Your Pakistani customer has sent you a sustainability questionnaire. Here is what the law and SECP require of them — and what they need from you.
Pakistan has introduced mandatory ESG and sustainability reporting for listed companies through the Securities and Exchange Commission of Pakistan (SECP). The SECP's Listed Companies (Code of Corporate Governance) Regulations require sustainability reporting aligned with international frameworks. Pakistan is also subject to significant international supply chain scrutiny — particularly in the textile and garment sector, which supplies EU and UK buyers subject to CSRD, CSDDD, and the UK Modern Slavery Act. If you supply goods or services to a Pakistani buyer, their ESG obligations are driven both by domestic regulation and by the international buyers they supply.
Key regulations in Pakistan — ESG & Sustainability Supplier Guide
SECP Listed Companies (Code of Corporate Governance) Regulations
The SECP requires listed companies to include sustainability and ESG disclosures in their annual reports. The framework covers environmental impact, social responsibility, and governance practices. Companies are expected to assess and disclose material ESG risks across their value chain, including supplier assessment.
Pakistan Stock Exchange (PSX) ESG Reporting Guidelines
The PSX has issued ESG reporting guidelines for listed companies aligned with GRI and TCFD frameworks. While initially voluntary, the guidelines are being progressively incorporated into mandatory reporting requirements. Companies are encouraged to assess supply chain ESG risks as part of their materiality assessment.
EU CSRD and CSDDD Supply Chain Reach
Pakistan's textile and garment sector is a major supplier to EU and UK buyers. Those buyers are subject to CSRD mandatory sustainability reporting and CSDDD supply chain due diligence obligations. Pakistani suppliers to EU and UK companies will receive increasingly detailed ESG questionnaires driven by these European regulations — regardless of Pakistan's domestic framework.
UK Modern Slavery Act — Supply Chain Reach
UK companies with turnover above £36 million must publish annual modern slavery statements covering their supply chains. Pakistani suppliers to UK buyers — particularly in textiles, food, and manufacturing — will receive modern slavery questionnaires as part of their buyer's compliance process.
What this means for you as a supplier
You are not directly regulated by EU or UK ESG laws. But your Pakistani buyer may be — and if your buyer supplies EU or UK companies, those buyers' ESG obligations flow directly into your supply chain relationship. The textile and garment sector in particular faces intense scrutiny from EU and UK buyers subject to CSRD, CSDDD, and the Modern Slavery Act. A non-response or a weak response puts your buyer's export relationships at risk — and makes you a liability in their supply chain.
Key dates
2021
PSX ESG Reporting Guidelines issued — voluntary framework for listed companies
2023
SECP updates corporate governance regulations with enhanced sustainability disclosure requirements
FY2024
EU CSRD mandatory for large EU companies — Pakistani suppliers to EU buyers begin receiving structured questionnaires
July 2029
CSDDD supply chain due diligence obligations — EU buyers must assess Pakistani suppliers for human rights and environmental risks
2027 onwards
EU Forced Labour Regulation in force — goods produced with forced labour barred from EU market
The dual pressure on Pakistani suppliers
Pakistani suppliers face ESG pressure from two directions simultaneously. Domestically, SECP and PSX requirements are creating reporting obligations for listed companies and their supply chains. Internationally, the EU and UK regulatory frameworks — CSRD, CSDDD, and the Modern Slavery Act — are creating detailed questionnaire requirements for Pakistani suppliers to European buyers, particularly in the textile, garment, and manufacturing sectors.
The international pressure is currently more acute than the domestic framework for most Pakistani SME suppliers. EU and UK buyers are already sending structured questionnaires, and the requirements will intensify as CSDDD supply chain obligations take effect from July 2029.
What your buyer's questionnaire will ask
Questionnaires from Pakistani buyers aligned with SECP/PSX requirements, and from EU/UK buyers with supply chain reach into Pakistan, typically cover the following areas.
Labour rights and working conditions
Compliance with Pakistan's Factories Act, minimum wage legislation, and prohibition of child and forced labour. For textile suppliers, evidence of compliance with ILO core conventions is frequently required by EU and UK buyers.
Health and safety
Workplace safety management, fire safety compliance (particularly relevant after Karachi factory incidents), and evidence of worker training. EU buyers subject to CSDDD will require documented safety management systems.
Environmental management
Effluent treatment and water management (critical for textile dyeing operations), waste disposal, and emissions tracking. Pakistan's Environmental Protection Act compliance is the baseline; ISO 14001 certification is increasingly expected by EU buyers.
Modern slavery and forced labour
Evidence of no forced labour, debt bondage, or child labour. UK Modern Slavery Act questionnaires are detailed and require documented recruitment practices, worker contracts, and grievance mechanisms.
Governance and anti-corruption
Anti-corruption policies, code of conduct, and supplier agreement acceptance. SECP corporate governance requirements and international buyer codes of conduct both require documented governance frameworks.
Climate and emissions
Greenhouse gas emissions data is increasingly required by EU buyers subject to CSRD. Scope 1 and 2 data at minimum; Scope 3 (including supplier emissions) is the direction of travel under ISSB S2.
The textile sector — Pakistan's highest-risk supply chain
Pakistan is one of the world's largest textile exporters, supplying EU and UK retailers, brands, and manufacturers. These buyers are subject to CSRD mandatory sustainability reporting, CSDDD supply chain due diligence, and the UK Modern Slavery Act. The textile sector faces the most intense and immediate ESG questionnaire pressure of any Pakistani industry.
Textile suppliers should prioritise labour rights documentation, environmental compliance (particularly effluent treatment), and fire and building safety evidence. EU buyers are also increasingly requiring climate data as CSRD Scope 3 reporting obligations take effect.
What happens if your response is inadequate
- →EU and UK buyers may suspend or terminate supply relationships where ESG questionnaire responses are inadequate or unverified
- →From July 2029, CSDDD requires EU buyers to take action on identified supply chain risks — including supplier remediation or termination
- →The EU Forced Labour Regulation (from 2027) can bar goods from the EU market if produced with forced labour — affecting the entire export relationship
- →SECP-listed Pakistani buyers face domestic enforcement for inadequate sustainability disclosures, creating pressure on their own supply chains
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received an ESG questionnaire from your buyer?
ESG Stress Free helps Pakistani suppliers — especially in textiles and manufacturing — respond to buyer ESG requirements.