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Pakistan PDP Bill vs EU GDPR
Personal Data Protection Bill (Ministry of IT & Telecommunication draft, 2023 version) (Pakistan) compared with Regulation (EU) 2016/679 (General Data Protection Regulation) (European Union (EEA)) on the same topics. Every value comes from the law pages, which link to the official sources.
| Topic | Pakistan PDP Bill Pakistan 10/14 facts confirmed by two sources | EU GDPR European Union (EEA) ✓ Confirmed by two sources |
|---|---|---|
| Status | Bill — not yet law. As of Aug 2026 Pakistan has no comprehensive data protection law; the 2023 draft has not passed Parliament.✓ | In force since 25 May 2018. Digital Omnibus amendments proposed Nov 2025, not adopted as of Oct 2026.✓ |
| Who it applies to | Proposed: controllers and processors handling personal data in Pakistan; final scope may change on enactment.✓ | Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.✓ |
| Size thresholds | Not applicable until enacted.✓ | None — applies regardless of size. Limited record-keeping relief for organisations under 250 staff (Art 30(5)), lost if processing is risky, not occasional, or includes special-category or criminal data.✓ |
| Regulator | None yet. The bill proposes a National Commission for Personal Data Protection within six months of the law taking effect.✓ | National data protection authorities (DPAs), coordinated by the European Data Protection Board (EDPB)✓ |
| Breach or incident reporting | Proposed: notify the Commission and affected people without undue delay, within 72 hours where feasible (not in force).✓ | Notify the competent supervisory authority without undue delay and within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals (Art 33). If you have an EU main establishment, that is your lead authority; if you have no EU establishment (even with an EU representative), notify the authority of every member state where affected people live (EDPB Guidelines 9/2022, para 73). Tell affected individuals without undue delay if the risk is high (Art 34).✓ |
| Deadline to answer personal data requests | Being verified | 1 month from receipt; extendable by 2 further months for complex requests if the person is told within the first month. Free of charge unless manifestly unfounded or excessive.✓ |
| Data protection officer | Being verified | DPO mandatory for public bodies, and where core activities involve large-scale regular and systematic monitoring, or large-scale processing of special-category or criminal-offence data.✓ |
| Local representative | Being verified | Non-EU controllers/processors caught by Art 3(2) must appoint an EU representative in writing, unless processing is occasional, low-risk and excludes large-scale sensitive data, or they are a public body.✓ |
| Sending data abroad | Proposed (not in force): 'critical' personal data must be processed only on servers in Pakistan; other data may go abroad to countries with adequate protection, or with Commission-approved safeguards or explicit consent.✓ | Transfers outside the EEA need an adequacy decision (e.g. UK, Switzerland, EU-US Data Privacy Framework), or safeguards such as Standard Contractual Clauses or Binding Corporate Rules, or a narrow Art 49 derogation.✓ |
| Cookies and consent | Being verified | Cookie/tracker consent is governed by the ePrivacy Directive Art 5(3); where consent is the GDPR legal basis it must be freely given, specific, informed, unambiguous and as easy to withdraw as to give.✓ |
| Maximum penalty | Proposed (not law): May 2023 draft allows fines up to USD 2 million (or PKR equivalent) for unremedied contraventions, with lower caps for unlawful processing (USD 125,000; USD 500,000 for sensitive and USD 1 million for critical data).✓ | Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher (lower tier: EUR 10 million or 2%).✓ |
= confirmed by two independent sources, at least one official.
Facts marked “Being verified” are still being confirmed and are not given as answers.
Who each law applies to
- Pakistan PDP Bill
- Proposed: controllers and processors handling personal data in Pakistan; final scope may change on enactment.
- EU GDPR
- Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.
What you must do under Pakistan PDP Bill
- Treat the PDP Bill as pending; no statutory duties apply yet.
- Follow sectoral rules (SBP, PTA) and PECA in the meantime.
- Prepare a 72-hour breach response plan, which the draft would require.
- Map personal data flows now to speed up compliance when the law passes.
- Watch MoITT and Parliament for enactment and Commission set-up.
What you must do under EU GDPR
- Identify a lawful basis for every processing purpose and record it.
- Publish a clear privacy notice covering purposes, recipients, retention and rights.
- Keep a record of processing activities and sign Art 28 contracts with processors.
- Run a DPIA before high-risk processing such as large-scale profiling or sensitive data.
- Report qualifying breaches within 72 hours (lead authority, or every relevant DPA if you have no EU establishment) and log all breaches.
- Answer access, erasure and other rights requests within one month.
Information only, not legal advice. Laws change; confirm with the regulator or a qualified lawyer before relying on this page. Spotted an error? Email contact@