1

Table of Contents
Acronyms.............................................................................................................. 3
Executive Summary ............................................................................................... 5
1. Introduction ...................................................................................................... 6
2. Populations of Interest ...................................................................................... 8
(a). Refugees ..................................................................................................................................... 8
(b). Asylum-seekers who are they? .................................................................................................. 8
(c). Stateless persons/persons at-risk of statelessness or those of undetermined nationality ........ 8

3. Assessment Process ........................................................................................... 8

4.Stakeholders .....................................................................................................13
(a). Entities responsible for conducting Civil Registration .............................................................. 13
(b). Entities responsible for Civil Registration law and policy ......................................................... 14
(c). Entities related to support of the vulnerable groups ............................................................... 15

5.Current systems and Practices of Civil Registration ............................................15

Legal framework ......................................................................................................... 15
(a). Civil Registration Legislation -Federal ...................................................................................... 16
(b) Civil Registration Laws - Provincial ............................................................................................ 17

Analysis on the Implementation of the Bali Process Toolkit in the three identified areas
.................................................................................................................................. 18
(a) . The Islamabad Capital Territory (ICT) ...................................................................................... 18
(b) . Peshawar District .................................................................................................................... 20
(c). Karachi Division ........................................................................................................................ 22

Curent practice for civil and functional registration of vulnerable groups ..................... 23
(a). Refugees ................................................................................................................................... 23
(b). Asylum-seekers ........................................................................................................................ 23
(c). Stateless persons, persons at-risk of statelessness and those of undetermined nationality ... 23

6. Gap analysis.....................................................................................................24
(a). Service provider issues ............................................................................................................. 24
(b). Beneficiary issues ..................................................................................................................... 24

7. Recommendations ...........................................................................................24

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Acronyms

Acronym Explanation

ACC Afghan Citizen Card

ANR Afghan National Registration

AJ&K Azad Jammu and Kashmir

ARC Alien Registration Card

Bali Process Bali Process on People Smuggling, Trafficking in Persons and

Related Transnational Crime

Bali Process Toolkit, or Bali Process Civil Registration Toolkit

Toolkit

CAF Commissionerate of Afghan Refugees

CCAF Chief Commissionerate of Afghan Refugees

CEDAW UN Convention on the Elimination of All Forms of Discrimination

Against Women

CNIC Computerized National Identity Card

CRC UN Convention on the Rights of the Child

CRMS Civil Registration Management System

CRVS Civil Registration and Vital Statistics

GB Gilgit-Baltistan

GDP Gross Domestic Product

GOP Government of Pakistan

ICCPR International Covenant on Civil and Political Rights

ICT Islamabad Capital Territory

ID Identification

IOM International Organization for Migration

MoI Ministry of Interior

MoLJ Ministry of Law and Justice

MoPDSI Ministry of Planning Development and Special Initiatives

SAFRON Ministry of States and Frontier Regions

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NADRA National Database and Registration Authority

NIC National Identity Card

PDHS Pakistan Demographic and Health Survey

PoR Card Proof of Registration Card

RSO Regional Support Office

SDGs Sustainable Development Goals

TSU-CRVS Technical Support Unit-Civil Registration and Vital Statistics

UDHR Universal Declaration on Human Rights

UN United Nations

UNCAT UN Convention Against Torture and Inhuman and Degrading

Treatment

UN ESCAP United Nations Economic and Social Commission for Asia and the
Pacific

UNFPA United Nations Population Fund

UNHCR United Nations High Commissioner for Refugees

UNICEF United Nations Children's Fund

WDI The World Bank’s World Development Indicators

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Executive Summary
Civil registration is the first right of a child and a person’s right to recognition as a person before
the law, as well as establishing their formal relationship with the State. This is stated in the
1990 Convention of the Rights of the Child that encourages all the signatory governments
including Pakistan to put in place appropriate legislative, administrative and other measures for
every child to be registered immediately after birth.

The Ministry of Planning, Development and Special Initiatives has developed the “National
Policy to Revamp and Reform Civil Registration of Vital Events and Ensuing Vital Statistics
System in Pakistan ” that ensures access to birth registration for all children born in the country,
and requested the Regional Support Office of the Bali Process on People Smuggling,
Trafficking in Persons and Related Transnational Crime and UNHCR Pakistan to provide
technical assistance to include vulnerable population groups i.e., refugees, asylum seekers,
stateless populations within national Civil Registration and Vital Statistics programs using the
Bali Process Civil Registration Assessment Toolkit.

This report provides the Government of Pakistan with practical recommendations to establish
inclusive civil registration systems based on the gaps in civil registration service providers and
beneficiaries identified by systematic desk review, key informant interviews, and focus group
discussions at the district and sub-district levels in the Islamabad Capital Territory, Peshawar
the capital of Khyber Pakhtunkhwa Province, and Karachi Division in Sindh Province.

During the assessment using the Bali Process Civil Registration Assessment Toolkit, it was
found that no laws and regulations on civil registration at the federal and local level distinguish
between Pakistani citizens and the vulnerable population groups including refugees, asylum
seekers, stateless persons and persons of undetermined nationality in terms of recording and
certification of their births, deaths, marriages and divorces. However, most of the vulnerable
population groups do not have required documents for these registrations. In addition, it was
noted that no procedures/guidelines were available for recording vital events in the vulnerable
population groups as well as no systematic training on civil registration for the local civil
registrars had been conducted in the Islamabad Capital Territory, Peshawar the capital of
Khyber Pakhtunkhwa Province, and Karachi Division in Sindh Province.

Based on the findings from the assessment, it is recommended to ensure civil registration for
all population groups regardless of their legal status by establishing appropriate legal provisions
for the inclusion of vulnerable population groups to access CRVS at the federal and provincial
levels. Capacity development support including standard operating procedures and trainings
specifically on inclusion of vulnerable population groups is also recommended in line with the
split of the National Policy to Revamp and Reform Civil Registration of Vital Events and
Ensuing Vital Statistics System in Pakistan.

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1. Introduction
Civil registration and vital statistics (CRVS) is the continuous, permanent, compulsory, and
universal recording of the occurrence and characteristics of vital events of the population. Civil
registration is the first right of a child and a person’s right to recognition as a person before the
law, as well as establishing their formal relationship with the State. It provides individuals with
documentary evidence to prove their legal identity and family relationships, which are
important for accessing essential services including healthcare, education and social
protection. Other rights and activities such as political participation, recourse to justice,
nationality, property ownership, formal employment, inheritance, and the use of financial
services are also ensured through the functioning of robust systems.

Civil registration for recording of vital events of a country's population has become an essential
ingredient of the international development agenda. Sustainable Development Goal (SDGs)
16.9 calls for the provision of a legal identity including birth registration for all by 2030. In
addition, Goal 17.18 states that, “…by 2020, enhance capacity-building support to developing
countries, including for least developed countries and small island developing states, to
increase significantly the availability of high-quality, timely and reliable data disaggregated
by income, gender, age, race, ethnicity, migratory status, disability, geographic location and
other characteristics relevant in national contexts'' which is the key to ensuring the core
principle of the 2030 Agenda “Leave no one behind”.

All Member States of the United Nations Economic and Social Commission for Asia and the
Pacific (ESCAP), including Pakistan, adopted a Ministerial Declaration aiming to strengthen
the universal civil registration for all people and endorsed a Regional Action Framework that
encourages States to evaluate inequalities in accessing civil registration for vulnerable
population groups and to set national targets to address them. Pakistan has also affirmed its
commitment to the 2030 Agenda for Sustainable Development by adopting the SDGs in its own
national development agenda (Vision 2025).

In accordance with the Regional Action Framework, the Ministry of Planning, Development
and Special Initiatives (MoPDSI) has developed the “National Policy to Revamp and Reform
Civil Registration of Vital Events and Ensuing Vital Statistics System in Pakistan1” that ensures
access to birth registration for all children born in the country. Further, the MoPDSI has
requested the Regional Support Office (RSO) of the Bali Process on People Smuggling,
Trafficking in Persons and Related Transnational Crime (Bali Process) and UNHCR Pakistan
to provide technical assistance to include vulnerable groups i.e., asylum seekers, refugees and
stateless persons within the national CRVS program using the Bali Process Civil Registration
Assessment Toolkit (Bali Process Toolkit) that was co-developed by the RSO and UNHCR.

The Bali Process Toolkit helps to generate three main outcomes:

 Assessment report: Comprehensive description of the findings and recommendations
of the assessment collectively endorsed by the body leading the assessment. This
should also be reviewed and approved by a higher authority that can take relevant
decisions for implementation.

1
https://www.pc.gov.pk/uploads/crvs/Draft.pdf
This policy is developed in line with with the 1990 Convention of the Rights of the Child
(CRC) and highlights the importance of appropriate legislative, administrative and other
measures for every child to be registered immediately after birth.

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  Action plan: A document that explains how the assessment recommendations will be
implemented, including what needs to be done, when, how and by whom, usually
within a timeframe of one to ten years.
 Targets: Targets, milestones or objectives towards which efforts can be directed for
measuring progress (or lack thereof), e.g. proportion of births, deaths and marriages
that are registered in a given timeframe or other targets of a qualitative nature, such as
undertaking a particular action (e.g. produce a manual or deliver a training) by a certain
date.

The scope of this assessment report covers the following vulnerable groups.

Vulnerable Groups
Refugees Afghan refugees holding Proof of 1,43 Million
Registration Cards (PoR Card holders)

UNHCR Mandate recognized Refugees 5,172

(Afghans and Non-Afghans)

Asylum Seekers (Afghans and Non-Afghans) 10,190

Stateless Bihari, Bengali and Rohingya 3.Million (approx..)

Population communities

In addition to the vulnerable groups mentioned above, Pakistan also hosts two other groups of
Afghans namely the Afghan Citizen Card(ACC) holders and the undocumented Afghans2. The
ACC holders were registered by National Database and Registration Authority(NADRA)
through a onetime registration exercise and are about 879,1983 individuals. The registration
exercise was closed without any recourse to modifications and additions in their database, thus
rendering this group unable to register their births, deaths and marriages. The exact number of
the undocumented Afghans is not known however it is estimated to be between 300-500,000
individuals. This group is believed to be completely void of any documentation and thus have
no recourse to any civil registration.

Although both these groups do not fall within the scope of this study nonetheless their
vulnerabilities in terms of lack of access to essential services can pose serious threats to their
safety and dignity thus warranting a careful consideration in the broader scheme of the CRVS.

2
ACC holders: Individual of Afghan origin individuals living in Pakistan registered by the
Government of Pakistan during the 2017-18 ACC documentation exercise. ACC holders are
required to return to Afghanistan and can only return to Pakistan after receiving a Pakistani
visa in an Afghan Passport.
Undocumented Afghans: Individual of Afghan origin who falls within undocumented
categories, including: 1) Individuals with no valid documents (POR, ACC, or visa), 2) Individuals
with Tazkira (Afghan ID card) which comes under undocumented category, 3) Individuals with
a Proof of Registration Card that has expired before 2015 and 4) Individuals with no passport
or with a passport with an expired or no visa.
3
Pakistan Migration Snapshot August 2019, International Organization of Migration (IOM),
pg.13, 1. Pakistan Migration Snapshot 2019.pdf (iom.int)

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2. Populations of Interest
The Bali Process Toolkit is designed to identify and address gaps and needs of the vulnerable
population groups i.e., refugees, asylum seekers, stateless persons, undetermined
nationalities in order to include them in the civil registration systems.

A mapping of the vulnerable population groups in Pakistan is described below as it relates to

access to both civil registration and functional registration.

(a). Refugees

(i). Afghan Refugees who are registered with the Government of Pakistan(GoP)
Approximately 1.43 million Afghan refugees are registered with the GoP and holding
Proof of Registration (PoR) Cards issued by the National Database and Registration
Authority (NADRA). The stay of PoR cardholders in the country is regulated by the
policy decisions of the Federal Cabinet implemented through the Ministry of States and
Frontiers Region (SAFRON) and its department, the Chief Commissionerate for
Afghan Refugees (CCAR).

(ii). Other Afghan and non-Afghan refugees who are recognized by UNHCR
These individuals are recognized as refugees under the mandate of UNHCR and
include not only Afghans but persons from other nationalities. UNHCR determines and
grants them refugee status. They are provided with UNHCR- issued refugee cards
which generally provide them protection against refoulement and allows a degree of
freedom of movement.

(b). Asylum-seekers

These individuals have been registered by UNHCR as Asylum-seekers under its mandate.
Asylum seekers are individuals who seek asylum and await their status to be determined. In the
context of Pakistan, as mentioned in the preceding para, their refugee status determination is
carried out by UNHCR under its mandate.

(c). Stateless persons/persons at-risk of statelessness or those of undetermined nationality

Pakistan hosts an undetermined number of stateless persons, those at-risk of statelessness or of

undetermined nationality is estimated to be a population of approximately 3.5 million
compromised of those from the ethnic Bihari, Bengali and Rohingya communities. The exact
number of the stateless populations is yet to be determined. Most of this population group reside
in Karachi and had migrated to Pakistan before the creation of Bangladesh in December 1971.
There are no formal figures to estimate the overall size of the population.

3. Assessment Process
Three sites were selected for the assessment process: the Islamabad Capital Territory (ICT),
Peshawar District in Khyber Pakhtunkhwa, and Karachi Division in Sindh (all the seven
districts). Each of these locations has a sizable population of each vulnerable group and can be
considered representative to generate practical recommendations for mainstreaming of these
groups into the national CRVS system.

There was not an existing body to coordinate civil registration for non-nationals including the
vulnerable groups at the national and sub-national level as such, MoPDSI and UNHCR jointly
established a Core Working Group (CWG) on Mainstreaming Vulnerable/Marginalized
Population in Civil Registration System. The table below shows the composition of the CWG.

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Members of the Core Working Group

Co-Chairs

Chief (Health), Ministry of Planning, Coordinating CRVS at national level and is heading
Development and Special Initiatives the TSU at the MoPD&SI. He is also proposed to
(MoPDSI), Islamabad co-chair the CWG.

Assistant Representative, UNHCR, Responsible for protection of refugees and other

Islamabad vulnerable groups at UNHCR Pakistan.

Federal Government

National Technical Advisor (TSU- Supporting Chief (Health), MoPD&SI, Islamabad

CRVS), MoPD&SI, Islamabad and covers technical aspects of implementation of
national CRVS programs.

Ministry of Interior, Islamabad (MOI) Ministry of Interior is dealing with: Nationality,

citizenship and naturalization; Entry and stay of
foreigners in Pakistan; regulation of movement in
Pakistan of persons not domiciled in Pakistan;
issuance of passports, visas.

National Database and Registration Responsible for issuance of national identity cards
Authority (NADRA), Islamabad to Pakistani nationals, POR cards to Afghan
Refugees, ACCs for Afghan Citizens, and Alien
Registration Cards. Maintains a National Database
of Civil Registration Management System (CRMS).

Ministry of States and Frontier Regions The Principal Ministry dealing with Afghans at the
(SAFRON), Islamabad Federal level.

Chief Commissioner for Afghan The chief administrative office under SAFRON and
Refugees (CCAR), Islamabad deals with management of Afghan refugees at the
Federal level and is supported by provincial
Commissionerate’s for Afghan refugees.

Ministry of Foreign Affairs, Islamabad Dealing with Pakistan’s foreign relations and of the
foreigners in and out of the country.

Pakistan Bureau of Statistics, Islamabad The main statistical agency of the federal and
provincial governments for generation of vital
statistics in Pakistan that conducts National Census
after every ten years and a number of other censuses
and surveys assigned by these governments.

Provincial Governments of Sindh and Khyber Pakhtunkhwa

Planning& Development Department, Coordinating department for mainstream CRVS in

Government of Sindh, Karachi Sindh province.

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 Planning& Development Department, Coordinating department for mainstream CRVS in
Government of Khyber Pakhtunkhwa, Khyber Pakhtunkhwa province.
Peshawar

Civil Society

Representative of International Rescue An INGO working in the poverty alleviation, natural

Committee, Islamabad disasters and disadvantaged population groups in
Pakistan.

United Nations Agencies and International Financial Institutions

UNICEF UN Agency dealing with children and their birth

registration. Currently executing a project titled
“Digital Birth Registration” (DBR) for universal
birth registration in five districts in Sindh and
Punjab in association with the provincial
governments of Sindh and Punjab for children under
18 in the following districts: Badin, Noshero Feroze,
Thatta, and urban districts of Karachi (Sindh); and
Bahawalpur, Dera Ghazi Khan, Muzaffargarh,
Pakpattan, Rahim Yar Khan, Rajanpur, and Lahore
(Punjab)4.

IOM Intergovernmental organization in the field of

migration and related issues, especially supporting
ACC holders.

UNFPA Leading UN agency in support of government

statistics.

The World Bank The largest donor to the Government of Pakistan and
financially supports national CRVS programs.

The assessment process consists of three phases:

 Phase I- Planning and preparation.

 Phase II- Collecting, analyzing and validating information; and
 Phase III- producing the main outputs including practical recommendations from the
assessment.

The table below shows the detailed activities jointly conducted by UNHCR and the MoPD&SI,
and approved by the CWG. The key limitations to conducting the assessment was due to
COVID-19 which restricted the number of field visits undertaken and the nature of interviews
conducted.

4
UNICEF, Status of Civil Registration and Vital Statistics in South Asia Countries, 2018, available at
https://www.google.com/search?q=UNICEF+crvs+project+in+sindh&oq=UNICEF+crvs+project+in+sind
h&aqs=chrome..69i57.23480j0j8&sourceid=chrome&ie=UTF-8

10
Phase I: Planning and preparation (March – April 2020)

Activity Tools

1. Organize the first Core Working Group meeting (MoPDSI and

UNHCR):

● Identify the members for Core Working Group (CWG).

● Develop information material, which includes work plan,
roles and responsibilities of the stakeholders who will be
involved with the assessment and areas for piloting the
assessment, timeframe, etc.

2. Conduct a preliminary desk research (UNHCR): Tool A1 Guidance for

internal desk review
● Collect existing data and materials.
● Undertake analysis of existing CRVS information on the  Profile of refugees,
vulnerable groups including refugees, asylum seekers, asylum seekers,
stateless persons, and persons of undetermined stateless persons
nationality. and persons of
● Map CRVS Stakeholders and existing functions in the undetermined
registration of vulnerable groups. nationality that
● Analyzing existing CRVS law and policy related to the reside in the
vulnerable groups. territory
 Stakeholder-
mapping
 Known gaps and
barriers
3. Develop a work plan for a pilot project implementation in
Islamabad, Karachi and Peshawar districts (UNHCR):

● Coordinate with federal and provincial authorities

including MoPDSI to set a practical time frame for the
implementation of the toolkit.
● Developing a work plan for each site to be approved by
the CWG.

Phase II: Collecting, analyzing, and validating information (July 2020 – April 2021)

Activity Tools

4. Conduct a gap analysis between the existing / proposed TOOL H: Questionnaire

registration mechanism for the vulnerable groups in each at ICT,  General issues
Peshawar, and Karachi (UNHCR):  Service provider
issues
● Conducting consultative meetings at Islamabad, Karachi  Beneficiary issues
and Peshawar in person with minimum number of  Relationship with
participants (as per prevailing social distancing functional and
guidelines) and/or telephonically. population
registration

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 ● Based on the collected information through the
consultative meetings, conduct a gap analysis between
the existing/proposed registration mechanism for the
vulnerable groups in each target site.

5. Conduct field visits and focus group discussions in Islamabad, Tool H: Questionnaire
Karachi and Peshawar districts to assess local-level practices on  General issues
CRVS (Under the restriction of the movement, only a field visit  Service provider
to Karachi was conducted) (UNHCR): issues
 Beneficiary issues
● Coordinate with federal and provincial authorities Relationship with
through the CWG to prepare a field visit and focus group functional and
discussions in the seven districts Karachi. population
● Conducting focus group discussions telephonically with registration
relevant actors in Islamabad and Peshawar.
Tool I: Guidance for
conducting field visits and
focus groups

6. Organize a workshop telephonically with relevant stakeholders Tool J: Example of agenda

to share preliminary findings (UNHCR): for the result workshop

● Reviewing and consolidating findings identified from

information collection activities (e.g. desk research, field
visits, focus group discussions)
● Prepare a draft report about the prevailing civil
registration assessment of the vulnerable groups in pilot
districts of Islamabad, Karachi South and Peshawar.
● Share the findings with relevant stakeholders to get
feedback which will be incorporated in the final report.
7. Organize the 2nd Core Working Group Meeting to present a Tool J: Example of agenda
draft assessment report (MoPDSI and UNHCR): for the result workshop

● Sharing with the CWG a draft report reflected

inputs/feedback received from stakeholders at the
workshop.
● Collecting inputs/feedback from the CWG for the
preparation of the final report

8. Organize the last Core Working Group Meeting to finalize the Tool J: Example of agenda
report on “mainstreaming the vulnerable groups in the national for the result workshop
CRVS system” (MoPDSI and UNHCR):

● Presenting the draft final report with an action plan,

targets and areas for actual implementation to the CWG
for the endorsement of the report

Phase III: Implementing the formulated action plan and recommendations from the assessment.

The Phase III will be implemented by MoPDSI in line with the action plan approved by the
CWG. This includes:

12
 ● Organize a dissemination meeting to share the findings and recommendations to a
wider group of stakeholders at the federal and provincial levels.
● Formulate operational guidelines / SoPs for the registration of the vulnerable groups
(based on the outcome of the assessment)
● Develop a capacity building plan focusing on knowledge gaps identified during the
assessment
● Organize technical trainings for local officials for promoting inclusion of the
vulnerable groups in the mainstreaming CRVS system
● Developing information material for promoting inclusion of the vulnerable groups in
the mainstreaming CRVS system
● Conducting media campaign and community sensitization

4.Stakeholders
(a). Entities responsible for conducting Civil Registration

(i). Ministry of Health Services Regulation and Coordination (MoNHSRC)

Responsible for the notification of births and deaths. At the provincial level this is
carried out by the relevant health departments. In case the birth occurred at home,
registered doctors midwives with the respective provincial governments issue a
birth notification.

(ii). The National Database & Registration Authority (NADRA)

NADRA is an autonomous organization established under the National Database and

Registration Authority Ordnance, 2000 hereinafter referred to as “NADRA Ordinance
2000”. NADRA is mandated “…to facilitate the registration of all persons and the
establishment of maintenance of multipurpose databases, data warehouses, networking,
interfacing of databases and related facilities”.5

(iii). Local Government Departments

The Department of Local Government registers the child to NADRA database at its
sub-district offices including union council offices based on the birth notification and
required documents including CNIC number of both parents. NADRA issues the birth
certificates. Following the creation of local governments with a view to devolve powers
at the grass roots level, the registration of births, deaths, marriages, and divorces were
entrusted to these institutions at the lowest tier of the government, functioning in their
local areas in the provinces. Each province enacted their separate though identical local
government acts specifying the roles and responsibilities for the local bodies including
the function of registration of births, deaths and marriages.

(iv). Pakistan Bureau of Statistics (PBS) + Provincial Bureaux

The PBS is a federal agency attached to the Ministry of Finance and provides services
in terms of collection and compilation of statistical data relating to various socio-
economic sectors through primary, secondary sources, and administrative records of
the government in line with the General Statistics (Reorganization) Act, 2011. The PBS
has 34 provincial/regional Offices in total across the country. It was created by merging
5
The National Database and Registration authority Ordinance (NADRA Ordinance), 2000

13
 the Federal Bureau of Statistics, the Population Census Organization, The Agriculture
Census Organization and the Technical wing of the Statistics Division in 1981.

(b). Entities responsible for Civil Registration law and policy

(i). Ministry of Planning Development and Special Initiatives (MoPDSI)

The Technical Support Unit (TSU), Ministry of Planning, Development and Special
Initiatives is a key actor to design and implement CRVS related policies. It leads
technical coordination for CRVS development and promotion at the national and sub-
national levels by the National Policy to Revamp and Reform Civil Registration of
Vital Events and Ensuing Vital Statistics System in Pakistan.

(ii). Ministry of Foreign Affairs (MoFA)

MoFA is responsible for Pakistan's diplomacy, bilateral, and multilateral

relations/affairs as well as for providing support for a country's citizens who are abroad
through Pakistani government offices abroad with diplomatic and consular status. In
addition, the MOFA deals with former nationals, diaspora as well as foreigners in
Pakistan in coordination with the MoI.

(iii). The Ministry of Law and Justice (MoL&J)

The MoL&J has an overarching role to examine draft legislative bills before
submission to the parliament. It also examines draft Cabinet orders and treaties that are
to be brought before Cabinet meetings. There are two types of legislative bills - those
introduced by the Cabinet (public bills), and those introduced by Parliamentarians
(Private members bills). With respect to legislative bills to be introduced by the
Cabinet, all bills drafted by the relevant ministries are examined by MoL&J before they
are brought before the Cabinet meetings. Cabinet orders are enacted by the Cabinet,
either on the basis of authorization by law or for the purpose of implementing law. All
draft orders are examined by the MoL&J before being brought before Cabinet
meetings.

Similarly, law departments in the provinces, the special areas of Gilgit-Baltistan and AJ&K are
responsible to examine draft laws introduced by sector departments before submission to the
provincial cabinet. Although the MoL&J’s role is limited to the vetting of the bills without the
authority to bring about substantial change, its role is important in highlighting the inter-play
between various law for the time being in force.

(iv). Ministry of Interior (MOI)

The MOI is primarily responsible for implementing the internal policies, state security,
administration of internal, and assisting the government on territorial affairs in close
coordination with the home department of the respective local governments. In
addition, the MOI is primarily responsible managing the affairs of foreigners in the
country and in this regard enjoys wide discretionary powers.

(v). UNICEF

UNICEF has an international mandate to uphold the rights of all children including
birth registration of children to ensure every child is protected, healthy and educated,
focusing on the children left behind by wider economic and social progress. It is the
lead agency of national project for Technical Assistance and ICT as CRVS Model

14
 District in Pakistan, which helps the government to develop a uniform, standardized
national CRVS system including Legislation, Protocols/Bylaws/SOPs, Inter-sectoral
coordination, infrastructure, etc. in line with the National Policy to Revamp and
Reform Civil Registration of Vital Events and Ensuing Vital Statistics System in
Pakistan.

(c). Entities related to support of the vulnerable groups

(i). Ministry of the States and Frontier Regions (SAFRON)

The Ministry of SAFRON has been mandated to look into the affairs of Afghans in
Pakistan-both refugees and non-refugees. It is headed by a Federal Minister. The
Ministry of SAFRON is administratively and operationally supported by the office of
the Chief Commissioner for Afghan Refugees (CCAR). The CCAR oversees the
refugee matters through provincial Commissioner Afghan Refugees (CARs) in
provinces.

(ii). United Nations High Commissioner for Refugees (UNHCR)

UNHCR was established pursuant to the United Nations General Assembly Resolution
428(V) of 14 December 1950 with the exclusive mandate to provide protection and
seek durable solutions to refugee situations. Over time UNHCR was also entrusted the
role for protecting stateless persons as striving for prevention, reduction and eradication
of statelessness. UNHCR’s mandate is humanitarian and non-political in its nature.

5.Current systems and Practices of Civil Registration

Legal framework

15
(a). Civil Registration Legislation -Federal

An analysis on the prevailing civil registration laws in Pakistan reveals that there exists not a
single law comprehensively dealing with the subject. There are several laws both at Federal and
Provincial level dealing with the same subject. Some of the legislations have evolved over time
into new enactments and authorities and thus were repealed. This report will examine only those
laws in vogue both at the Federal and Provincial levels. The inter-play between federal and
provincial laws could be, at times, not easily discernible. Following are the key legislations at
the Federal level dealing with the Civil Registration.

(i). NADRA Ordinance 2000

NADRA operates a centralized database of citizens with the family tree of each person
documented and often dating back for generations called the Civil Registration Management
System (CRMS). The citizen’s vital events are registered in the CRMS. The NADRA ordinance
also provides for certain registrations by this authority of some other classes of citizens and
non-citizens having an origin in Pakistan but currently living out of the country, and of the
foreigners currently residing in Pakistan, both legally and illegally 6 . NADRA although
autonomous is guided by the directives from the MOI. NADRA issues the following
documentation:7

a) National Identity Card: National Identity Card (NIC) is issued to the citizens of Pakistan.
The unique 13-digit identification number is recognized all over the country. It is the first
requirement of individuals as it is mandatory to obtain documents like driving and arms
license, National Tax Number (NTN), bank account, passport, cellular connection etc.
Every citizen of Pakistan, 18 years and above, is eligible for NIC.
b) National Identity Card for Overseas Pakistani (NICOP): NICOP is a registration document
issued to a eligible citizen of Pakistan who lives or has reference abroad. Any citizen of
Pakistan can apply for NICOP and can travel to Pakistan without requiring a visa in case
of dual nationality Passport number is a mandatory for applying for NICOP of newborn
babies if they are born abroad.
c) Child Registration Certificate (CRC): CRC is a registration document used to register
minors under the age of 18 years. It is the fundamental right of a child to get a registration
certificate from the place of origin. CRC is also known as B-form. CRC can be taken by
providing documented proof of childbirth from union council. Parent is required to be a
holder of National Identity Card (NIC)/National Identity Card for Overseas Pakistanis
(NICOP).
d) Pakistan Origin Card (POC): POC is issued to Pakistani Origin expatriates by showing
proof of their origin in Pakistan.
e) Family Registration Certificate (FRC): Family Registration Certificate (FRC) is a mean of
being identified with your NADRA’s record. This provides the family composition.
f) Cancellation Certificate: Cancellation certificate is a registration document issued to
register the termination of ID card in case of death of any citizen. Any blood relative
possessing a valid NIC/NICOP, death certificate from union council and the graveyard
certificate of the deceased family member, can apply for the cancellation. The original ID
card of the deceased is destroyed at NADRA’s registration center to ensure that it cannot
be misused.

(ii). Cantonment Ordinance 2002

6
Section 8, NADRA Ordinance,2000
7
NADRA official Website, accessed 15 July 2021, https://www.nadra.gov.pk/identity/

16
Cantonment areas falling within districts are governed by the Cantonments Ordinance, 2002.
The function of registering births, deaths and marriages in the cantonment areas is entrusted to
Union Administrations constituted under the ordnance. Since the vulnerable groups are
foreigners and given that foreigners entry and residence in cantonments is barred by law
therefore this legislation has no relevance to the vulnerable groups.

(iii). Muslims Family Law Ordinance (MFLO), 1961

The Muslims Family Law Ordinance, 1961 is a Federal law however, it has a very close link to
the local governments/bodies. It must be noted here that with regards to registration of
marriages, the Union Councils or Tehsils councils, as the case may be, are to appoint
Nikah(term used for Muslim marriage) Registrars (Those who solemnize marriage and records
it) under the Muslim Family Laws Ordinance, 19618.

(iv). The National Database and Registration Authority (Alien Registration Card)
Rules, 2002

These rules were recently promulgated by NADRA and approved by the Federal Cabinet vide
Statutory Regulation Order (S.R.O) 247(I)/2021. Under these rules NADRA will resume the
functions of former authority for alien registration called the National Alien Registration
Authority (NARA). NARA was established under the provisions of the Foreigners Act, 1946
however it was merged with NADRA through an amendment in the NADRA ordinance in
2016. The rules provide for the registration of foreigners intending to live in Pakistan beyond
90 days. It also gives an exemption, upon registration, from prosecution under the Foreigners
Act,1946 for those foreigners living illegally in Pakistan for a period of five years or more. The
rules have formalized the registration of foreigners under the umbrella of NADRA. However,
the rules exclude Afghans (all categories including refugees, ACC holders and undocumented)
from its operation.

As provided by the rule 6, the birth, death, marriage or divorce of a foreigner’s family member
shall be reported to NADRA. Additionally, rule 18 requires that the officer or authority to
whom, or to where births and deaths are required to be reported under any law relating to
registration of births and deaths, shall report the birth of a newly born foreigner, and the death
of a foreigner who has not attained the age of eighteen years to the District Registrar or any
other authorized registration officer of the Authority.

(v.) The Islamabad Capital Territory Local Government Act, 2015

This local government act though Federal in nature deals with the composition of the local
governments in the Islamabad Federal Capital Territory. It is identical to the local government
acts of various provinces entrusting the functions of recording births, deaths, marriages and
divorces to the Union Councils-in rural context and Municipal Corporation-in the urban
context.

(b) Civil Registration Laws - Provincial

The following local government acts are in place in the districts of Peshawar and Karachi:

a. The Sindh Local Government Act, 2013

b. The Khyber Pakhtunkhwa Local Government Act, 2013
These local government acts define composition of the local governments at the lowest
administrative tiers which are either at Tehsil level (which is the sub-unit of a district) or Union

8 Section 5, Muslim Family Laws Ordinance, 1961, http://punjablaws.gov.pk/laws/777a.html

17
Council level (which is the sub-unit of a Tehsil) in rural areas. These laws also apply to
Municipalities, Metropolitan areas and Towns which are differentiated as urban areas.

Under the current arrangement, the local governments in the provinces record the births, deaths,
marriages and divorces and the data is transferred to NADRA for reconciling at the Federal
level under its mandate of being a central repository of data. The local government acts of all
the provinces are mostly identical with the main difference lying in nomenclature and territorial
divisions of the local governments. The key function of the registration of births, deaths,
marriages and divorce is almost similar in all the provinces.

Analysis on the Implementation of the Bali Process Toolkit in the three identified areas

Based on the outline of the current registration system, the Bali Process Toolkit was tested in
the Islamabad Capital Territory, Peshawar the capital of Khyber Pakhtunkhwa province as well
as Karachi Division in Sindh province. The below is an overall description of the process for
Pakistani nationals according to the law and policy framework and a summary of the current
practices for each of the targeted groups.

(a) . The Islamabad Capital Territory (ICT)

Vulnerable Groups (as of July 2021)

Refugees Afghan refugees holding Proof of 35,003
Registration Cards (PoR Card holders)

UNHCR Mandate recognized Refugees 841

(Afghans and Non-Afghans)

Asylum Seekers (Afghans and Non-Afghans) 1359

(i). Legal framework for registrations of Births, Deaths, Marriages and Divorces

ICT Administration operates under Presidential Order No. 18 of 1980, which confers powers
of the Provincial Government upon the Chief Commissioner Islamabad. There are six
directorates and twenty-five departments working under ICT Administration. All departments
report to the concerned Directorate under the supervision of Chief Commissioner Islamabad.

The Islamabad Capital Territory Local Government Act, 2015 and includes the registration of
births, deaths, marriages and divorces for the Pakistani residents in ICT. This falls under the
responsibility of Local Government & Rural Development.

As per section 71(1) read with serial number (j) of the Second Schedule of the Islamabad
Capital Territory Local Government Act, 2015, a Union Council shall, subject to the provisions
of the Capital Development Authority Ordinance, 1960, arrange for registration of births,
deaths, marriages and divorces in the rural areas of the ICT, and pass on such information about
such events in the Union Council to such persons and institutions as may be prescribed by rules.
Similarly, in the urban areas of Islamabad, the Directorate of Municipal Administration of the
Metropolitan Corporation of Islamabad (MCI) is responsible for registration of births, deaths,
marriages, and divorces.

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There is no provision in the ICT Local Government Act, 2015 explicitly barring registration of
birth and deaths of foreigners. However, for foreigners to register new births and deaths, valid
passports are a pre-requisite. As such, this condition excludes refugees, asylum seekers and
Stateless persons from registration of births and deaths.

(ii). Birth Registration Process

For Pakistani nationals, either of the parents or a close relative of a child must visit the
Directorate of Municipal Administration of the Metropolitan Corporation Islamabad (MCI), if
he/she is a resident of the urban areas of ICT falling in the jurisdiction of that entity. If he/she
is a resident of rural areas of ICT, their birth registration will be done at the Union Council’s
office. The informant is required to fill in the Birth Registration Form ‘A’ issued by NADRA
along with supporting documents: (i) an affidavit as per a standard specimen on a stamp paper
of Rs. 10 duly attested by a notary public solemnly affirming and declaring that the information
about the date and place of birth of the child is correct; (ii) the original birth notification issued
by the certified persons including registered doctors at health institutions or an affidavit of the
midwife if the birth occurred at home; (iii) attested copies of CNICs of the parents, and the
informant (in case either of parents is not the informant); (iv) attested copy of passport of
parents in case either (or both) of them are foreigners; (v) a copy of Islamic marriage contract
i.e. Nikah Nama if the mother’s CNIC is not registered with her husband / father of the child.

Based on the as Form ‘A’ information, the local administration registers the birth to the
NADRA. Upon the completion of the registration, a birth certificate is printed on a NADRA-
supplied secure paper by the Municipal Services Directorate of the MCI or the union councils.
The birth certificates are signed by the Administrative Officer of the Directorate of Municipal
Administration of MCI or the Union Council’s secretary9.

(iii). Death Registration Process

For Pakistani nationals, a close relative of a deceased person needs to visit the Directorate of
Municipal Administration of the Metropolitan Corporation Islamabad (MCI), if he/she is a
resident of the urban areas of ICT falling in the jurisdiction of that entity. If he/she is a resident
of rural areas of ICT, their death registration will be done at the Union Council’s office. The
informant is required either to fill in the Death Registration Form also called in case of MCI as
Form ‘B’.

Along with the above-mentioned information, the following six documents are required: (i) the
original death certificate issued by the hospital, clinic, nursing home, etc.; (ii) attested copies
of the CNICs of the deceased and the applicant; (iii)attested copies of passports of the deceased
and the applicant in case either of them are foreigners; (iv) an attested copy of Nikah Nama in
case of a female deceased wherein her CNIC is not registered with her husband; (v) an affidavit
as per a standard specimen on a judicial stamp paper of Rs. 10 duly attested by a notary public,
by all legal heirs of the deceased solemnly affirming and declaring that the information given

9
Chapter 9 NADRA Ordinance 2000 Registration of citizens.— (1) …a parent or guardian of
every citizen who has not attained that age shall, not later than one month after the birth of
such citizen. (5) The Authority may issue to a citizen who has not attained the age of
eighteen years but is registered under subsection (1), such certificate of registration in such
form and manner and containing such information relating to such registered citizen as may
be prescribed.

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about the death of the deceased is correct and is being given with the consent of all legal heirs;
and (vi) a similar affidavit from all widows if the deceased had more than one wife.

Based on the as Form ‘B’ information, local administration registers the death to NADRA.

Upon the completion of the registration, a death certificate is printed on a NADRA-supplied

secure paper by the Municipal Services Directorate of the MCI or the union councils. The death
certificate is signed by the Administrative Officer of the Directorate of Municipal
Administration of MCI or the Union Council’s secretary.

(iv). Marriage Registration Process

For Pakistani nationals, Muslim marriages are performed by Nikah Khawan, who also act as a
Marriage Registrar appointed by the Directorate of Municipal Administration of the MCI in
case of urban areas of Islamabad or by the concerned Union Council in case of rural areas of
ICT. Before administering the Nikah ceremony during solemnization of a Muslim marriage,
the authorized Nikah Registrar enters in the Nikah Nama, or the Nikah certificate. The Nikah
form has to be filled in duplicate of three forms. One form remains with the couple, one with
the Marriage Registrar and one is submitted to the concerned MCI or the Union Council as the
case may be. The marriage is registered at the Directorate of Municipal Administration of the
MCI in case of urban areas of ICT or at the concerned Union Council’s office in case the
marriage ceremony is performed in the rural areas of ICT.

Based on a copy of the Nikah Nama, the marriage registration certificate is issued under the
signatures of the Administrative Officer of the Directorate of Municipal Administration of the
MCI, or the secretary of the union council. The marriage registration is essentially done under
the MFLO,1961 which applies only to Pakistani Citizens. As such, refugees, asylum seekers
and Stateless persons cannot register marriages with the local government in ICT. This is also
the case with marriage registration in local governments in provinces.

(v). Divorce Registration Process

For Pakistani nationals, A Divorce Deed, wherein a brief history of marriage and child
description is narrated and terms and conditions of divorce if any is required for Divorce
Registration. Preparation of a Divorce Deed is done by the couple (and a family lawyer is
required). The divorce registration is done by the Directorate of Municipal Administration of
the MCI in case of urban areas of Islamabad or by the concerned Union Council in case of rural
areas of ICT. For the registration, the applicant is required the following documents: (i)
Original Divorce Deed; (ii) Copy of Divorce Deed; (iii) Copy of CNIC (Divorcer and
Divorcee); and (iv) Copy of CNIC of the Father of Divorcer and Divorcee. Upon registration,
Divorce Registration Certificate is issued.

(b) . Peshawar District

Vulnerable Groups (as of July 2021)

Refugees Afghan refugees holding Proof of 308,927
Registration Cards (PoR Card holders)

UNHCR Mandate recognized Refugees 985

(Afghans and Non-Afghans)

Asylum Seekers (Afghans and Non-Afghans) 1324

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 (i). Legal provision for registrations of Births, Deaths, Marriages and Divorces

The Khyber Pakhtunkhwa Local Government Act, 2013 is the basis for the registration of the
vital events of residents in Khyber Pakhtunkhwa province, which has introduced a new tier of
the local government called as Village Councils in the rural areas and Neighbourhood Councils
in the urban areas with specific composition10 and functions11. These newly created lowest
local government entities register births, deaths, marriages and divorces.

The Local Government and Rural Development Department oversees coordination between the
secretarial functions of village and neighborhood councils in the district 12 . In addition, the
Section 112 of the Khyber Pakhtunkhwa Local Government Act, 2013 states that “the
provincial government may, by notification in the official gazette, make rules for carrying out
the purposes of this Act13”, and articulates that “in particular and without prejudice to the
generality of this power, such rules may provide for the matters specified in Part-I of Seventh
Schedule14” and “rules may be made by the Government, among other functions of the village
and neighbourhood councils, for registration and certification of births, deaths, marriages and
divorces.”15

With regard to the Part-1 of Seventh Schedule of this Act, the Government of Khyber
Pakhtunkhwa has prepared a draft of The Khyber Pakhtunkhwa Registration of Births, Deaths,
Marriages and Divorce or Dissolution of Marriages Rules, 2021. These rules have been passed
by the provincial cabinet of Khyber Pakhtunkhwa and are expected to be published in the
official gazette soon.

The Khyber Pakhtunkhwa Local Government Act, 2013 is a substantive law providing
municipal functions of Khyber Pakhtunkhwa province, including Peshawar district. It does not
distinguish between the citizens and the vulnerable population groups in terms of recording and
certification of their vital events. One of the significant changes brought by these rules is the
express mention, in section 13, of a “refugee residence permit number” as a requirement for
registering the births in refugee populations. Although the refugee residence permit number has
not been defined however the PoR Card number or UNHCR issued mandate refugee card
number may be construed as refugee residence permit.

(ii). Births, Deaths, Marriages and Divorces Procedure in Peshawar District

All the Births, Deaths, Marriages and Divorces Procedures are the same as the ICT and use the
same NADRA issued formats for Pakistani nationals. According to rule 15 of the Khyber
Pakhtunkhwa Registration of Births, Deaths, Marriages and Divorce or Dissolution of
Marriages Rules, 2020, in case either of the parents or both the parents of the child is/are

10 Ibid, section 27
11 The Khyber Pakhtunkhwa Local Government Act, 2013, section 29, a new section 29 substituted for
the original one through section 15 of The Khyber Pakhtunkhwa Local Government (Amendment) Act,
2019
12 Ibid, section 29 (3)
13 The Khyber Pakhtunkhwa Local Government Act, 2013, section 112 (1)
14 Ibid, section 112 (2)

15 Ibid, Sevenths Schedule, Part-I, serial No. 23

21
foreigner(s), he/she is required to register his or her passport number or refugee residence
permit number duly attested by the concerned embassy, consulate or high commission, as the
case may be, and submit the copy thereof to the concerned council for registration of birth.

Where any of the parties to the marriage is a foreigner, it is mandatory to appear before Court
Registrar, concerned Embassy, Consulate or High Commission, and declare on oath that he or
she is performing the marriage with free will and without any undue influence. For registration
of marriage, the following documents are required to be submitted to the Nikah Registrar along
with the Nikah Form, as prescribed under the Muslim Family Laws Ordinance 1961: (i) A
copy of declaration on oath made before with Court Registrar, concerned Consulate, High
Commission, as the case may be; and (ii) Attested copy of CNIC and / or passport (of a
foreigner) and (iii) A certificate from the concerned Embassy, Consulate or High Commission
regarding his / her marital status in his or her own country as well as security clearance, clearly
certifying that he or she has not been involved in any illegal acts.

The concerned local council within whose jurisdiction marriage is solemnized, is required to
issue the Computerized Marriage Registration Certificate.

The following documents are required for the issuance of marriage certificate: (i) A copy of
Nikah Nama duly registered by the Nikah Registrar or the marriage certificate, in case the
marriage being solemnized by any other authority, as per personal laws of non-Muslims; and
(ii) CNICs of husband and wife along with copies of their parent’s CNICs. Alternatively, the
copy of passport (in case of foreigner) or residence permit (in case of refugee).

(c). Karachi Division

Vulnerable Groups(as of July 2021)

Refugees Afghan refugees holding Proof of 65,656
Registration Cards (PoR Card holders)

UNHCR Mandate recognized Refugees 379

(Afghans and Non-Afghans)

Asylum Seekers (Afghans and Non-Afghans) 604

Stateless Bihari, Bengali and Rohingya 3.Million (approx..)

Population communities

(i). Legal provision for registrations of Births, Deaths, Marriages and Divorces

In Sindh province, including seven districts of Karachi, the Sindh Local Government Act, 2013
provides the basis of registration of vital events for residents. It has been amended by the
provincial legislature since its initial passage in the year 2013.

Serial No. (34) of Schedule IV of the Sindh Local Government Act, 2013 details that
registration and computerization of data regarding births and deaths, marriages and divorces,
and the maintenance of such vital statistics is prescribed as a function of the Union Councils.
The registration of births, deaths and marriages is being performed by the Union Committees
in all seven districts of Karachi Division.

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Like Khyber Pakhtunkhwa, the Sindh Local Government Act, 2015 is a substantive law
providing for municipal functions in all districts of Sindh - including seven Karachi districts –
and does not distinguish between Pakistani citizens and the vulnerable population groups
including refugees, asylum seekers, stateless persons and persons of undetermined nationality
in terms of recording and certification of their births, deaths, marriages and divorces.

Curent practice for civil and functional registration of vulnerable groups

(a). Refugees

(i). PoR Card Holders

The Data of the PoR Cards known as the Afghan National Registration (ANR) is managed
directly by NADRA. The registration of births, deaths and marriages as well as other
modifications is conducted for PoR Card holders by NADRA at designated PoR Card
Modification (PCM) Centers supported by UNHCR. Modifications as well as new birth
registrations are carried out into these PoR Cards through a special arrangement agreed between
UNHCR and NADRA. NADRA and UNHCR have agreed on Standard Operating Procedures
(SOPs) for effecting any modification and new birth registrations. The SOPs also provide for a
procedure of registration of marriages and deaths but the prevalence of recording these events
is extremely low for certain reasons such as a) low awareness amongst the refugee community
on the importance of these registration/certificates, b) lack of documentary proof of marriages
since most Afghans solemnize marriages verbally at local level c) lack of resources for
travelling to PCM centres unless required. Furthermore, marriage certificates are issued by
either the Embassy of Afghanistan in Pakistan or the Afghan consulates in Pakistan after
solemnizing their marriages in Pakistan.

(ii). Other Afghan and non-Afghan refugees who are recognized by UNHCR

The mandate refugees are registered with UNHCR in its database called ProGres. The mandate
refugees do not have access to public registration for the recording of their births, deaths and
marriages. This has led to challenges for them in accessing public services which are
increasingly dependent on having Computerized National Identity Card (CNIC) issued by
NADRA. UNHCR continuously advocates for these individuals in terms of accessing public
services.

(b). Asylum-seekers

These individuals are issued Asylum Seeker Certificate (ASC) by UNHCR following their
registration in the ProGres. The ASC serves a proof of registration and affords protection
against refoulment and access to basic services such as health, education and freedom of
movement. Like the mandate refugees, the asylum seekers do not have access to public
registration system for recording of their births, deaths and marriages. These vital events are
recorded by UNHCR in ProGres.

(c). Stateless persons, persons at-risk of statelessness and those of undetermined nationality

These community members may have some access to civil registration including births, deaths
and marriages however a considerable number of people of these groups do not have access to
public registration system. A sizeable number of people especially from the Bihari and the
Bengali groups had acquired CNICs however most of them have been blocked by NADRA for
want of verification under the prescribed law. One of consequence of this blockage of CNICs

23
has resulted in suspension of the validity of the identity documents of complete households.
Registering new births with the local bodies is not uniform and persons resort to access those
local bodies-not necessarily the relevant one who could facilitate registration of their births
somehow. This results in low acceptability of such birth certificates by NADRA down the line
when these individuals’ approach for acquiring CNIC.

6. Gap analysis
(a). Service provider issues

(i) Legal and regulatory framework

The laws and regulations on civil registration at the federal and local level (i.e. Punjab, Sindh,
Khyber Pakhtunkhwa, Balochistan, ICT, the cantonment areas, Azad Jammu & Kashmir, and
Gilgit-Baltistan) do not distinguish between Pakistani citizens and the vulnerable population
groups including refugees, asylum seekers, stateless persons and persons of undetermined
nationality in terms of recording and certification of their births, deaths, marriages and divorces.
However, attested copy of CNIC and / or passport (of a foreigner) is a requirement for these
registrations and the local civil registrars are not able to record most of vital events in the
vulnerable population groups.

(ii) Capacity of local civil registrars

During the assessment, the local civil registrars in ICT, Peshawar, and Karachi stated that no
procedures/guidelines were available for recording vital events in the vulnerable population
groups. It is also noted that no systematic training on civil registration for the local civil
registrars has been conducted in the ICT, Peshawar, and Karachi.

(b). Beneficiary issues

(i) Awareness about the civil registration
During the assessment, an Afghan refugee respondent stated that birth registration of his
children was done but he was not aware of basic procedures for death and marriage registration.
The application forms for PoR card modification were only available in Urdu or English but
Dari was not available.

(ii) Geographic barriers

Distances are a challenge for PoR holders for recording vital events. The four PCM centres i.e.,
Peshawar, Quetta, Karachi, and Rawalpindi are not well accessible for afghan refugees reside
in remote areas. In addition, afghan refugees need to travel to the Afghan Embassy in Islamabad
or one of the Afghan consulates in Peshawar, Quetta, Karachi or Lahore to get a marriage
certificate and record their marriage at the one of PCM centres.

7. Recommendations
Based on the findings from the assessment the following recommendations are made.

Recommendations for Policy and Operational Considerations

24
 ● Ensure birth registration for all children born on the territory of Pakistan
regardless of their legal status in line with the Convention on the Rights of
Child (CRC) to which Pakistan is signatory.
● Explicit legal provisions for the inclusion of vulnerable population groups to
access CRVS may be considered when drafting federal law in accordance with
of the Bali Process Declaration on People Smuggling, Trafficking in Persons
and Related Transnational Crime and in line with Pakistan’s obligations under
the CRC and ICCPR.
● At provincial level, where gaps remain to explicitly reference these vulnerable
population groups, relevant legislations including local government acts
should be revised.
● The National Policy to Revamp and Reform Civil Registration of Vital Events
and Ensuing Vital Statistics System in Pakistan aims to establish a one stop
service system regarding CRVS at local government offices and started a pilot
project to implement this system in the ICT as a model district. However, the
model district does not provide any CRVS services for non-nationals nor those
who are stateless, at-risk of statelessness or of undetermined nationality, and
inclusion of the vulnerable population groups shall be considered for the next
stage of the pilot.
● Capacity development support including standard operating procedures and
trainings specifically on inclusion of the vulnerable groups should be
contemplated.
END

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