NON-STATE ACTORS IN EDUCATION
2.2 Non-state education provision
3.1 Regulations by distinct levels of education
- Early childhood care and education (Entry/Establishment ○ Financial operation ○ Quality of teaching and learning ○ Equitable access ○ Quality assurance, monitoring and accountability)
- Primary and secondary education (Entry/Establishment ○ Financial operation ○ Quality of teaching and learning ○ Equitable access ○ Quality assurance, monitoring and accountability)
- Tertiary education (Entry/Establishment ○ Financial operation ○ Quality of teaching and learning ○ Equitable access ○ Quality assurance, monitoring and accountability)
3.3 Supplementary private tutoring
In Pakistan, there is no single national education act or law. At the federal level, all education from early childhood to tertiary level is governed by the National Education Policy (2017), which defines “private sector institutions” as “education institutions which are not opened, run, managed and financed by the government” but by “individuals, civil societies, trusts, non-government organizations and WAFAQs”. It further clarifies that these institutions include a “varied category (of) institutions” such as “low cost, high cost, non-profit, profit based and Deeni Madaris”, in addition to “both registered and non-registered institutions”. The Constitution of the Islamic Republic of Pakistan (1973, as amended in 2018) only refers to “religious communities or denominations” as non-state actors operating within the country’s education system.
2.1 State education provision
State schools
Most education (60% of total enrolment) is provided by the state and is free and compulsory in Pakistan from primary (ages 6 – 9), middle (ages 10 – 12), high (ages 13 – 14), and higher secondary (ages 15 – 16) education levels. However, the only level with a higher share of state schools is primary level, as non-state schools account for 66%, 68%, and 61% of all schools at middle, high, and higher secondary levels respectively.
When comparing rural and urban areas in Pakistan, a significant majority (77%) of children residing in rural areas aged 5-16 attend state schools, whereas the majority (62%) of children in urban areas aged 5-16 attend schools which are operated and managed by non-state actors.
Finally, when examining state and non-state provision in the different provinces, Punjab appears to have the least numerical difference between state (51%) and non-state (49%) institutions, while the Khyber Pakhtunkhwa (KP) Newly Merged Districts (former “Federally Administered Tribal Areas”) appear to have the most significant difference in state and non-state institutions, with state schools accounting for 94% of all schools in the region. As these districts have been merged with KP following the 2018 Amendment to the Constitution of the Islamic Republic of Pakistan (1973), the province with the most significant apparent difference between state and non-state institutions is Balochistan, where 93% of all schools in the district are owned and managed by the state. Notable differences in state and non-state provision can also be recorded by education level. In Sindh, although fewer than 10% of primary schools are owned and managed by non-state actors, this percentage jumps to over than 60% for middle, high, and higher secondary schools. It should be noted here that many non-state institutions operate under the radar or unregistered from the state, and these numbers are likely to be influenced by non-state registration systems (or lack thereof) in different provinces.
Adopt-A-School Program schools are state schools that individuals from the private or civil society sector (such as NGOs, community-based organizations, educationalists, members of the armed forces, or concerned citizens) are encouraged to “adopt” and “improve” through school development plans, mobilization of school management, and overall supervision of the state school’s activities. Based on the Sindh Education Foundation’s (SEF) website, 582 state schools (accommodating over 131,000 students) from all 18 districts in Sindh have been supported by 102 “adopters”. Whereas this public-private partnership (PPP) model was initiated by the SEF (a semi-autonomous government body set up and directly funded by the government of Sindh), the program is gradually being replicated across other provinces as well, such as KP’s philanthropist program.
Non-state managed, state schools
Public School Support Program (PSSP) schools in Punjab and Education Management Organizations (EMO) program schools in Sindh are certain low-performing state schools which have been outsourced (in terms of management and operation) by each provincial government to non-state actors with the aim to “improve the quality” of education in these schools. Specifically, the Punjab Education Foundation (PEF), a semi-autonomous government body similar to the SEF, has outsourced over 1,800 schools to NGOs or community organizations, including organizations the foundation has worked with (43%), private school chains (31%), private individuals (17%), and private school owners (8%). The School Education and Literacy Department on the other hand (under the government of Sindh and based on the Sindh Public-Private Partnership Act 2010) has outsourced the management and operation of 110 state schools in Sindh to education management organizations (EMOs) from the non-state sector. Non-state organizations are selected based on a competitive, two-phased bidding process which assesses the actors’ technical capacity, proposed work plan, profile of the proposed professionals, and financial proposal presented. In each of these cases, the state retains the ownership of the school and land, schools are required to follow the provincial state curriculum, and any students attending these schools do not pay tuition fees.
Non-state funded, state schools
No information was found.
2.2 Non-state education provision
The non-state sector occupies over 40% of overall education in Pakistan. From primary up to high school level in particular, over 30% of total education enrolments appear to be in the non-state, private sector. These include enrolments in independent, non-state schools, as well as enrolments in non-state schools under PPP arrangements with various provincial governments in Pakistan.
Specifically, the federal government of Pakistan has established five semi-autonomous provincial foundations with the aim to enhance education access to disadvantaged groups through different PPP models with non-state actors in the country. The foundations define as “disadvantaged” children of lower socioeconomic status, children with special needs, minorities, out-of-school children, or children residing in remote and under-served areas. The largest of these foundations is the Punjab Education Foundation (PEF) which caters to over 2.1 million students in Punjab, followed by the Sindh Education Foundation (SEF – 505,743 students), the KP Elementary Education Foundation (EEF – 44,773 students), the Balochistan Education Foundation (BEF – 27,112 students), and the National Education Foundation (NEF) which caters to 6,251 students in Islamabad Capital Territory (ICT), Gilgit Baltistan (GB), and Azad Jammu and Kashmir (AJ&K).
Independent, non-state schools
Deeni Madaris are independent religious education institutions in Pakistan which are funded and managed by local communities, and provide formal Islamic religious education (from primary to higher secondary level) to children of lower socioeconomic status in Pakistan. Nearly all (97% of 32,272) of these institutions are privately owned, managed, and operated (with hardly any internal interference or funding from the state). Deeni Madaris follow their own curriculum (with no state consultation), which comprises of religious courses such as Quran, Hadith, and Fiqh, while there has been an emerging trend to introduce certain “mainstream” subjects. However, while many view Deeni Madaris as providing valuable education services to Pakistan, due to a growing perception throughout the years of these institutions inculcating extremist views to their graduates, the new government has announced that it plans to bring the majority of them under increased state control. According to the National Education Policy (2017), the federal government aims to “bridge the gulf between religious education and formal education system and integrate them for strengthening coordination among Madaris, Government and Private Institutions”.
Low-fee private schools (also referred to as low-cost private schools) are independently owned, operated, and managed non-state schools that cater to families of lower socioeconomic status through relatively lower cost and tuition fees (in comparison to elite private schools). These schools operate in all provinces in Pakistan, and tend to be particularly heterogeneous, as they can be operating for-profit or not-for-profit, and be managed by a variety of different non-state actors such as NGOs, communities, private individuals, faith-based organizations, or private school chains. Low-fee private schools can choose to either follow the provincial curriculum or their own independent curriculum, with some schools teaching in English Medium and others in Urdu. While the increased presence of low-fee private schools in Pakistan has been regularly reported in both government sources and academic research, no exact numbers or government statistics of this diverse set of independent private schools was found.
Elite private schools are for-profit independent non-state schools that charge particularly high tuition fees (in comparison to low-fee private schools) and usually teach in English medium. Many elite private schools in Pakistan are affiliated with international examination boards and do not follow the provincial curriculum. While the presence of elite private schools is documented in Pakistan, no exact numbers or statistics of these schools were found, as all non-state private schools (no matter their profit, value, or cost orientation) tend to be categorized under “private” schools in official government statistics.
State-funded (government-aided), non-state schools
Government-aided schools in Pakistan are mainly categorized into existing non-state schools which receive subsidies from the state (including community schools) and new non-state schools which have been established through state subsidies.
The PEF, SEF, BEF, and NEF have all introduced different PPP subsidy programs that operate based on per-child state grants distributed on a monthly basis to partner schools which are operated and managed by non-state actors (most commonly low-fee schools). Based on Pakistan’s education statisticis (2016-2017), the vast majority of non-state schools that are subsidized through per-child monthly grants by the state are the Foundation Assisted Schools (FAS), which cater to over 1.8 million students in all 36 districts in Punjab. The PEF provides financial and technical assistance to approximately 3,700 partner schools in both rural and urban areas in the province. The FAS program selects participating providers through a three-phased process, which includes inspection, school infrastructure, pupil-teacher ratio, and student academic performance.
Similarly, in the province of Sindh, Self-Assisted Schools, Existing School Support Program schools, and Middle and High School Program schools are all provided with grants and loans through the SEF.
Moreover, in ICT, the School Support Program schools are supported by the NEF in reaching disadvantaged groups through subsidies aiming to cover the cost of tuition fees, textbooks, utility charges, and staff salaries.
In addition to providing subsidies to existing non-state schools, the PEF and SEF have introduced New School Program schools (NSP – PEF) and Promoting Private Schools in Rural Sindh schools (PPRS – SEF), in which non-state actors (mostly NGOs and civil society organizations) are funded by the provincial government to establish and manage new schools in remote, under-served localities. The PEF has established 2,203 new schools in remote, under-served localities in all 36 districts in Punjab, while the SEF has established 1,398 new schools in remote areas in 18 districts in Sindh. The areas within which the new schools are established are selected based on the number of out-of-school children and distance to existing primary schools (at least within a one-kilometre radius).
Community schools are schools which are established in remote, rural areas and operated and managed by local communities (commonly teachers and parents) and NGOs. These schools are funded by the state and international donors (which provide free textbooks, staff salaries, tuition fees, and teacher training) while the local community donates the land and building for their establishment. Community school programs have been introduced in Khyber Pakhtunkhwa (Girls Community Schools), Azad Jammu & Kashmir (Community Model School Program), and Balochistan. Balochistan has established the largest number of community schools compared to the other provinces, with 633 schools catering to approximately 27,000 students. Each community school establishes a Parent or Village Education Committee which becomes responsible for managing school activities and daily operations. The curriculum taught within these schools is usually the provincial curriculum.
All schools under the programs outlined above which are subsidized by the provincial governments are independently operated and managed, and do not charge students tuition fees.
|
State subsidies to existing non-state schools |
|||
|
Program |
# of schools |
# of students enrolled |
Province |
|
Foundation Assisted Schools |
3,700 |
1.8 million |
Punjab |
|
Self-Assisted Schools |
918 |
157,752 |
Sindh |
|
Existing School Support Program |
N/A |
N/A |
Sindh |
|
Middle and High School Program |
158 |
48,628 |
Sindh |
|
School Support Program |
N/A |
N/A |
Islamabad Capital Territory |
|
State subsidies for the establishment of new non-state schools |
|||
|
Program |
# of schools |
# of students enrolled |
Province |
|
New School Program |
2,203 |
N/A |
Punjab |
|
Promoting Private Schools in Rural Sindh |
1,398 |
304,482 |
Sindh |
|
Community schools |
|||
|
Program |
# of schools |
# of students enrolled |
Province |
|
Girls Community Schools |
37 |
3,678 |
Khyber Pakhtunkhwa |
|
Community Model School Program |
44 |
4,000 |
Azad Jammu & Kashmir |
|
Balochistan Education Foundation |
633 |
27,000 |
Balochistan |
Contracted, non-state schools
No information was found.
2.3 Other types of schools
Homeschooling
Homeschooling appears to exist at a low percentage in Pakistan, however there were no exact numbers, monitoring mechanisms, or regulations found. Home-based learning was particularly encouraged by the federal government in the COVID-19 context, in which provincial education authorities became responsible for implementing no-tech (textbooks, workbooks), low tech (TV and radio learning programs), and high-tech (digital books, social media, smart phone apps) learning solutions (with particular attention in reaching the most vulnerable). During the country-wide school closures due to COVID-19, children have been provided with home-based learning material in addition to teacher or tutor home visits.
Market contracted (Voucher schools)
Voucher schools are non-state schools (most commonly low-fee schools) which certain eligible families of lower socioeconomic background can access through state-funded coupons (vouchers). Children that are eligible for vouchers are provided with free textbooks and can attend the voucher school tuition-free. Voucher schemes have been introduced in Punjab by the PEF (Education Voucher Scheme) to children aged 5-16 of lower socioeconomic background (0.5 million children) and in Khyber Pakhtunkhwa by the EEF (Iqra Farogh-e-Talim Voucher Scheme) to out-of-school children aged 5-16 (30,000 children). The NEF has additionally announced a voucher scheme project in June 2020 which aims to enroll approximately 31,000 children aged 5-9 to eligible non-state schools in Islamabad Capital Territory, Azad Jammu & Kashmir, and Gilgit Baltistan.
Unregistered/Unrecognized schools
The National Education Policy (2017) mentions that non-state schools in Pakistan include “registered and unregistered institutions”, including approximately 13% of Deeni Madaris that are operating unregistered from federal and provincial governments. However, while acknowledged in existence, these schools are not included in federal government statistics.
Instead, different provinces have taken action against unregistered private schools. In Punjab, the Education Ministry gave unregistered schools tight deadlines to get registered, or otherwise be subject to closure. This decision was suspended after strong resistance from private schools, with district education officers directed to speed up the process of registering these schools. In Rawalpindi, over 3,000 of the approximately 5,000 private schools were found to be operating unregistered from the state government. In Islamabad ICT, hundreds of private schools are being stated to be run without registration. In 2019, PEIRA closed several unregistered schools with the help of government administration and the police, while steps have been taken to introduce “One Window Operation” so that schools can apply for online registration. In Sindh, the Minister keeps records of the number of registered and unregistered schools.
The Ministry of Federal Education and Professional Training oversees the whole education system in Pakistan (including state and non-state provision) which was established to work towards national cohesion in education policymaking (through the National Education Policy 2017 and the development of national education standards) in view of Article 25A of the Constitution of the Islamic Republic of Pakistan 1973 in which the state is obliged to provide free and compulsory education to all children aged 5-16. The federal Ministry is also specifically responsible for the supervision, administration, and management of all state and non-state education in Islamabad Capital Territory. Since 2019, Deeni Madaris (which used to be under the supervision of the Ministry of Religious Affairs and Interfaith Harmony) are also governed by the Ministry of Federal Education and Professional Training (through the Directorate General of Religious Education and 16 regional offices) based on a Memorandum of Understanding signed by the federal Ministry and the Ittehad Tanzeemat tul Madaris Pakistan with the aim to “bridge the gulf between religious education and formal education system and integrate them for strengthening coordination among Madaris, Government and Private Institutions”.
Based on the 18th Amendment of the Constitution of the Islamic Republic of Pakistan (1973), education administration, management, and financing was fully devolved to the provinces and districts, which were required by law to establish a local education authority to supervise the provision and regulation of both state and non-state education in their territories.
The authorities specifically responsible for the governance and regulation of non-state actors at the district level are, in Islamabad Capital Territory, the ICT Private Educational Institutions Regulatory Authority (for pre-primary, primary, and secondary education levels) and the Higher Education Commission (for tertiary level). Although the Private Educational Institutions Regulatory Authority (PEIRA) is under the Ministry of Federal Education and Training, it only oversees non-state schools in ICT. In Sindh, the authority responsible is the Directorate of Inspections and Registration of Private Institutions (for all education levels) and the Public-Private Partner Node is responsible for the management and development of education PPPs, while in Balochistan, the BEF is responsible for regulating non-state actors at all education levels. Finally, in Punjab, the Registering Authority under the Government of Punjab is responsible for registering and regulating non-state institutions at all education levels. However, not all provinces have a regulatory system in place when it comes to non-state actors in education, as no relevant authority or Act regarding non-state actors was found in GB, KP, or AJ&K.
Vision: As Pakistan struggles with being the country with the second highest number of out-of-school children worldwide, the state relies on non-state involvement in education for support, which has led to such a sizeable presence of the sector (over 40% of overall provision in Pakistan). The National Education Policy (2017) specifically aims to “encourage and facilitate quality private sector education” stating that “private educational institutions are playing (an) important role for educational development in Pakistan”. This vision is equally reflected at the provincial level, with Sindh and Punjab both aiming to encourage increasing PPPs and private sector involvement in education provision, particularly in “expanding access to education”. The School Education Sector Plan And Roadmap for Sindh (2019-24) states that the “the contribution of private education and PPPs in service provision is also expected to contribute to improve access to education”, while the Punjab Education Sector Plan 2019/20 – 2023/24 envisions to “strengthen public-private partnership modalities to expand access to education”.
3.1 Regulations by distinct levels of education
Early childhood education (ECE) in Pakistan (commonly referred to as “Katchi”) covers ages 3-5, of which nearly half (49%) of total enrolments are in the non-state sector. Katchi class is considered part of primary education in the country, while the non-state sector is the only sector which provides separate educational institutions exclusively for ECE.
Registration and approval: See Multi-level regulations.
Licence: See Multi-level regulations.
Profit-making: See Multi-level regulations.
Taxes and subsidies: See Multi-level regulations.
Quality of teaching and learning
Curriculum and education standards: See Multi-level regulations.
Teaching profession: See Multi-level regulations.
Fee-setting: See Multi-level regulations.
Admission selection and processes: See Multi-level regulations.
Policies for vulnerable groups: See Multi-level regulations.
Quality assurance, monitoring and accountability
Reporting requirements: See Multi-level regulations.
Inspection: See Multi-level regulations.
Child assessment: See Multi-level regulations.
Sanctions: See Multi-level regulations.
Registration and approval: See Multi-level regulations.
Licence: See Multi-level regulations.
Water, sanitation and hygiene (WASH): All non-state education institutions in Pakistan from pre-primary to higher education level are required to provide clean water, sanitation, and hygiene facilities, as per the country’s WASH standards. Low-fee private schools are particularly criticized in the National Education Policy (2017) for not providing children and staff with adequate facilities.
Profit-making: See Multi-level regulations.
Taxes and subsidies: See Multi-level regulations.
Quality of teaching and learning
Textbooks and learning materials: The National Education Policy (2017) states that any textbooks used by state or non-state educational institutions from pre-primary to higher education level are required to comply with the National Textbook Standards, while any learning material used is prohibited from containing anything that is repugnant towards cultural and ethical values of Islam. At the provincial level, Islamabad Capital Territory states that any textbooks used by non-state educational institutions from pre-primary to secondary level must not be discriminatory towards Islam, Pakistan, or any minority community. At pre-primary to higher secondary level, the BEF in Balochistan requires all textbooks used to be listed and pre-approved upon registration. In the case of Sindh, any textbooks used will need to be prescribed and approved by the department of Education and Literacy, while any additional reading materials need to be approved by the Registering Authority. The only reference to textbooks used by non-state managed institutions in Punjab is that institutions are prohibited from encouraging students or parents to purchase textbooks from a particular provider.
Teaching profession: See Multi-level regulations.
Corporal punishment: Corporal punishment is prohibited from pre-primary to secondary education level in all schools in ICT and Sindh. According to the Islamabad Capital Territory Prohibition of Corporal Punishment Act passed in 2021, the provincial government has banned all forms of corporal punishment at formal and informal workplaces and in various educational settings (which include government, religious, and private institutions, whether registered or unregistered by the state), with penalties for any corporal punishment administered. However, this bill only applies to ICT and corporal punishment is not prohibited in non-state educational institutions in the other provinces in Pakistan. KP and Punjab have only prohibited corporal punishment to children aged 5-16 attending state schools.
Other safety measures and COVID-19: No information was found.
Fee-setting: See Multi-level regulations.
Admission selection and processes: See Multi-level regulations.
Policies for vulnerable groups: See Multi-level regulations.
Quality assurance, monitoring and accountability
School board: See Multi-level regulations.
Reporting requirements: See Multi-level regulations.
School inspection: See Multi-level regulations.
Student assessment: See Multi-level regulations.
Diplomas and degrees: See Multi-level regulations.
Sanctions: See Multi-level regulations.
In Pakistan, tertiary education starts after the higher secondary education level (at age 17), with the majority of enrolments (81%) being in state-managed and operated institutions. Tertiary education institutes (TEIs) can be classified into two main categories: degree-awarding institutions or chartered universities, colleges or institutes which are affiliated with degree-awarding institutions. According to the Guidelines for the Establishment of a New University or an Institution of Higher Education (2007), any degree-awarding institution with more than four departments may be eligible to obtain a university title.
The Higher Education Commission (HEC) was established in 2002 through the Higher Education Commission Ordinance (2002) as an autonomous, constitutionally established national institution responsible for overseeing and regulating both state and non-state TEIs in Pakistan. Similar to pre-primary, primary, and secondary education levels in Pakistan, the state strongly encourages non-state sector participation in tertiary education, as the government alone cannot cope with the huge demand.
Registration and approval: While non-state institutions usually apply to be registered with provincial education authorities (see section on multi-level regulations), if an institution wishes to be established in Islamabad Capital Territory, the application must be made with the HEC. In order to be considered for application by the HEC, the non-state institution is initially required to be registered as a legal entity (specifically a Foundation, Society, or Trust) by a sponsoring body such as the Companies Ordinance (1984) or Trust Act (1882). This requirement does not apply to state institutions. An authorized representative of this body will then submit a feasibility report to the Chairman of the HEC to initiate the application process. The institution must then additionally provide the HEC with proof of available premises, quality assurance mechanisms, administrative and academic staff, and programs or courses of study. If the required forms are found to be satisfactory, an Inspection Committee is appointed by the HEC to verify all the submitted documents and report back to the HEC. For more information, see Multi-level regulations.
License: Once receiving the report by the Inspection Committee, the HEC is responsible for recommending the case for grant of charter to the federal or provincial government. The charter will then be formally granted by the federal or provincial government. For more information, see Multi-level regulations.
Profit-making: There was no explicit prohibition of profit-making for non-state institutions found. Non-state institutions must be registered as a society/trust or a registered/constituted foundation under the relevant regulations of the Companies Ordinance/Trust Act/Societies Registration Act. For more information, see Multi-level regulations.
Taxes and subsidies: See Multi-level regulations.
Quality of teaching and learning
Curriculum and education standards: According to the Higher Education Commission Ordinance (2002), the HEC is required to guide non-state TEIs in designing their curriculum, while making sure that the programs offered provide sufficient content in social sciences, humanities, engineering, and technology. The Guidelines for the Establishment of a New University or an Institution of Higher Education (2007) additionally state that if a non-state TEI wishes to add any courses of study, these will need to be pre-approved by the HEC. Overall, the standard of courses taught at any non-state TEI must be consistent and comparable with other institutions in Pakistan. For more information, See Multi-level regulations.
Teaching profession: The HEC is responsible for determining that the qualifications and service terms and conditions of teaching staff are adequate. For more information, see Multi-level regulations.
Fee-setting: According to the Guidelines for the Establishment of a New University or an Institution of Higher Education (2007), any admissions fee or annual tuition fee charged by a non-state TEI must be specified upon its application to the HEC and therefore be pre-approved. Universities are given slightly more flexibility regarding their fee structure, which they are allowed to charge as they see fit. However, an increase in fees that exceeds the 10% annual increase will need to be pre-approved by the Chancellor of the university. Universities are additionally required to institute financial aid programs to students in need (however with no specification in number of programs or what constitutes a student “in need”). For more information, see Multi-level regulations.
Admission selection and processes: According to the National Education Policy (2017), there is an issue in access to non-state TEIs in Pakistan, as these institutions tend to charge especially high tuition fees, and be primarily located in urban settings. Whereas Article 37(c) of the Constitution of the Islamic Republic of Pakistan (1973) states that tertiary education be made “equally accessible to all on the basis of merit”, there is no particular policy in place for ensuring this enhanced access. The Guidelines for the Establishment of a New University or an Institution of Higher Education (2007) only state that at least 10% of students admitted to non-state TEIs be granted fee exemptions and scholarships on a “need basis”, without specifying what exact students this would cover. For more information, see Multi-level regulations.
Quality assurance, monitoring and accountability
Board: The Senate of a non-state TEI is required to consist of a Chancellor, a Vice-Chancellor, one member of government, four persons from society at large which are distinguished in particular fields, two academics, and one person nominated by the HEC. The Principal Officers of a university consist of a Chancellor, Vice-Chancellor, Deans, principals of constituent colleges, a Registrar, and a Treasurer.
Reporting requirements: Non-state TEIs and universities are responsible for putting an appropriate regulatory mechanism in place for regulating administrative and academic matters within the institution. They are additionally responsible for submitting annual reports to the HEC. For more information, see Multi-level regulations.
Inspection: The HEC conducts periodic rating exercises of non-state TEIs or universities, in which it ranks the institutions based on their performance, research and overall quality. The HEC or Provincial Education Department are additionally responsible for carrying out periodic inspections of non-state TEIs, in which they ensure that each institution is following the set guidelines and rules. For more information, see Multi-level regulations.
Assessment: While non-state TEIs and universities are free to determine their assessment and examination systems based on the courses provided, their assessment mechanism, examinations, and regulations need to be approved by the HEC upon registration. For more information, see Multi-level regulations.
Diplomas and degrees: Universities are the only institutions which are formally authorized to award degrees, diplomas, and certificates in Pakistan.
Sanctions: The HEC and Provincial Education Department are authorized to close an institution if it is found to be overlooking any laws or regulations. For more information, see Multi-level regulations.
3.2 Multi-level regulations
The following section covers regulations from pre-primary to secondary education in Islamabad Capital Territory in addition to regulations from pre-primary to higher education in the provinces of Balochistan, Sindh, and Punjab (distinguished in the text).
The provinces of Balochistan, Sindh, and Punjab all have registration and regulation acts for “privately managed” institutions that cover levels from pre-primary to higher education. According to these acts, an institution is considered privately managed if it not owned or managed by a local body, provincial or federal government, or by a body set up or controlled by the government. Balochistan follows the Balochistan Private Educational Institutions Registration and Regulation Authority Act (2015), Sindh follows the Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001, as amended in 2003), while Punjab follows the Punjab Private Educational Institutions (Promotion and Regulation) Ordinance (1984, as amended in 2017).
Registration and approval: All registration and licensing procedures from pre-primary to secondary level in Pakistan occur at the provincial level based on provincial acts and by-laws.
In Islamabad Capital Territory, all non-state managed educational institutions of pre-primary to secondary level are required to make an application to be registered with the Private Educational Institutions Regulatory Authority (PEIRA) under the The Islamabad Capital Territory Private Educational Institutions (Registration and Regulation) Act (2013). Applicants can be “any person or group of persons”, while the application must be accompanied by all relevant forms and documents (listed in the Act) in addition to the required registration fee. According to the Private Educational Institutions (Registration and Fee Determination) Rules, 2016, the minimum requirements for registration include the institution to be suitably located (complying with infrastructure standards), adequately staffed, and equipped, with a maximum teacher-student ratio of 1:30. Upon receival of the application, PEIRA nominates an Inspection Committee to inspect the institution, ensure the minimum standards are met, and submit recommendations to PEIRA within 30 days. In the case of the establishment and registration of Deeni Madaris from pre-primary to upper secondary level, an application must be made to one of the 16 regional offices established by the Directorate General of Religious Education (under the Ministry of Federal Education and Professional Training).
To register a non-state managed education institution in Punjab and Sindh from pre-primary to higher education level, it is mandatory for applicants (which are described as “any person”) to make an application (accompanied by all relevant documents and a registration fee) with the provincial Registering Authority (appointed by each local government) and comply with minimum infrastructure standards. In Sindh, this authority varies depending on the level of the institution, as pre-primary to secondary institutions are required to register with the Directorate of Inspection and Registration of Private Institutions, whereas intermediate and degree-awarding institutions must register with the Secretary at the Education and Literacy Department. In Balochistan, this application must be made to the BEF. The application is then sent to the District Committee (Punjab) or the Inspection Committee (Sindh) for inspection, after which a report is sent back to the Registering Authority for approval. In the case of Balochistan, the BEF is responsible for verifying all the required documents within the application. While there is no act that determines how non-state institutions get registered in Gilgit-Baltistan or AJ&K, based on the Gilgit Baltistan Education Strategy (2014), all registrations of non-state institutions from pre-primary to higher education level are managed at the district education office (a process which is assumed to be followed in AJ&K as well).
License: In Islamabad Capital Territory, PEIRA rejects or grants a registration certificate to operate a non-state institution from pre-primary to secondary level based on the recommendations submitted by the Inspection Committee. This registration (and accompanied fee) is then required to be renewed on an annual basis. Deeni Madaris are similarly granted a registration certificate to operate at pre-primary to secondary level by one of the 16 regional offices under the Directorate General of Religious Education.
In Sindh or Punjab (once receiving the submitted recommendations by the Inspection or District Committee and if the report is found to be satisfactory), the Registering Authority may grant a certificate of registration to operate a non-state institution from pre-primary to higher education level, which remains valid for three years. In Balochistan, the BEF grants the registration certificate, which is valid for two years.
Profit-making: Non-state educational institutions from pre-primary to higher education level in Pakistan may either operate on a non-profit or profit-making basis (National Education Policy 2017). However, the federal government states that non-profit institutions will be provided with additional incentives, while profit-making institutions are required to provide free education to at least 10% of their total student enrolments. At the provincial level, profit-making was only found to be mentioned in ICT, which states that non-state managed institutions from pre-primary to secondary level can operate either for-profit or not-for-profit.
Taxes and subsidies: The federal government of Pakistan has established five different foundations to assist non-state actors operating at pre-primary to secondary level in the establishment and maintenance of non-state schools in the country, which includes grants, loans, state infrastructure, community facilities, and any other related services. These include the PEF in Punjab, the SEF in Sindh, the EEF in KP, the BEF in Balochistan, and the NEF which promotes PPPs in ICT, GB, and AJ&K. Moreover, according to the National Education Policy (2017), non-profit institutions which are established and run by philanthropists will be provided with incentives from the government to establish institutions at all education levels (pre-primary to higher education). In the spirit of bringing Deeni Madaris in par with the national education system, the federal government additionally states that any Deeni Madaris which implements national education standards and follows the provisions of the Constitution will be “fully supported by the government” and provided with free textbooks.
At the provincial level, Sindh has issued a Public-Private Partnership Act (2010, amended in 2014) that has established a Departmental Public-Private Partnership Node responsible for identifying suitable projects at all education levels in Sindh from pre-primary to higher education and providing technical and financial support to non-state actors.
Quality of teaching and learning
Curriculum and education standards: All educational institutions from pre-primary to secondary level in Pakistan (irrespective of ownership) are required to adopt a curriculum that is based on the National Curriculum Framework, while all schools must adhere to the basic educational standards set by the federal government in terms of student assessment, learning materials, curriculum and textbooks (National Education Policy 2017). The Private Educational Institutions (Registration and Fee Determination) Rules, 2016 state that in this curriculum must generally follow the Federal Scheme of Studies, and must not teach any material that may be repugnant towards Islam or Pakistan ideology, or discriminatory towards any minority community. Similar rules apply to Deeni Madaris, which are required to ensure conformity with the national curriculum framework, in addition to introducing certain contemporary subjects. According to the National Curriculum Framework (2019), the federal government plans to introduce certain core, compulsory subjects to all educational institutions, including Islamic Studies, Pakistan Studies, and Social Studies. The medium of instruction at primary level must be the national language (Urdu) or local languages, with English taught as a compulsory subject from Grade 1.
At the provincial level, according to the Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001), the curriculum taught in any non-state managed institution from pre-primary to higher education level is required to ensure teaching of the Sindhi language in line with existing provincial law and should at least be on par with the provincial government-approved curriculum. The Ordinance additionally states that the institution is prohibited from teaching any subject which may be repugnant to the religious, moral, or ideological values of Islam. In the case of Balochistan, the BEF is responsible for developing a standard curriculum which is in line with the provincial curriculum in order to ensure relevance with the provincial scheme of studies. No specific information regarding curriculum was found in the Punjab Private Educational Institutions (Promotion and Regulation) Ordinance (1984).
Teaching profession: All teachers employed in both state and non-state educational institutions in Pakistan from pre-primary to higher education level are required to comply with the National Professional Standards for Teachers, which include standardized certification and accreditation procedures and teacher training programs (which are also applicable to Deeni Madaris). There are common minimum requirements of academic and pre-service teacher education qualifications for employment of teachers in the public, private and private-public-partnership schools. However, employment rules are not applicable to non-state educational institutions. The 2017 policy aims for “uniformity in designations, qualifications, salary structures and professional growth...of teaching personnel across the country”. The employment authority for all teachers is set at the provincial level, with various school personnel employment policies and practices which the policy specifies apply to “public sector schools of provinces”.
At the provincial level, PEIRA is responsible for checking the qualifications of any teaching staff hired within a non-state institution from pre-primary to secondary level in Islamabad Capital Territory, as well as their terms and conditions of services (with salaries required to be approved). Moreover, PEIRA works for continuous teacher development through the Federal College of Education or any other teacher training institute. In the case of non-state educational institutions from pre-primary to higher education level, the BEF is responsible for checking the qualifications and service terms and conditions of the teaching staff employed in non-state institutions in Balochistan, as well as promoting pre-service and in-service training. In the case of non-state institutions operating in Sindh, there is no specific reference to teacher qualifications, only that the provincial government must ensure that any teacher salary is commensurate with the fee structure of the institution. The Punjab Private Educational Institutions (Promotion and Regulation) Ordinance (1984) provides no information on teachers employed in non-state institutions in Punjab.
Fee-setting: According to the National Education Policy (2017), all “tuition fees fee and funds charged by elite private educational institutions at all levels will be rationalized”.
At the provincial level, the fees to be charged by a non-state institution from pre-primary to secondary level in ICT are determined by PEIRA based on certain transparent criteria that include a cost methodology and financial model. No institution which is managed by a non-state actor is allowed to charge any additional fees unless pre-approved by PEIRA through a Fee Increase Proposal. All fees must be charged on a monthly basis, and any services provided are required to commensurate with the fee being charged.
At pre-primary to higher education level, Balochistan, Sindh, and Punjab all have regulations on the fee-setting of non-state institutions. According to the Balochistan Private Educational Institutions Registration and Regulation Authority Act (2015), the Fee Regulatory Committee (operating under the BEF) determines the admissions fee, monthly tuition fee, security fee, and any other fee to be charged by non-state managed institutions. The BEF is additionally responsible in ensuring that any fee being charged is based on the quality provided by the institution. In the case of Sindh, the Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001) states that any fees charged must be recommended by the Inspection Committee and approved by the provincial government upon registration. Any additional fees will need to be approved by the Registering Authority. Finally, based on the Punjab Private Educational Institutions (Promotion and Regulation) Ordinance (1984), the fees charged by any non-state institution must be fixed, and are not allowed to increase beyond 5% every year (unless granted formal approval by the provincial government). This Ordinance was amended in 2016 to further regulate the fee structure of non-state institutions and to prohibit schools from compelling parents to pay extra fees for uniforms and textbooks from a particular provider. However, as this was still enforced, the final amendment in 2017 increased the penalty to schools if charging these fees.
Admission selection and processes: The National Education Policy (2017) states that all profit-based educational institutions (of all levels in Pakistan) are required to provide free education to “deserving children” at a rate of at least 10% of their total enrolment.
Based on the ICT Right to Free and Compulsory Education Bill 2011, the Punjab Free and Compulsory Education Act 2014, and the Sindh Right of Children to Free and Compulsory Education Bill 2013, 10% of total enrolment in each class in non-state managed institutions from primary up to higher secondary level must consist of socially or economically disadvantaged groups (of which all receive education tuition-free), known as the Free-Ship Rules. The Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001) was the only act found which additionally requires non-state institutions from pre-primary to higher education level to enroll at least 10% of students from economically and socially disadvantaged groups tuition-free.
Moreover, while ICT, Punjab, Sindh, Balochistan, and Khyber Pakhtunkhwa have all established acts that aim to ensure the implementation of Article 25A of the Constitution of the Islamic Republic of Pakistan (1973), only the acts passed in ICT, Punjab, and Sindh specifically refer to non-state institutions. According to the ICT Right to Free and Compulsory Education Bill 2011, the Punjab Free and Compulsory Education Act 2014, and the Sindh Right of Children to Free and Compulsory Education Bill 2013, no child or parent applying to a non-state managed school which provides education from primary to higher secondary level must be subject to any form of admissions screening procedure by the school (other than academic merit), which, in the case of ICT, is punishable with a fine of up to 50,000 IRP (678.33 USD).
While regulations concerning admission selection procedures in non-state institutions are established in regard to primary and secondary education in ICT (Right to Free and Compulsory Education Bill 2011), Punjab (Punjab Free and Compulsory Education Act 2014), and Sindh (Right of Children to Free and Compulsory Education Bill 2013), no act was found which prohibits pre-primary or degree-awarding institutions from applying screening selection processes. Only the Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001) requires non-state institutions at all education levels (from pre-primary to higher education) to provide extra scholarships and fee concessions to academically-deserving students.
Policies for vulnerable groups: Federal and provincial governments in Pakistan have initiated various voucher schemes for the education of out-of-school children in non-state educational institutions. Moreover, there have been numerous programs in different provinces (see section on provision) that aim to support non-state educational institutions in reaching disadvantaged groups (including children residing in rural areas, out-of-school children, and community programs targeted towards girls). These programs provide non-state schools with government subsidies to cover the tuition fees and textbooks for these different groups. In the case of Deeni Madaris, the National Education Policy (2017) states that free accommodation, basic necessities, and textbooks are provided to all students by the federal or provincial governments. Finally, the policy states that all educational institutions (both state and non-state, including Deeni Madaris) must launch special programs for the eradication of illiteracy.
Quality assurance, monitoring and accountability
Board: School management from pre-primary to secondary level must be decentralized towards the school and the community (National Education Policy 2017).
In Islamabad Capital Territory, according to the Private Educational Institutions (Registration and Fee Determination) Rules, 2016, all institutions that are managed by non-state actors from pre-primary to secondary level must have an established Managing Committee or Board of Directors, in addition to a Parent-Teacher Syndicate. The Sindh Private Educational Institutions (Regulation and Control) Rules similarly require the establishment of a Management Board (comprised by members of government, civil society, and private educational institutions), as well as a Parent-Teacher Association at all educational institutions from pre-primary to secondary level.
Reporting requirements: All non-state educational institutions in Pakistan remain accountable to the bodies responsible for their quality assurance. In Islamabad Capital Territory, all non-state educational institutions from pre-primary to secondary level are required to submit annual audit reports to the PEIRA, in addition to maintaining up-to-date records of their accounts, teacher salaries, admissions, and teacher attendance. In Sindh and Balochistan, non-state educational institutions from pre-primary to higher education level must similarly submit annual audit reports to their concerned authorities (the provincial government in Sindh and the BEF in Balochistan), in addition to information on their activities and progress. Deeni Madaris receiving any financial assistance from the provincial government are additionally required to be transparent regarding their income and expenditure (preparing and submitting reports when requested).
Accountability mechanisms are additionally in place in different provinces for non-state educational institutions that receive funding from the state. For instance, in Punjab, non-state schools that are under the FAS, EVS, and NSP programs continue to receive funding based on certain pre-defined indicators in the Memorandum of Understanding, which include the schools’ performance and student learning outcomes in the annually administered Quality Assurance Test (QAT). The schools are also required to comply with increased reporting requirements (compared to unaided schools).
Inspection: Any non-state managed institution operating in Islamabad Capital Territory from pre-primary to secondary education level is subject to regular inspections by PEIRA or the federal government to ensure minimum quality standards are met. The institution’s performance is additionally evaluated and rated (A, B, or C) every two years based on a list of quality factors.
Non-state managed institutions operating at pre-primary to higher education level are all subject to regular inspections by the BEF (in Balochistan), and the provincial government and Registering Authority in Sindh and Punjab. In Punjab, non-state institutions that are under the FAS, EVS, and NSP programs are strongly monitored and surveilled by the PEF (which conducts additional surprise or informed school visits).
Assessment: Boards of Examinations are established in different provinces to conduct examinations for both state and non-state educational institutions. As religious education is being integrated with the national education system, Deeni Madaris are also required to be affiliated with national examination boards (National Education Policy 2017).
At the provincial level, Islamabad Capital Territory and Balochistan allow non-state educational institutions to be additionally affiliated with external examination boards, but these need to be registered and pre-approved by the PEIRA (in Islamabad Capital Territory) and the BEF (in Balochistan).
Diplomas and degrees: Any student leaving a non-state institution in In Islamabad Capital Territory (from pre-primary to secondary level) must be issued with an institution leaving certificate. Students will not be allowed to be admitted to any other institution (whether state or non-state) without this certificate.
There is no reference to education level transitions in the Balochistan Private Educational Institutions Registration and Regulation Authority Act (2015) or the Punjab Private Educational Institutions (Promotion and Regulation) Ordinance (1984). The Sindh Private Educational Institutions (Regulation and Control) Ordinance (2001) only mentions that students in pre-primary and primary must be admitted based on their birth certificate, whereas admission to any other classes must be made based on the certificate obtained from the student’s previous school or institution.
Deeni Madaris have traditionally issued different certificates (Mutawassita, SanawiyaA’ma and SanawiyaKhasa) and degrees (A’liya and A’lamiyya) compared to the national education system, which the National Education Policy (2017) aims to make equivalent to all other diplomas and certificates issued in the country.
Sanctions: Non-state educational institutions in Islamabad Capital Territory, Balochistan, Sindh, and Punjab are all subject to sanctions of the requirements of registration are not met or if any of the provisions of their governing acts are not complied with.
In Islamabad Capital Territory (at pre-primary to secondary level), PEIRA has the authority to impose fines or cancel an institution’s certificate of registration (and close the school down) if the management and instruction of a non-state institution are not found to be at the prescribed standards set out in the Private Educational Institutions (Registration and Fee Determination) Rules, 2016 and The Islamabad Capital Territory Private Educational Institutions (Registration and Regulation) Act (2013).
At pre-primary to higher education level, the BEF in Balochistan has the authority to suspend or cancel an institution’s registration if the management and instruction are not found at a prescribed standard, as set out in the Balochistan Private Educational Institutions Registration and Regulation Authority Act (2015), while the provincial government in Sindh and Punjab may similarly cancel an institution’s registration certificate and order the closure of the institution if the quality is not found to be at the prescribed standards and the institution is not compliant with national or provincial laws. Finally, if any Deeni Madaris fails to register under the Ministry of Federal Education and Training, the federal government has the authority to shut them down or cancel their registration certificate (in the case of registered institutions that are not complying with the minimum standards).
There are also sanctions in place in the case that schools receiving funding from the provincial government fail to comply with the minimum requirements. In the EVS and FAS programs in Punjab, if the schools fail to pass the QAT two consecutive times, their continuity in the PPP program is terminated (and they no longer receive government funding).
3.3 Supplementary private tutoring
Pakistan has witnessed a rapid growth of the private tuition industry. According to the Annual Status of Education Report (2020), a significantly higher proportion (22%) of students attending non-state private schools in rural areas in Pakistan (aged 5-16) engage in private tuition classes compared to students attending state schools (6%). While no information was found regarding national or urban private tuition statistics, these numbers are likely to increase in urban settings in Pakistan as the private tuition industry tends to be particularly prevalent in urban areas. When comparing rural settings in different provinces, the KP Newly Merged Districts (35%) and Punjab (32%) appear to have the highest numbers of students in non-state private schools engaging in private tuition. Private tuition classes can either be conducted one-on-one, or in larger private tuition academies in the country. It has additionally been reported that the industry is predominately supplied by teachers from non-state private schools.
Private tutoring is mainly regulated by each provincial government, with specific regulations found in ICT and Balochistan which consider “private tuition centers” a type of “private educational institution” which is regulated similar to non-state schools under their respective education authorities.
In ICT, private tuition centers are required to be registered under PEIRA (similar to private educational institutions). Centers may only operate from the middle education level and above and are required to comply with the minimum infrastructure standards that are applicable to non-state schools, as stated in the The Islamabad Capital Territory Private Educational Institutions (Registration and Regulation) Act (2013). In Balochistan, private tuition centers are similarly registered as private educational institutions under the BEF and are required to conform to the minimum building standards, under the Balochistan Private Educational Institute Registration and Regulation Authority, Act, 2015.
Financial operation and quality
Both ICT and Balochistan regulate the fees levied and curriculum offered in private tuition centers (ensuring that it does not diverge greatly from the school curriculum and conforms to minimum standards). Moreover, the BEF and PEIRA regulate all fees levied by private tuition centers (with a fixed rate provided) and require centers to submit annual audit accounts. Finally, similar to non-state schools, private tuition centers are subject to regular inspections by each authority to ensure minimum standards are maintained (with fines prescribed for violation of standards).
While teachers are not prohibited from providing private tutoring lessons, the PEIRA and BEF both regulate their qualifications and terms and conditions of service.
