Citizens Protection (Against Online Harm) Rules, 2020

Document type

Update (March 2020): The Rules remain on the statute books however the Pakistani authorities have now pledged to review the regulations and undertake an ‘extensive and broad-based consultation process with civil society and technology companies’. This was in response to a letter from the Asia Internet Coalition addressed to the Prime Minister in which tech-companies threatened to pull out completely from Pakistan if the Rules were enforced.

Content takedown: The Rules require social media intermediaries to remove, suspend or disable access to illegal online content within 24 hours on when it receives such communication from the Pakistan Telecommunication Authority (PTA). The decision of whether the content is impermissible under the law will be taken by the PTA or the National Coordinator (appointment by the Minister of Information Technology and Telecommunications). In emergency situations (as determined by the National Coordinator), the intermediary would be required to take down content within 6 hours.

Local presence requirement and data localization: Rule 5 requires companies to open permanent offices in Islamabad and set up servers to store data in the country.

Proactive monitoring of live content: Rule 4(4) requires social media companies to ‘deploy proactive mechanisms to ensure prevention of live streaming’ of any content in violation of any law, rule, regulation for the time being in force regarding online content related to terrorism, extremism, hate speech, defamation, fake news, incitement to violence and national security. It is pertinent to note that fake news has not been defined and thus may be anything the government deems to be so.

Penalties and fines: Rule 7 stipulates the National Coordinator may block the entire Online system or Social Media Application if a company fails to abide by the Rules or may impose a fines up to five hundred million rupees (3 million US$ approximately).
For detailed analysis, refer to
Digital Rights Foundation.

Topic, claim, or defense
General or Non-Specified
Public Order (Includes National Security)
Document type
Issuing entity
Executive Branch
Type of service provider
Host (Including Social Networks)
Issues addressed
Notice Formalities
OSP obligation considered
Block or Remove
Monitor or Filter
Type of law
General effect on immunity
Weakens Immunity
General intermediary liability model
No Safe Harbor or Immunity