Climate Change Laws: Comparing Pakistan and Sweden

1. Abstract

The current paper explores the climate governance in Pakistan, a country which has faced existential crisis due to climate induced catastrophes – and compares Pakistan with Sweden which is gold standard for environmental sustainability. Even though Pakistan contributes less than 1% to Global Greenhouse Gas (GHG) emissions, it remains the most affected country. This study provides comparative analysis of Pakistan Climate Change Act 2017 and Swedish Climate Act 2018, while evaluating best practices in carbon pricing, renewable energy transition, and institutional enforcement. The findings say that Pakistan does have institutional framework, but the problem lies in implementation and finances. Conversely, Sweden’s long term strategy provides a roadmap for carbon neutrality by 2025 while Pakistan stands at destruction. The paper writing provides policy recommendations in the last with the purpose that Pakistan may align its domestic laws and practices with international best practices.

 

2. Introduction

Climate change poses existential threat to most of the countries particularly those that are under developed. Pakistan is in hot waters due to glacial melt, catastrophic flooding (as seen in 2022 and later), and lethal heatwaves in regions like Multan in Punjab and many cities of Sindh. For countries like Sweden, Denmark and others, this challenge is the driver of innovation and a commitment to global leadership.

As per Global Climate Risk Index, Pakistan ranks consistently among the top ten of most vulnerable nations. Pakistan lost over $30 billion due to the 2022 floods and one-third of Pakistan was submerged. Pakistan is in the frontline of the climate crisis and is struggling hard with a compliance deficit.

2.1 Problem Statement

Pakistan has two environmental legal frameworks including Environmental Protection Act 1997 and the Climate Change Act 2017 – both face serious crisis of implementation and budget deficit. At first, the federal government had the power to enforce these environmental frameworks and make policies related to it. Since the 18th amendment in 2010, these powers have been devolved to provinces, which has created another dilemma of inconsistent implementation.

2.2 Research Objectives

This paper aims to achieve following objectives;

• To analyze the legal provisions of Pakistan’s climate policies.
• To identify the “best practices” that have made Sweden a global leader.
• To provide a comparative matrix of institutional effectiveness.

 

3. Literature Review

The scholarship on climate change and climate legislation has shifted from ‘theoretical compliance’ to ‘enforcement efficacy’. We have made policies and laws but the implementation is at par particularly in Pakistan. There is a governance gap globally and administrative capacity is the primary barrier to climate sustainability.

3.1 The Global Governance Gap

Andersson (2019) provides a seminal quasi-experimental study on Sweden, demonstrating that the carbon tax alone reduced transport emissions by 11%. The writing provides evidence of how Sweden, when they made climate governance part of their budgets, reduced carbon emissions and earned revenues through carbon tax. This contrasts sharply with literature on the Global South, where UNDP (2025) argues that administrative capacity, rather than just law-making, is the primary barrier to climate success. Even if finances are there, they are misused and implementation of environmental laws rarely happens and we witness the devastating effects of climate change almost every year now.

3.2 Pakistan’s Legislative Evolution

Recent scholarship by Jamshaid & Muller (2025) highlights that Pakistan’s move toward a National Carbon Market (NCM) at COP29 represents a pivot from purely regulatory oversight to market-based incentives. However, researchers warn that the 18th Amendment, while democratizing governance, has created “jurisdictional friction” where federal climate goals often clash with provincial industrial priorities.

In the context of Pakistan, research by Jamal (2018) argues that the Climate Change Act 2017 remains largely “aspirational” and on paper because the Pakistan Climate Change Authority which is the primary body for implementation and has remained under-resourced for years. The problems are with implementation which is further complimented by lack of finances. Conversely, Swedish literature focuses on the “Green Model,” which integrates business profitability with carbon reduction (Sweden.se, 2026).

 

4. Environmental Laws in Pakistan

In Pakistan, the environmental laws have evolved from colonial times. At that time we had statutes like the Forest Act 1927 which was quite complex unlike modern frameworks.

4.1 The Bedrock: Pakistan Environmental Protection Act (PEPA) 1997

The Pakistan Environmental Protection Act (PEPA) 1997 replaced the 1983 ordinance of Pakistan Environmental Protection Council (PEPC) – and remains the primary legal authority for environmental control and sustainability and it works as a guiding document for future environmental legislation.

The National Environmental Quality Standards (NEQS): The NEQS are specific limitations and standards and PEPA mandates that no person or industry shall emit or discharge any effluent or pollutant in excess.

Environmental Impact Assessment (EIA): This is the most critical part under section 12 of the said Act. No project shall be commenced or industry be installed, if it likely causes environmental degradation – this was the initial screening called Initial Environmental Examination (IEE).

Environmental Tribunals: The statute established environmental tribunals to hear cases related to the environment and prioritize environmental sustainability. It was a forum where technical experts were called to sit beside judicial members.

 

4.2 The 18th Amendment: A Paradigm Shift

In 2010, the 18th Amendment to the Constitution of Pakistan abolished the “Concurrent Legislative List.” As a result, the subject of “Environmental Pollution and Ecology” was devolved entirely to the provinces. Since then, there has been a governance crisis in Pakistan related to sustainability. The amendment led to provincial autonomy which resulted in province-specific laws like Punjab Environmental Protection Act (Amended 2012) and the Sindh Environmental Protection Act 2014.

Though the provinces enacted their own laws related to environmental regulation- it created regulatory patchwork at the same time. A company which was operating nationwide could now face different standards and enforcement levels, which exacerbated the issue of climate reporting and international treaty compliance.

4.3 The Pakistan Climate Change Act 2017

The Paris Agreement was adopted by 196 countries at COP21 in 2015 and Pakistan is one of them. The aim of the agreement was to limit global warming to 2 degree celsius. While PEPA 1997 was focused on pollution control, the Pakistan Climate Change Act 2017 was specifically designed to meet international obligations under the Paris Agreement. The act designed following bodes;

The Climate Change Council: Chaired by the Prime Minister, this body is designed for high-level policy coordination.

The Climate Change Authority (PCCA): Tasked with designing projects for the Green Climate Fund (GCF) and managing the national carbon footprint.

Critics, such as Jamal (2018), argue that the Pakistan Climate Change Authority (PCCA) has historically functioned as a “paper tiger” due to a lack of permanent technical staff and consistent funding, often remaining subservient to the Ministry of Climate Change rather than acting as an independent regulator.

4.4 Emerging Frameworks

National Adaptation Plan (NAP) 2023: This is the most recent strategic document. It moves beyond “prevention” to “resilience,” identifying seven priority sectors including the Agriculture-Water Nexus and Urban Resilience. It specifically addresses the “reconstruction” needs following the 2022 floods.

National Carbon Market Policy (2025): Currently in its pilot phase, this policy attempts to create a “voluntary” carbon market in Pakistan, preparing the local industry for the global shift toward carbon pricing, a direct bridge to the Swedish best practices discussed later in this paper.

 

4.5 Challenges in Enforcement

Pakistan’s ranking in the Climate Change Performance Index (CCPI) 2026 is 15th, which highlights that Pakistan is highly vulnerable to climate catastrophes as witnessed back in 2022. It further states that Pakistan is low on renewable energy and climate policy implementation.

 

5. Comparative Analysis: Pakistan vs. Sweden 

5.1 Why Sweden Succeeds

The Swedish framework is unique because it is legally binding on the government’s budget. Each year, the Swedish government must present a climate report alongside its Budget Bill. This ensures that environmental goals are never sidelined for economic ones.

The Swedish climate act of 2018 mandates that every government regardless of political differences must present a Climate Report alongside its annual budget which ensures that fiscal spending should not outperform carbon emissions. Additionally, if the proposed budget increases emissions-  the government is legally required to explain how it will compensate to meet the net-zero 2045 target.

5.2 Governance Structure: Pakistan and Sweden

The main hurdle for Pakistan in the implementation of environmental law is constitutional complexities where climate action is neither recognized nor incentivized within the NFC formula. Provinces do receive fiscal transfers but there is no binding authority regarding the implementation of climate law. The Federal Ministry of Climate Change makes global commitments (e.g., a 50% emission reduction by 2030), but it lacks the constitutional power to force the Punjab or Sindh provincial governments to change their agricultural or industrial practices. As noted by CDPR (2025), Pakistan faces an “implementation vacuum” where federal ambition meets provincial incapacity.

Sweden operates in a centralized system where the national government sets the standards, local municipalities (Kommuner) implement the policies and they also receive funding for the implementation. Then there comes into play the Swedish Watchdog i.e, The Swedish Climate Policy Council which provides external audits of the government progress on climate action.

 

5.4 Best Practice Transferability: The “Climate Matchmaker”

In 2025, Sweden launched the “Climate Matchmaker” initiative, specifically designed for developing nations like Pakistan to learn from their best practices and bridge their implementation gap.

Sweden had made a Social Climate Plan, and Pakistan could have adopted it (as endorsed by EU) – the plan uses carbon tax (revenue) to subsidize electric transport for rural and low-income populations. For Pakistan, this would mean using a “Smog Tax” from Lahore’s industrial sector to directly fund electric bus transit in the same city creating a visible, circular benefit that builds public trust.

This section examines the “Judicialization of Climate Change,” comparing how courts in two vastly different jurisdictions hold their governments accountable for climate inaction.

5.5 Judicial Activism: The Aurora Case (Sweden) vs. Asghar Leghari (Pakistan) and Zia v. WAPDA (1994)

The judiciary has always stepped in whether there is human rights violation or issues related to the environment – though climate issues are ultimately human rights issues. It has emerged as a final arbiter for climate enforcement when legislative and executive branches fail to act.

5.5.1 The Aurora Case: Youth-Led Accountability in Sweden

In Sweden back in 2022, a group of over 600 individuals protested which included children and young adults – their slogan was simple and that was to save the environment before it’s too late. The group (famously called the aurora group) also included Greta Thunberg. When the government paid no attention, the aurora group sued the Swedish Government.

The group’s main argument was that Sweden’s current climate policies are insufficient to meet its own targets which thereby violates our rights enshrined in European Convention on Human Rights (ECHR) – specifically right to life and family. In the coming years 2024-25, the Swedish courts allowed the case to proceed further. It signaled that even in a “green leader” nation, the judiciary can intervene if the government’s long-term strategy is deemed mathematically inconsistent with its short-term actions. After this landmark case, the Swedish Government treats climate action not just as a policy goal but as a human rights dilemma. (Anton Foley and others v. Sweden (The Aurora Case) (2025). Case No. Ö 1511-24)

5.5.2 Asghar Leghari v. Federation of Pakistan: Climate Justice in the Global South

While nations like Sweden sets targets for the future and treats climate change as a threat to fundamental human rights – Pakistan lags behind and struggles with present survival.

In the landmark case in 2015, a farmer named Asghar Leghari sued the government for failing to implement the National Climate Change Policy 2012. Asghar argued that the government’s inaction threatened his food and water security, violating Article 9 (Right to Life) and Article 14 (Dignity) of the Constitution of Pakistan. Former Justice Mansoor Ali Shah ruled that climate change is the defining challenge of our time. The Court created a Climate Change Commission (CCC) to work as a watchdog on the government’s progress. This step pushed the government from policymaking to project execution. (PLD 2018 Lahore 364)

 

5.5.3 The case of Shehla Zia v. WAPDA (1994)

This particular case serves as a landmark judgement in the constitutional history of Pakistan and laid foundations for environmental law in Pakistan. The Leghari case was about climate adaptation while this instant case transformed the ‘right to life’ into the “right to clean environment”.

 

Before 1994, environmental protection was not considered to be a constitutional right. All this changed when a group of people led by Ms. Shehla Zia challenged the construction of an electricity grid station in Islamabad.

 

The Petitioners relied on right to life and article 14 (dignity of men) since there were no environmental statutes at the time. They said that construction of grid stations in such close proximity poses a serious threat to life.

 

Justice Saleem Akhtar delivered a judgment that redefined Pakistani jurisprudence. The Court held:

“The word ‘life’ is very significant as it covers all facets of human existence… it does not mean nor can it be restricted only to vegetative or animal life. It includes all such amenities and facilities which a person born in a free country is entitled to enjoy with dignity.”

After this definition, the court ruled that an unpolluted and green environment is a condition precedent for life. That a degraded environment violates the very right to life. The court incorporated two international principles to the judgment;

The Precautionary Principle: The Court ruled that even if scientific evidence of harm (like the impact of electromagnetic fields) is inconclusive, the state must “err on the side of caution” to protect citizens.

Sustainable Development: The Court acknowledged that while energy projects are necessary for economic growth, they cannot be pursued at the cost of human health.

The impact of the case was not just that Shehla Zia stopped the construction of the grid station rather the results were significant. The Government was forced to establish Public Consultation before implementation of any project. WAPDA was ordered to issue notices to hear public objections and now Environmental Impact Assessments (EIAs) is a standard across Pakistan.

5.5.4 The 26th Constitutional Amendment: Article 9A

The right to clean the environment existed only in judicial interpretation for three decades. In 2024, the constitution of Pakistan 1973 was amended for the 26th time and a new article (9A) was inserted.

The article explicitly states:

“Every person shall be entitled to a clean, healthy, and sustainable environment.”

This was a monumental shift. Once it was just in judicial interpretation and now it’s our constitutional rights and it was all a result of judicial activism. It now aligns with international standards like the UN’s declaration of 2022  as “clean and healthy environment” as a universal human right. Now citizens can invoke this article challenging deforestation, environmental degradation and inadequate climate adaptation measures.

 

6. Global Best Practices for Climate Change

In 2026, the international community has moved beyond carbon reduction – they are working on system transformation. Following are a few effective strategies which leading green economies like Sweden and Denmark use.

6.1 Market-Based Instruments: The “Polluter Pays” Evolution

The most successful mitigation strategy remains the internalizing of the social cost of carbon.

Dynamic Carbon Pricing: Beyond simple taxing in Sweden, there is now contemporary carbon taxing through Emission Trading System (ETS). According to Stiglitz et al. (2017), a carbon price of $50–$100/tCO2 is essential to keep global warming below 2 degree celsius.

The “Feebate” System: This practice is successfully employed in Norway and Sweden where a fee is imposed on high carbon products (like ICE vehicles) and that fee is used to provide a rebate for low carbon alternatives (like electric vehicles).

6.2 Nature-Based Solutions (NbS) and Blue Carbon

Leading green economies are also taking advantage of ecosystems and are being used as infrastructure.

Regenerative Agriculture: Global leaders like the Netherlands and Denmark are shifting toward silvopasture (integrating trees with livestock) and cover cropping. Research by WRI (2025) shows that pastures with trees can sequester 5–10 times more carbon than treeless areas while protecting livestock from heatwaves.

Mangrove & Wetland Restoration: In the Global South, Vietnam and Mozambique have pioneered “Community-Managed Forests.” Restoring coastal wetlands could sequester an additional 290 Mt of CO2e per year by 2050, providing a natural shield against storm surges (World Bank, 2026).

6.3 Innovative Climate Finance (The 2026 Frontier)

Financing remains the biggest hurdle for developing nations like Pakistan. Global best practices now include:

Debt-for-Climate Swaps: Through this scheme, a debt of a country is forgiven with a condition of local investments in climate action which is relevant to Pakistan’s current economic climate situation.(GIZ, 2026).

6.4 Urban Resilience: The “Cool City” Framework

When urban temperatures rise,the cool city framework comes into play and the “Smart Development” model is being standardized:

Reflective Infrastructure: As per the World Bank Findings, if rooftops are painted white and heat-reflective coatings are used – it will reflect 60-90% of sunlight, reducing indoor temperatures and energy demand for air conditioning. (World Bank, 2026).

The 15-Minute City: A planning best practice from Paris and Bogota that ensures all essential services are within a 15-minute walk or bike ride, drastically reducing transport-related emissions.

7. Recommendations for Pakistan: The “Fix, Grow, and Build” Strategy

Based on the comparative analysis, Pakistan now needs to step in and work for systematic transformation. The clock is ticking and if the action is not taken on time, we could face far worse devastation that we will forget 2022 floods and other events of the past. It needs fiscal and legal transformation.

7.1 Fiscal & Economic Recommendations

Establish a Revenue-Neutral Carbon Levy: Pakistan needs to move from exploratory National Carbon Market Policy 2024 to formal carbon levy on high emission fuels like Coal and Bunker Oil.

Incentivize “Green Offsets” for Industry: Pakistan should also work to introduce tax credits for Small & Medium Enterprises (SMEs) that implement ISO 14001 standards or switch to solar-powered manufacturing, effectively creating a “Domestic Carbon Border Adjustment Mechanism (CBAM)” to protect exports to the European Union (EU).

7.2 Legal & Institutional Recommendations

Constitutional “Climate Bridge”: If we talk about constitutional gaps, Pakistan can amend the Rules of Business to mandate a Climate Clearance” for all provincial development projects exceeding Rs. 500 million. This will bridge the gap previously created by the 18th amendment.

Judicial Specialization: Pakistan can also establish “Green Tribunals or Benches” not just at the High Court but also at district level to serve as a watchdog and handle local government environmental violations of crop burning, unnecessary deforestation or illegal logging with urgency.

 

8. Implementation Roadmap

The proposed roadmap aligns with Pakistan’s National Adaptation Plan (NAP) and the 300-Day Preparedness Plan announced in late 2025. We divide the roadmap into three phases.

Phase I: The “Fix” Phase (2025–2026)

Legislative Audit: Pakistan should fully operationalize the Pakistan Climate Change Authority (PCCA) established under Climate Change Act 2017, with permanent technical staff and a dedicated treasury line.

Carbon Market Pilot: Pakistan has authorized its first Article 6.4 carbon offset projects to prove the viability of international carbon credit trading under the Paris Agreement. Pakistan should launch the first Article 6.4 projects (e.g., the Korean Clean Water Project in Punjab) to prove the viability of carbon credit trading.

Infrastructure Restoration: Execute the “300-Day Plan” to rebuild flood-damaged levees and drainage systems in Sindh and Balochistan using Nature-Based Solutions.

Phase II: The “Grow” Phase (2027–2028)

Mandatory Climate Budgeting: Integrate climate risk assessments into the Annual Development Programme (ADP) at both Federal and Provincial levels mirroring the Swedish Budget Bill requirement.

Electrification of Transport: Implement the New Energy Vehicle Policy targets by replacing 30% of public transit fleets with Electric Buses in smog-prone cities (Lahore, Karachi, Faisalabad).

Debt-for-Nature Swaps: Negotiate with bilateral creditors to convert 5% of external debt into “Green Bonds” for the Living Indus Initiative.

Phase III: The “Build” Phase (2029–2030)

Net-Zero Roadmap 2050: Formulate a legally binding “Long-term Strategy” (LTS) that commits Pakistan to a specific year for carbon neutrality, supported by a decentralized grid of 60% renewable energy.

Climate Insurance: Launch the National Parametric Insurance Scheme for the agriculture sector to provide instant payouts to farmers during extreme weather events.

 

9. Conclusion

This research has compared two contrasting countries – Sweden which is considered a pioneer in green growth/economy and Pakistan which is most vulnerable to climate change effects. There could be many reasons for our vulnerability but the crisis of accountability and implementation remains the same. Sweden shows legislative discipline while Pakistan lacks governance. The differences on climate action remain still between Global North and Global South. Countries like Pakistan are in the frontline of vulnerability and struggling to mitigate risks posed by climate change.

Pakistan has policies and good laws but they are limited to shelves while Sweden has incorporated all these laws and policies to their annual spending and budgets. The most inspiring part of the study is the role of the judiciary. When governance and politicians fail to act, the courts step in to protect people. The case of the aurora group in Sweden and Leghari in Pakistan send the same message – climate change is real and we should act promptly.

Pakistan is a victim of floods and heat, but we have got the potential and Pakistan can be a leader by adopting best practices like Sweden – Blue Carbon and Green Finance can work.

The Journey from words on paper to climate justice requires only one thing – implementation. Pakistan is a resilient nation and we should consider climate action as our responsibility.

 

10. Bibliography

Government of Pakistan, Pakistan Climate Change Act 2017 (Act No X of 2017).

Government of Pakistan, National Adaptation Plan (NAP): A Resilient Pakistan (Ministry of Climate Change and Environmental Coordination 2023).

Government of Sweden, The Climate Act (2017:720) (Ministry of Climate and Enterprise 2018).

Ministry of Climate Change, Pakistan’s Third National Communication on Climate Change (Government of Pakistan 2025) submitted to the UNFCCC.

United Nations Framework Convention on Climate Change, Paris Agreement (adopted 12 December 2015, entered into force 4 November 2016).

Asghar Leghari v Federation of Pakistan PLD 2018 Lahore 364 (Lahore High Court).

Anton Foley and others v Sweden (The Aurora Case) Case No Ö 1511-24 (Swedish Supreme Court, 19 February 2025).

Shehla Zia v WAPDA PLD 1994 SC 693 (Supreme Court of Pakistan).

Germanwatch and NewClimate Institute, Climate Change Performance Index 2026: Pakistan Country Profile (2026).

M Cahyani and D Ardiyanti, ‘The Influence of Sweden’s Carbon Tax on Global Environmental Diplomacy’ (2025) Proceedings of IROFONIC 2024 vol 1.

L Nordlander, ‘Sweden’s First Systemic Climate Mitigation Case and the Application of KlimaSeniorinnen: Unpacking the Supreme Court’s Judgment in the Aurora Case’ (2025) Columbia Law School Climate Law Blog.

Organisation for Economic Co-operation and Development, Environmental Performance Reviews: Sweden 2025 (OECD Publishing 2025).

Swedish Climate Policy Council, Evaluation of the Government’s Climate Policy Action Plan: Report 2025 (2025).

World Bank Group and Asian Development Bank, Climate Risk Country Profile: Pakistan (World Bank 2021).

World Bank Group, Snapshot of the Pakistan Climate Change Action Plan 2021–2025 (World Bank 2022).