if needed (e.g., DRAP).
Audit claims and creatives for truthfulness; compile substantiation and ensure clear, readable disclaimers.
Screen for cultural and religious sensitivity and avoid prohibited themes or imagery.
Implement influencer disclosure standards; ensure paid partnerships are transparently labeled.
Use consent-based lists for email/SMS/WhatsApp; respect the Do-Not-Call Register and provide easy opt-outs.
Review targeting settings to avoid minors and sensitive attributes; enable brand safety controls programmatically.
Adopt privacy-by-design: cookie consent where applicable, data minimization, vendor DPAs, and security measures.
Validate promotion mechanics (contests, giveaways, cashbacks) against anti-gambling and consumer rules; publish T&Cs.
Ensure tax compliance: registrations, invoicing, sales tax collection, and withholding obligations for foreign platforms.
Prepare an escalation plan for takedown notices, consumer complaints, or regulator queries; archive ads and approvals.

Frequently asked questions

Do I need a government license to run Facebook or Google ads in Pakistan?

No general license is required just to place online ads. However, agencies providing advertising services must comply with tax registration and any sectoral licenses tied to their business. Your ad content and the product category must still comply with applicable laws.

Is influencer marketing legal?

Yes. But undisclosed paid endorsements or misleading testimonials can violate deceptive marketing rules. Use clear, upfront disclosure (e.g., “Paid partnership,” “#ad”). Sectoral restrictions still apply (e.g., no tobacco/alcohol).

Are cookie banners mandatory in Pakistan?

There is no comprehensive, GDPR-style cookie law in force as of late 2024. However, consent-oriented practices are advisable, especially if you serve users in jurisdictions with strict privacy laws or rely on third-party behavioral advertising.

Can I advertise betting, crypto, or forex trading?

Gambling/betting promotions are generally prohibited. Financial promotions (including crypto or leveraged forex) are high-risk and may be restricted by sectoral regulators and platform policies; many platforms prohibit or tightly control such ads.

Are comparative ads allowed?

Comparative advertising is permissible if it is accurate, non-disparaging, and supported by robust evidence. Misleading comparisons or unsubstantiated superlative claims can attract CCP action.

Can the government block my online ad?

Yes. PTA may order removal/blocking of online content that violates Pakistani law or public morality. Platforms also enforce their own community standards and regional ad policies.

Do I have to run ads in Urdu?

There is no blanket requirement to use Urdu. However, disclosures should be understandable by your target audience. For mass-market campaigns, consider Urdu or bilingual creatives to ensure clarity.

What about SMS blasts?

Unsolicited bulk SMS is restricted. Use opt-in lists, comply with sender ID rules, respect the Do-Not-Call Register, and include easy opt-out instructions.

Bottom line

Digital advertising in Pakistan is regulated—just not in a single place. Think of it as a matrix of truth-in-advertising (CCP), unlawful content control (PTA/PECA), sector-specific restrictions (DRAP, SBP, SECP), consumer protection (provincial laws), election-period rules (ECP), and tax compliance. Brands, agencies and creators that build transparent disclosures, robust claim substantiation, consent-based direct marketing, and culturally aware creative processes can scale online campaigns with less regulatory risk.

Note: This overview reflects the regulatory environment as of late 2024 and is for general information only. It is not legal advice. Consult qualified counsel for your specific campaign, product, and jurisdictions.