In early 2024, the provincial governments of Punjab and Sindh in Pakistan unveiled the draft Labour Codes that seek to repeal 25 existing labour laws and replace them with unified, “modernised” codes. The exercise of codifying labour laws began in 2022 and 2023, supported by the International Labour Organisation (ILO).

These draft Labour Codes represent a serious attack on workers’ rights. The government has promoted the simplified labour codes as a means to attract greater investment to the provinces, framing them as part of its broader “ease of doing business” agenda. This framing exposes the underlying intent: to make labour cheaper, more flexible, and easily disposable in the service of commercial gain. The new codes, by favouring business interest over worker rights, institutionalise a model of development rooted in labour exploitation rather than equitable and sustainable progress.

In this article, I will offer a critical examination of the proposed codes, drawing on consultations and analyses conducted with trade union federations, legal experts, and grassroots labour organisations. The findings reflect a disturbing pattern: the Codes erode long-standing legal protections, weaken trade unionism, exclude informal workers, and align disturbingly with neoliberal economic policies promoted by international financial institutions (IFIs).

In effect, they shift the paradigm of labour relations in Pakistan away from social justice and human rights and toward corporate flexibility and state control. It has rightly triggered widespread resistance from trade unions, labour rights advocates, and civil society.

Who Would Be Affected?

One of the most alarming features of the draft codes is the proposal to repeal foundational labour laws without offering any equivalent or improved protections. For instance, the repeal of the Workmen’s Compensation Act of 1923 and the Factories Act of 1934 would eliminate crucial safeguards for workers in case of workplace injuries, accidents, and occupational hazards. These laws have historically ensured some level of employer accountability and worker protection, and their removal represents a clear violation of international obligations under ILO Convention C121 on employment injury benefits and Convention C155 on occupational safety and health.

Similarly, the codes dismantle legal protections against child labour. Laws such as the Children (Pledging of Labour) Act, 1933 and provincial legislation like the Punjab Prohibition of Child Labour at Brick Kilns Act 2016 are being nullified, which could open the floodgates for renewed child exploitation, especially in the informal and unregulated sectors. These repeals directly contradict Pakistan’s commitments to the United Nations Convention on the Rights of the Child and relevant ILO conventions on child labour.

Women workers stand to lose significantly. The repeal of the Punjab Maternity Benefit Ordinance 1958 puts critical health and social protections at risk, leaving women vulnerable during pregnancy, childbirth, and maternity leave. Twelve weeks of maternity protection provided under the 1958 Maternity Ordinance have been halved to just 6 weeks under the draft labour codes. 

Beyond the repeal of specific laws, the draft Labour Codes actively seek to entrench exploitative systems of employment. It paves the way for regularising the contract labour regime, which would effectively facilitate the conversion of permanent, stable jobs into precarious, informalised work. Unions have struggled to unionise contract workers in Pakistan as they are vulnerable to sudden termination.

Even more disturbing is the legitimisation of bonded labour through the reintroduction of the advance payments (Peshgi system) — a form of advance payment that often traps workers in cycles of debt and dependency. Under the system, workers are expected to repay their advance payment. Employers effectively control the time and labour of all those who have received the advance payment. Now limited to the brick kiln and agricultural sectors and criminalised, the reintroduction effectively regularises it. It contradicts Pakistan’s own Bonded Labour System (Abolition) Act of 1992, along with ILO Convention C105 on the abolition of forced labour. Legalising such practices signals a dangerous retreat from hard-won battles against systemic labour exploitation.

The draft codes also represent an aggressive attempt to undermine trade unions and collective action. If adopted, the draft codes would dilute the mechanisms for recognising Collective Bargaining Agents (CBAs), with no explicit protections against employer interference in union elections. Under current laws, workers performing core tasks of an enterprise typically must be recognised as permanent employees, but the draft Law Codes would eliminate this requirement, enabling indefinite temporary status. Unions warn that this would severely weaken collective bargaining, as temporary workers are easier to hire and fire, thereby undermining union strength and enabling contractors who often restrict or ban union activities—a direct violation of constitutional protections (Article 17) and ILO Conventions 87 and 98.

Additionally, the Codes transfer dispute resolution from independent labour courts to government-controlled bodies dominated by bureaucrats, raising fears of biased and anti-worker decisions, thereby compromising labour justice and union autonomy. Instead of empowering industrial relations mechanisms, the codes centralise authority in the Labour Department, granting sweeping powers to government officers. The Labor departments seldom support trade unions. Unions fear that this bureaucratic overreach will threaten the independence of labour tribunals and reduce the space for impartial adjudication of disputes.

Organisations like the Home-Based Women Workers Federation (HBWWF) have questioned the intent of the codes as they fail to provide any form of protection to Pakistan’s vast informal workforce. Home-based workers, agricultural labourers, domestic workers, and others in the informal sector, which comprise almost 80% of the workforce, are outside the purview of the new labour codes. Unions have strongly demanded their inclusion. This exclusion continues the cycle of vulnerability faced by informal workers in Pakistan. 

A Neoliberal Labour Law

The codes reflect a neoliberal worldview that sees labour as a commodity to be “managed” rather than as human beings entitled to dignity, security, and rights. By prioritising the “ease of doing business” over the welfare of workers, the draft codes mirror global trends promoted by international financial institutions, which impose deregulation and labour flexibility in the name of economic competitiveness.

Throughout this drafting process, the Governments of Punjab and Sindh provinces, particularly through their Labour Departments, have breached both ILO Convention 144 and Recommendation 152 by failing to uphold transparency and genuine tripartite consultation.

Moreover, the dismissive and condescending attitude of the Labour Department and local consultants towards legitimate objections from the labour movement demonstrates a lack of good faith, disrespect for workers, and disregard for legal obligations.

However, the involvement of the ILO in facilitating these drafts is particularly troubling. Regrettably, the rather than safeguarding its foundational principles of inclusive consultation, ILO appears to have facilitated these violations.

A Struggle for Dignity and Democracy

The response from the labour movement has been swift and forceful. In both Punjab and Sindh, labour alliances have mobilised against what they rightly term “Charters of Slavery.” Trade unions, including the National Trade Union Federation (NTUF) and the Home-Based Women Workers Federation (HBWWF), have held large-scale conferences and demonstrations to denounce the draft codes and demand their immediate withdrawal.

The Punjab Labour Alliance, a coalition of national federations, has proposed alternative frameworks focused on ensuring a living wage, abolishing the contract labour system, expanding social protection, and legally recognising informal workers. These demands are not only legitimate but essential to building a fair and inclusive labour system. For now, the unions’ mobilisation has only got promises from the governments in both provinces. However, nothing concrete has actually been achieved. The governments are going ahead with their plans to pass these laws through the provincial assemblies in both provinces.

To move forward, a radical rethinking of the Labour Codes is required — one that centres the voices and experiences of workers themselves. Any reform process must begin with broad-based, meaningful consultations with trade unions, women’s groups, informal worker collectives, and other labour rights organisations. Instead of gutting existing protections, the state must expand them to cover those currently excluded. Labour legislation should be anchored in principles of human rights, social justice, and economic democracy — not in the imperatives of global capital.

The Punjab and Sindh Draft Labour Codes of 2024 constitute an unprecedented assault on the rights of workers in Pakistan. Their sweeping repeals, regressive provisions, and exclusionary logic undermine decades of struggle by the working class for dignity, security, and justice. These codes must be withdrawn in their current form. Any future labour reform must be democratic, transparent, and driven by those whose lives and livelihoods are at stake — the workers of Pakistan. The fight for just, humane, and equitable labour laws is not just a legal battle; it is a struggle for the soul of Pakistan’s democracy.