Public office & public accountability—I The declarations we must compare

Pakistan now has a digital filing deadline for senior civil servants. Parliament must ensure that declarations are compared, verified and acted upon

Pakistan is preparing to collect another set of asset declarations. The question citizens should ask is what will happen after the forms arrive. A declaration can expose an unexplained fortune, identify a conflict of interest or clear an honest officer of suspicion. It can also spend its entire life in an electronic cupboard.

The Establishment Division’s memorandum of September 16, 2026 requires civil servants in Basic Pay Scale (BS) 17 and above to submit their declarations for financial year 2025-26 through the Federal Board of Revenue (FBR) portal by October 30, 2026. Authorised corrections may be made until November 30, 2026. The memorandum provides for verification through risk-based checks and publication of selected, non-sensitive sections. These are concrete obligations against which performance can be measured.

Nearly ten years ago, in Parliamentary accountability, published on December 4, 2016, we proposed a joint parliamentary committee empowered by law to compare the declarations of elected representatives and state functionaries with their tax records. The central problem was institutional fragmentation. Different offices possessed different accounts of the same person’s financial affairs, without an effective, accountable process for reconciling them.

That proposal deserves revival under the current legal framework. The Elections Act, 2017 replaced the Representation of the People Act, 1976 and the Senate (Election) Act, 1975. Its sections 137 and 138 govern annual legislative asset statements and their publication. The task now is to connect these electoral obligations with tax and service declarations through a permanent verification system.

The civil-service framework has also changed. Section 15-A, inserted by the Civil Servants (Amendment) Act, 2025, requires digital filing and public availability through FBR of declarations covering senior civil servants, their spouses and dependent children, including domestic and foreign assets and liabilities. The provision recognises privacy and security. It creates a positive disclosure obligation rather than leaving publication entirely to administrative generosity.

The Civil Servants (Conduct) Rules, 2026 repealed the Government Servants (Conduct) Rules, 1964. Rule 12 establishes the declaration and verification arrangements, while rule 13 deals with conflicts of interest. This is a meaningful advance. Its value will depend on whether officials must explain material inconsistencies and whether decisions to pursue or close them can withstand scrutiny.

Our constitutional political economy explains why that final step is difficult. Those who decide how far an inquiry may proceed often work within the same hierarchy as those whose financial affairs require examination.

Digitisation can improve the record without changing the incentives governing its use. A portal will faithfully reproduce selective accountability if the selection remains controlled by political convenience or institutional solidarity.

Parliament should legislate for a common system of financial disclosure, supported by professional verification and public reporting. The law should identify covered offices expressly, including elected representatives, ministers and other public officeholders, civil servants and the appropriate categories of judicial and military office. Constitutional safeguards and jurisdictional differences must shape the enforcement route. They should not become a reason to abandon comparable standards of financial integrity.

A joint parliamentary committee should supervise the system, supported by a permanent verification office staffed through open, merit-based appointments. Its members must disclose their own interests and withdraw from matters involving themselves, their families or financial associates.

Officials should be selected for detailed examination through published criteria and a random component. A minister’s opponent should not become a higher risk merely because he is an opponent.

FBR should be required to transmit the relevant filed returns, wealth statements and reconciliations through a secure statutory channel. Election and service authorities should supply their corresponding records.

The committee’s verification staff could then identify omissions, inconsistent ownership claims and unexplained changes. The relevant individual must receive the proposed finding and a fair opportunity to supply records and explanations before adverse conclusions are reached.

Comparison requires care. An asset recorded at acquisition cost in one statement may appear at a different value in another. A spouse may own property independently. A loan can finance an acquisition without representing income. These differences need analysis. Treating every mismatch as corruption would punish carelessness and lawful transactions alongside concealment, destroying the credibility of the exercise.

Where evidence indicates a possible offence, the record should go to the authority legally competent to investigate it. The committee should monitor the response and publish institutional performance. It should have no power to pronounce guilt, manufacture jurisdiction or direct a court to convict. Tax recovery, electoral consequences, disciplinary action and criminal prosecution each require their own legal foundation.

The public must receive enough information to assess financial interests and changes in wealth. Bank account numbers, identity numbers and precise residential details can be protected. Redaction becomes objectionable when it removes the ownership, financial value or interest that disclosure is supposed to reveal. Parliament should prescribe a meaningful public minimum and require reasons for any additional restriction.

The tension is visible in the bill passed by the National Assembly on January 21, 2026 to permit withholding publication of a legislator’s statement on security grounds. The Senate’s legislative register records its transmission but does not record Senate passage or presidential assent in that entry.

The proposal remains troubling because an entire statement could disappear from public view where limited redactions could address the actual danger. Parliament should preserve public access while addressing any demonstrable security risk.

Public accountability cannot depend on which class of officeholder has the better argument for secrecy. Nor should Pakistan require an external lender to discover a principle already contained in Article 19A of its Constitution. Citizens finance public authority and are entitled to information of public importance, subject to lawful, reasonable restrictions.

The coming filing deadline provides an immediate opportunity. Parliament should require publication of the number expected to file, the number filing on time, the verification criteria and the timetable for reporting results. It should ask what information the public will actually see. It should then move from monitoring this civil-service exercise to legislating the wider system proposed by us in 2016.

An honest declaration also protects its maker. A permanent, verified record can answer a politically motivated allegation long after an officer has been transferred or a government has changed. That protection becomes credible only when the same standard applies to the governing party and its opponents.

Citizens should see the process continuing through a change of administration, with pending matters preserved and resolved on their merits. The recurring practice of announcing a fresh accountability drive would then give way to an ordinary public duty, performed throughout the year and capable of being checked against a record.

Pakistan has spent years collecting declarations while arguing about accountability. The next test is whether an unexplained difference between two official records produces an explanation, a lawful finding and an outcome that citizens can examine.

[To be Continued]

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Huzaima Bukhari, lawyer and author, has been Adjunct Faculty at Lahore University of Management Sciences (LUMS), member Advisory Board and Senior Visiting Fellow of Pakistan Institute of Development Economics (PIDE). She also served Civil Services of Pakistan from 1984 to 2003.

Dr. Ikramul Haq, Advocate Supreme Court, Adjunct Faculty at Lahore University of Management Sciences (LUMS), member Advisory Board and Visiting Senior Fellow of Pakistan Institute of Development Economics (PIDE), holds an LLD in tax laws. He was full-time journalist from 1979 to 1984 with Viewpoint and Dawn. He also served Civil Services of Pakistan from 1984 to 1996.