We, the undersigned, are concerned over the continued lack of transparency regarding the social media rules, originally Citizen Protection (Against Online Harms) Rules 2020 and recently retitled “Rules for removal and blocking of unlawful online content (procedure, oversight, and safeguards) Rules 2020”. The media has reported on the approval of the updated draft of rules from the Cabinet Committee for Disposal of Legislative Cases (CCLC) and ratification from the Cabinet. It is concerning that the updated rules are being kept confidential and secret, despite constant demands and requests from civil society to make them public and brings into question the sincerity of the consultative process.

We would like to remind the cabinet and the government that drafting of rules that stand to have a detrimental impact on the digital ecosystem, economy, and online expression is not a task that should be rushed through without paying attention to the inputs of all involved stakeholders. We are concerned that there has been no consultation on the revised draft, despite the fact that there were serious questions and concerns with the manner in which the consultative process was carried out. The lack of transparency is not only alarming, it projects the intention of the government to disregard the concerns of individuals that have time and again been raised and communicated to government departments and officials.

We remind the government that giving access to a revised draft after any initial consultative process is a legitimate expectation and an international best practice. We stress upon the urgent need for a truly credible, transparent, and inclusive consultative process and remind the government that the previous round of consultations was boycotted by a number of civil society organisations due to similar concerns on refusal to denotify the original rules before the process commenced.

It is also extremely alarming that there has been no formal and official response from the government on the letter by Asia Internet Coalition (AIC) that has expressed serious concerns over lack of meaningful consultation, sharing of the second draft before notification, and lack of response on requests for access. We fear that by not paying due attention to a body that comprises corporations that are fundamental to the progress of Pakistan’s economy, the government is actively endangering the nation’s progress and obstructing the growth potential of Pakistan as a digital market.

And given the unknown status of the first version of the Rules which should have been denotified by the Cabinet, the lack of transparency and expression of secrecy in democratic processes is not only worrying, it points towards the authorities’ intentional attempt to bar any kind of discourse in the lawmaking process which, in every democracy, is supposed to be transparent and must follow a multi-stakeholder consultation framework before any document becomes a regulation in the country.

Hence, the undersigned groups and individuals express their unequivocal opposition to the Rules in this form and demand immediate de-notification of the Citizen Protection (Against Online Harms) Rules 2020 and initiation of a sincere, efficient, and representative consultative process.


Organisations & Associations 

Media Matters for Democracy (MMfD)

Bolo Bhi

Digital Rights Foundation (DRF)

Pakistan Federal Union of Journalists (PFUJ)

Centre for Peace and Development Initiatives (CPDI)

Pakistan Press Foundation (PPF)

Institute for Research, Advocacy, and Development (IRADA)

Karachi Union of Journalists (KUJ)

Women in Media Alliance (WIMA)

Global Neighborhood for Media Innovation (GNMI)

Human Rights Commission of Pakistan (HRCP)

Journalist Defence Committee, Pakistan Bar Council (PBC)


Individual Signatories 

Abdullah Nizamani, Advocate

Adnan Rehmat, media analyst, and activist

Afia Salam, Journalist, and Activist

Aftab Alam, Advocate

Amber Rahim Shamsi, Senior Journalist

Arif Taj, Senior Journalist

Asmatullah Niazi, Senior Journalist

Ayesha Khalid, Journalist

Dr. Tauseef Ahmed Khan, Academic, Writer

Dr. Qaiser Bengali, Economist

Fahmidah Yousfi, Journalist/Blogger

Fauzia Kalsoom Rana, Former Joint Secretary, National Press club Islamabad

Fauzia Shahid, Senior Journalist

Husain Naqi, Senior Journalist and Analyst

I.A. Rehman, Human Rights Activist

Jamil Ahmed Khan, Senior Journalist

Mateen Haider, Journalist, Analyst

Matiullah Jan, Journalist

Mazhar Abbas, Senior Journalist, and Analyst

Mazhar Arif Society for Alternative Media and Research

Mehmal Sarfaraz, Journalist, and Analyst

Mehreen Zahra-Malik, Editor

Mian Tahir, Director News 24 News

Muhammad Haider Imtiaz, Advocate High Court

Muhamamd Ziauddin, Senior Journalist

Murtaza Solangi, Senior Journalist and Analyst

Naazir Mahmood, Senior Journalist

Najia Ashar, Journalist, Global Neighborhood for Media Innovation

Nasir Malick Former Secretary-General PFUJ

Owais Tohid, Senior Journalist

R Umaima Ahmed, Journalist

Ramsha Jahangir, Journalist

Salwa Rana, Media Matters for Democracy

Sarwar Bari, Human Rights Activist

Shafique Chaudhry, ED PCHR and former Commissioner, NCHR

Shumaila Shahani, Lawyer

Tanzeela Mazhar, Senior Journalist

Usama Khawar Ghumman, Advocate, President Indus Public Lawyers Front

Yasser Latif Hamdani, Advocate

Zaibunnisa Burki, Senior Journalist, The News