PAKISTAN presented its first Nationally Determined Contributions in 2016, updating it in 2021 and most recently submitting NDC 3.0 last month. The latest asks for $565.7 billion in climate finance. Implementation of the first two? Marginal. Catastrophic floods in 2021 and 2025 affecting all provinces proved the point. As climate change accelerates, our resilience erodes further. The reason is simple: Pakistan’s NDCs were top-down federal documents for bottom-up provincial subjects.

Constitutional reality: The 18th Amendment devolved climate-relevant sectors to the provinces. Agriculture, water management, urban planning, disaster response, irrigation, land use, forestry, infrastructure development and construction standards are all provincial subjects. These are where climate impacts hit and where adaptation must happen.

The first two NDCs were federal exercises. The climate change ministry reached out to the federal and provincial departments, set national targets and submitted documents to the UNFCCC. The provinces were not asked to develop their own NDCs, prepare implementation strategies, estimate financial needs or align budgets with climate commitments. Federal pledges were disconnected from provincial capacity.

Provincial development budgets total Rs2,869bn in 2025-26 — nearly three times the federal PSDP. These resources proceed without systematic alignment with NDC commitments. The machinery implementing development has never been oriented towards systematic climate action.

Case study in federal-provincial disconnect: The 2021 and 2025 floods exposed how federal NDC commitments fail without provincial implementation. Both the 2016 and 2021 NDCs pledged climate-resilient agriculture, improved drainage infrastructure and enhanced disaster preparedness. Yet when calamity hit, provincial responses revealed complete disarray.

Sindh’s agriculture department had no plans for salt-tolerant crop varieties despite federal commitments. Its irrigation department hadn’t climate-proofed canal systems. Provincial disaster management lacked pre-positioned resources, early warning integration, and evacuation protocols at scale. When the floods hit, Sindh requested emergency federal intervention rather than implementing existing NDC adaptation measures.

The floods exposed how federal NDC obligations fail without provincial implementation.

Punjab’s drainage systems remained unchanged despite years of federal flood resilience pledges. Its irrigation department continued operating colonial-era infrastructure. Provincial planning had approved countless urban development PC-1s in flood-prone areas without EIAs or climate screening. Punjab’s own climate vulnerability assessment mandated by federal policy had never been completed.

Balochistan’s water infrastructure couldn’t handle extreme rainfall because its planning had never developed the watershed management systems promised in federal NDC documents. KP’s disaster preparedness was compromised because the provincial DMA had received neither the budget nor the institutional mandate to implement federal adaptation commitments. The floods revealed that federal ministries can pledge climate action to the UNFCCC, but only provincial departments can deliver it.

Provincial subjects, federal commitments: Agriculture is provincial. Sindh controls 5.4 million acres of irrigated land supporting cotton, rice, sugarcane. Punjab manages 14m acres producing wheat, rice and cotton. Each requires distinct climate strategies. Sindh needs salinity management and heat-resistant varieties. Punjab needs water-efficient irrigation and crop diversification. Federal NDC commitments to ‘climate-resilient agriculture’ mean nothing without the provinces developing costed plans, their irrigation departments modernising infrastructure and their budgets funding implementation.

Urban resilience is provincial and municipal. Sindh faces coastal flooding, extreme heat and inadequate drainage. Punjab confronts air quality crises, urban heat islands and monsoon flooding. Cities experience industrial water pollution and heat stress. Each area needs its own nuanced resilient-development priorities.

Political economy: Different political parties entrenched in different provinces create implementation barriers rarely acknowledged in federal NDC documents. Divergent political priorities make provincial implementation negotiable rather than automatic. The federal government has prioritised emergency cash disbursements over provincial NDC implementation capacity. This treats disaster response and disaster prevention as separate rather than integrated interventions.

Planning departments in Sindh and Punjab approve countless PC-1s annually without reference to federal NDC targets, while provincial finance departments don’t track climate-relevant spending or organise budgets around NDC priorities. The World Bank and ADB have committed over $60bn since 2016, much of the amount flowing through provincial projects, yet systematic alignment with NDCs priorities is absent without the provinces owning the commitments.

Provincial ownership: Provincial NDCs would need each province to assess specific vulnerabilities and develop locally led responses. For example, Sindh would quantify coastal inundation risk, estimate costs for mangrove restoration and coastal defences, and budget for heat action plans in Karachi, Hyderabad and Thatta. Punjab would assess water scarcity in Bahawalpur and Multan districts and budget for urban heat mitigation in Lahore and Faisalabad. Balochistan would map drought vulnerability, estimate small-scale water harvesting needs and budget for rangeland management. KP and GB would assess GLOF risk and budget for disaster preparedness in the northern districts.

Provincial finance departments would tag climate expenditures in annual budgets. NDC alignment for PC-1 approvals would be mandatory. Citizens’ groups have already begun to hold provincial governments accountable for climate failures, including Sindh for Karachi’s heat deaths and Punjab for Lahore’s poor air quality.

Path forward: The Pakistan Climate Change Council must require each province to develop its own NDCs aligned with the national framework and based on provincial stakeholder consultation. Adaptation and mitigation strategies must have clear budgets, timelines, baselines and indicators. The Planning Commission will need to take the lead in climate-proofing the PSDP. The Economic Affairs Department must engage with the World Bank and ADB to align their $1.5-2bn annual portfolios with provincial NDC implementation.

Without provincial NDCs backed by provincial implementation strategies and provincial budgets, federal climate commitments to the UNFCCC will continue to be contradicted by the provincial planning departments and undermined by provincial budget allocations. The third federal NDC will fail like the first two did unless it catalyses provincial ownership. That is the lesson Pakistan must finally learn.

The writer is a climate change and sustainable development expert.

Published in Dawn, October 9th, 2025