The First Counsel

Legislation · 2021

Online Content Rules under PECA (Removal & Blocking Rules lineage)


In force

Entry updated 11 June 2026

Subordinate rules under section 37 of PECA 2016 governing the removal and blocking of online content and imposing registration and compliance duties on social media companies.

What it is

Section 37 of the Prevention of Electronic Crimes Act, 2016 empowers the blocking and removal of "unlawful online content" on grounds that track Article 19 of the Constitution: the glory of Islam, the integrity, security or defence of Pakistan, public order, decency and morality, contempt of court, and offences under PECA itself. The operative procedure sits in subordinate rules with a contested lineage. The Citizens Protection (Against Online Harm) Rules, 2020 were approved in early 2020 and suspended after industry and civil-society objections. They were followed by the Removal and Blocking of Unlawful Online Content (Procedure, Oversight and Safeguards) Rules, 2020, which were in turn replaced — after the Islamabad High Court pressed for reconsideration — by rules of the same name notified in 2021. The 2021 Rules are the current instrument.

The 2021 Rules set out a complaint and direction procedure run through the Pakistan Telecommunication Authority. Social media companies above a user threshold [THRESHOLD, COMMONLY STATED AS 500,000 USERS IN PAKISTAN — TO BE VERIFIED BY REVIEWING LAWYER] must register with the PTA, appoint a compliance officer and a grievance officer, and establish a presence in Pakistan. Content must be removed or blocked within forty-eight hours of a direction, and faster in emergencies [TIMELINES — TO BE VERIFIED BY REVIEWING LAWYER]. Non-compliance can be met with blocking of the entire service, and the rules provide for review of directions and an appeal to the High Court.

What changed

The frame is shifting above the rules. The Prevention of Electronic Crimes (Amendment) Act, 2025 created the Social Media Protection and Regulatory Authority, designed to take over online content regulation from the PTA, with its own registration regime, complaint council and tribunals. Until that authority's regime is operational, the 2021 Rules remain the working procedure [HANDOVER STATUS AND ANY NEW RULES AS OF MID-2026 — TO BE VERIFIED BY REVIEWING LAWYER]. Enforcement history shows the powers are used at platform scale: X (Twitter) was blocked from February 2024 for over a year, with access restored in 2025 without a formal announcement [DATES — TO BE VERIFIED BY REVIEWING LAWYER], and Wikipedia was briefly blocked in 2023. Constitutional challenges to section 37 and to the rules have been litigated in the high courts, and network-level content-management infrastructure expanded through 2024–25 [STATUS OF CHALLENGES AND DEPLOYMENTS — TO BE VERIFIED BY REVIEWING LAWYER].

Who is affected

Social media platforms and hosting providers face registration, local-presence and takedown obligations. Internet service providers implement blocking directions. Businesses that depend on platform reach — e-commerce, digital media, advertising, creators — carry the commercial consequences of takedowns and platform-level blocks. Individual publishers whose content is removed hold the review and appeal rights, and foreign platforms weighing entry into Pakistan must price the compliance architecture before launch.

What to do

Platforms and digital businesses should designate a Pakistan point of contact now, build a documented takedown-response procedure that gets legal review inside the forty-eight-hour window, and keep a register of every direction received and the action taken — the record matters if a blocking dispute reaches the High Court. Publishers whose content is blocked should seek review promptly and preserve evidence of what was removed and when. Everyone in this space should track the new authority's rule-making under the 2025 amendment before building compliance around the 2021 procedure alone, because the successor regime will change the counterparty, and possibly the timelines.

The text of the instrument, where publicly available, may be obtained from official sources; a PDF will be linked here when the firm’s annotated copy is released. [PDF FORTHCOMING]

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.

Status as stated is as of 11 June 2026 and must be verified against current law.

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