Demanding Accountability: The Case for a Performance Audit of Pakistan’s NGO Sector

For twenty years, foreign and public money has flowed through Pakistan’s NGO sector in the name of two hundred and sixty million citizens, and for twenty years, almost none of it has been checked for what it actually achieved. Financial audits confirm that a receipt matches a ledger line. Not one of them tells us whether a promised outcome was real. This is not a call to shut down civil society. It is a demand that the state finally do the one thing it has never done: verify results, not just paperwork.

Consider what is now a matter of public record, not allegation. A single consortium, led by the Sustainable Development Policy Institute (SDPI), has been awarded more than two billion rupees in government survey contracts since 2019 — a door-to-door household survey for Central Punjab. The same organisation’s Executive Director simultaneously chairs the Board of Directors of the National Disaster Risk Management Fund (NDRMF), a government-owned entity that channels international climate and disaster financing into the country. None of this required digging through leaked documents. It sits in signed contracts, procurement evaluation reports, and a government fund’s own website, available to anyone with the patience to assemble it.

I want to be precise about what this case does and does not show. It does not show wrongdoing. Competitive bidding produces repeat winners because expertise is not evenly distributed, and a person can hold two legitimate roles honestly for an entire career. What it shows, irrefutably, is the size of the gap. Two billion rupees of public money, tied to an organisation whose leadership also sits on the board of the very kind of fund it might one day seek financing through, and at no point in that structure does Pakistani law require a conflict-of-interest disclosure, an independent review, or a published performance audit. The payment schedule on these contracts releases money against submitted data — an inception report, a mobilisation report, household forms received at each milestone — never against independent verification that the underlying survey work was accurate. The Auditor General of Pakistan, whose entire purpose is to ask hard questions of public money, has never systematically turned that scrutiny on this sector at all.

This institutional vacuum makes recent developments all the more telling. When a major social registry survey was exposed as an unmitigated debacle, even the Government of Punjab distanced itself from the compromised data, despite having already disbursed flood relief based on those very metrics. Amidst this fallout, Chief Minister Maryam Nawaz deserves recognition for refusing to sweep the matter under the rug.

However, the true architect of accountability in this saga was the Secretary of the Benazir Income Support Program (BISP), Amer Ali Ahmad. Displaying monumental bureaucratic courage in the face of immense, high-level pressure, Ahmad fiercely initiated a rigorous counter-check of the operation. He uncovered a shocking reality: after just a single month, SDPI had completely abandoned the field, retreating to their offices to fabricate an entire “desk-bound” survey. Instead of gathering empirical, independent data, they merely co-opted lists provided by local politicians and village councilors—cynically manipulating the social registry to register their own voters as “deserving” beneficiaries to engineer upcoming election victories. This cold, calculated white-collar crime—using the poorest of the poor as pawns for political engineering—is an unprecedented level of corruption rarely witnessed anywhere else on this globe. Yet, Ahmad stood firm, intercepted this gross malpractice, and directed SDPI to refund 2.5 billion rupees of public money. This is a rare, shining template of public service, proving that incorruptible bureaucrats remain the thin line protecting this state from fiscal ruin. For his unwavering commitment and integrity, Amer Ali Ahmad has earned the nation’s highest esteem—proving that true patriotism is defined not by rhetoric, but by the relentless defense of the public exchequer.

This is what a performance audit exists to resolve, and its absence is what should trouble every citizen, regardless of which organisation or individual happens to illustrate the point today. A financial audit asks whether the money was recorded correctly. A performance audit asks whether the five million households counted in a survey were the five million households that actually exist, whether the poverty scores generated reflect real lives, whether the climate adaptation project claiming to have restored an ecosystem actually restored one, measured in hectares and tonnes of carbon rather than in seminar photographs. Pakistan has never systematically asked that second question of its NGO sector, in any donor-funded climate, disaster-risk, or social-registry programme, in twenty years.

Other countries in this region did not accept that gap. India’s Comptroller and Auditor General can and does audit non-government organisations handling public or foreign funds for performance, not merely for bookkeeping, with findings that go before Parliament. Bangladesh’s NGO Affairs Bureau, working with its own CAG, applies value-for-money audits aligned with international public-audit standards and publishes what it finds. Pakistan has built neither mechanism. An NGO’s annual audit here confirms an accountant matched a receipt to a ledger. It says nothing about whether a single life improved, a single watershed was protected, a single rupee of climate finance reduced a single ton of emissions.

The demand that follows from this is simple and specific, and it does not require accusing anyone of a crime to be justified. The Auditor General of Pakistan should conduct genuine, independent, performance-based audits of NGO spending on climate, disaster-risk, and social-registry projects, going back at least to 2015 — measuring outcomes against claims, not receipts against ledgers. The Economic Affairs Division, which approves every foreign-funding MOU before a rupee enters the country, should require a conflict-of-interest declaration from any organisation whose leadership simultaneously holds a position on a government-owned fund’s board, disclosed publicly before any contract is awarded, not buried in an internal file. NDRMF, and every fund like it, should publish a conflict-of-interest policy governing board members who lead organisations eligible to compete for the same category of financing they help oversee. And donors themselves — the governments and multilateral funds writing these cheques — should be required to publish real-time, dollar-by-dollar tracking of where the money goes inside the country, because accountability cannot be a demand made only of the country receiving the funds.

None of this punishes an honest organisation. A genuinely effective NGO has nothing to fear from a performance audit; it has a case study waiting to be proven. What an audit regime does is remove the permanent, low-grade doubt that currently attaches to the entire sector, honest and dishonest alike, because no mechanism exists to tell them apart. Twenty years in, Pakistan still cannot say with evidence which of its NGOs delivered and which merely reported. That is not a reason to attack the sector. It is the precise reason to finally measure it.

Two hundred and sixty million people have had their name borrowed for two decades of funding they will likely never trace, and one confirmed, two-billion-rupee case now sitting in the public record shows exactly why “we filed the receipts” can no longer pass for accountability. The very least owed to them is an honest count, at last, of what that money actually built.