Pakistan’s labour-law framework changed substantially after the Eighteenth Amendment devolved labour to the provinces. Employers, workers and trade unions must now identify the law applicable to the relevant establishment, workplace and employment relationship rather than assume that one statute governs every matter across Pakistan.
This article reviews the existing industrial-relations framework and the Punjab Labour Code 2026, Act IX of 2026. It is a general overview as at 27 August 2026 and is not a substitute for advice on a particular employment relationship or dispute.
Federal and provincial industrial-relations framework
The principal industrial-relations enactments include the Sindh Industrial Relations Act 2013, Punjab Industrial Relations Act 2010, Khyber Pakhtunkhwa Industrial Relations Act 2010 and Balochistan Industrial Relations Act 2010. At federal level, the Industrial Relations Act 2012 applies to trans-provincial establishments and industries within federal jurisdiction. These laws address trade-union registration, collective bargaining agents, unfair labour practices, industrial disputes, strikes, lock-outs and the jurisdiction of labour adjudicatory bodies.
Punjab Labour Code 2026: enactment and commencement
The Provincial Assembly of the Punjab passed the measure on 4 February 2026. It received the Governor’s assent and was published in the Punjab Gazette (Extraordinary) on 10 February 2026 as Act IX of 2026. The Code is designed to consolidate and rationalise more than two dozen Punjab labour enactments covering employment, wages, working time, industrial relations, occupational safety and health, labour welfare and dispute resolution.
Enactment is not the same as commencement. Section 1(3) provides that the Code shall come into force on a date specified by the Government through a notification in the official Gazette. Before treating any provision—or the repeals and savings in section 435—as operative, employers and workers should verify the applicable commencement notification and any supporting rules. Existing laws and pending proceedings must be assessed with the transitional provisions in view.
Important changes contained in the Code
- Broad coverage: the Code is framed to apply across workplaces and sectors in Punjab, subject to stated exclusions including civil servants regulated by the Punjab Civil Servants Act 1974, defence services and police or other specified law-enforcement services.
- Worker status and misclassification: sections 132 and 133 establish tests for determining an employment relationship and address deliberate classification of an employee as an independent contractor or self-employed person.
- Employment agreements: agreements may be permanent or fixed-term and full-time or part-time. An agreement exceeding one month is generally required to be written, provided to the employee before work begins and to record the essential terms identified in the Code.
- Fixed-term work: fixed-term arrangements require objective justification and are subject to limits on their purpose, duration and successive renewal. Work of a permanent nature cannot simply be labelled fixed-term.
- Working time: the general ceiling is eight hours per day and forty-eight hours per week, subject to the Code’s detailed exceptions, overtime, rest and sector-specific provisions.
- Fundamental protections: the Code addresses forced and bonded labour, child labour, equality and non-discrimination, occupational safety and health, freedom of association and collective bargaining.
- New forms of work: dedicated provisions address domestic workers, home-based workers, agricultural workers, road-transport workers and digital-platform workers.
Practical preparation for employers
- Map every workplace, establishment and category of worker, including contractors, platform workers and workers supplied through agencies.
- Review appointment letters, employment agreements, fixed-term arrangements, disciplinary procedures, termination practices and internal work regulations.
- Audit wage, payroll, working-time, leave, social-security and record-keeping processes against the law applicable before and after commencement.
- Review occupational-safety systems, risk assessments, reporting lines and responsibility assigned to employers, principals and occupiers.
- Track Gazette notifications, final rules and transitional directions; do not rely solely on press reports describing the Code as “notified.”
Considerations for workers and trade unions
Workers and unions should retain employment records, wage statements, notices and correspondence; identify the correct employer and establishment; observe statutory grievance and limitation procedures; and obtain advice before commencing industrial action or proceedings. The appropriate Labour Court, Tribunal, the National Industrial Relations Commission or constitutional forum depends on the governing statute, territorial facts and nature of the dispute.
How Legum Law Firm can assist
Legum Law Firm’s employment and labour practice advises employers, employees and trade unions on workplace policies, employment contracts, restructuring, disciplinary and termination matters, collective bargaining, industrial disputes, regulatory compliance and representation before labour forums. Advice should be tailored to the facts, governing province, commencement status and any applicable notification or rule.