The First Counsel

Client Alert

PECA takedown procedure: the current mechanics

The 2025 amendment moved online blocking and removal powers from the PTA to a new authority — here is the current path of a takedown order, and the appeal that follows it.


16 June 2026 · 3 min read · The First Counsel

Draft — for lawyer review before publication

The power to block or remove online content in Pakistan sat for nearly a decade with the Pakistan Telecommunication Authority under section 37 of the Prevention of Electronic Crimes Act 2016 and the Removal and Blocking of Unlawful Online Content (Procedure, Oversight and Safeguards) Rules 2021. The Prevention of Electronic Crimes (Amendment) Act 2025 rebuilt that machinery. This alert states the position as of mid-June 2026.

What changed

The 2025 amendment created a new regulator — the Social Media Protection and Regulatory Authority — and vested the blocking and removal power in it, along with a complaints body and dedicated tribunals [the Authority's constitution and the current status of appointments — TO BE VERIFIED BY REVIEWING LAWYER]. The amendment widened the categories of unlawful content, added an offence of disseminating information known or believed to be false with intent to cause fear or unrest, punishable with imprisonment and fine [section number and penalties — TO BE VERIFIED BY REVIEWING LAWYER], and required social media platforms to enrol with the Authority as a condition of operating [enrolment mechanics — TO BE VERIFIED BY REVIEWING LAWYER].

The investigative side changed too. The FIA's cybercrime wing was replaced by the National Cyber Crime Investigation Agency, which now handles PECA offences [transition and current status — TO BE VERIFIED BY REVIEWING LAWYER].

The appellate route is new. Orders travel to a Social Media Protection Tribunal, and from the tribunal an appeal lies to the Supreme Court within sixty days [route and limitation periods — TO BE VERIFIED BY REVIEWING LAWYER]. Constitutional challenges to the amendment are pending before the High Courts, and the operational state of the new bodies has developed in stages since enactment [current status of the challenges and of the Authority's rules — TO BE VERIFIED BY REVIEWING LAWYER].

What it means

For businesses, the takedown regime runs in two directions, and both changed.

As a complainant — the company facing an impersonation page, a fraudulent investment scheme trading on its name, leaked internal data, or a coordinated defamation campaign — the route is a complaint to the new Authority seeking a removal or blocking direction. The practical questions are the old ones: identifying the content precisely, evidencing why it falls within a statutory category, and moving quickly, because harmful content replicates faster than any regulator acts. Parallel remedies remain available and are often faster in combination — the platforms' own reporting channels, civil defamation proceedings, and in Punjab the Defamation Act 2024 with its tribunal timelines [interaction — TO BE VERIFIED BY REVIEWING LAWYER].

As a respondent — the company or executive whose post, advertisement, or statement is targeted — the exposure is broader than before. The widened content categories and the false-information offence mean a takedown complaint can arrive attached to a criminal dimension, investigated by the new agency. An order against content is appealable, but limitation is short and the record you can appeal on is the record you built when the notice first arrived.

The unsettled constitutional position cuts both ways. Orders made under the amended Act are being complied with while the challenges proceed; no one should assume the regime away, and no one should assume its final shape either.

What this means for you

Decide now who inside the company owns this risk — takedown notices, platform enrolment questions, and content complaints move on short clocks and are routinely missed in shared inboxes. If your business faces impersonation or fraud content, prepare a standing evidence pack: URLs, preserved captures with timestamps, and the corporate authorizations needed to complain, so a filing can go out in hours rather than weeks. Pursue platform reporting channels and the statutory route in parallel rather than in sequence. If you receive a notice or an order against your own content, calendar the appeal limitation on the day it arrives, preserve everything, and take advice before responding — a response drafted for a regulator can be read later by an investigator. Media, marketing, and social teams should have the widened content categories explained to them in plain terms, because the line between aggressive commentary and a statutory offence is now drawn by a new authority whose practice is still forming. And have counsel recheck the state of the constitutional challenges before relying on any settled view of this regime — as of mid-2026, it is moving.

This publication is provided for general information only. It is not legal advice, and neither reading it nor corresponding with the firm about it creates a lawyer–client relationship. The position stated must be verified against current law before it is relied upon.

The position stated is as of 16 June 2026 and must be verified against current law.

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