Customer Complaint Policy (Pakistan)

A Customer Complaint Policy in Pakistan lodges the matter formally, identifying the parties, the facts and the outcome the complainant seeks.

The Contract Act 1872 (Act IX of 1872) is the primary legislation governing commercial contracts in Pakistan. Section 73 of the Contract Act 1872 provides that a party who suffers loss due to breach of contract is entitled to compensation — a customer whose complaint arises from a seller's failure to deliver goods or services as contracted has a legal right to remedies under Section 73. The Customer Complaint Policy is the mechanism through which businesses honour their contractual obligations by providing accessible redress for genuine grievances before disputes escalate to litigation.

Sector-specific consumer protection frameworks complement the general law of contract. The Punjab Consumer Protection Act 2005, the Khyber Pakhtunkhwa Consumer Protection Act 1997, the Sindh Consumer Protection Act 2014, and the Balochistan Consumer Protection Act 2003 establish consumer courts, consumer rights, and complaint procedures for residents of each province. These Acts empower Consumer Courts to award compensation, order refunds, require product replacement, and impose fines on sellers who deceive or defraud consumers.

The State Bank of Pakistan (SBP) imposes thorough customer complaint handling requirements on banks and financial institutions regulated under the Banking Companies Ordinance 1962. The SBP's Consumer Protection Framework requires every bank to maintain a designated complaints officer, a written complaint policy available to all customers, a complaints register, and internal resolution timelines — with escalation to SBP's Consumer Protection Department where internal resolution fails. The SBP Banking Mohtasib (Ombudsman), established under the Banking Companies Ordinance 1962, provides a free alternative dispute resolution mechanism for banking customers.

The Pakistan Telecommunication Authority (PTA) requires all licensed telecom service providers — mobile operators, internet service providers, and payphone operators — to maintain published customer complaint procedures under the Pakistan Telecommunication (Re-organisation) Act 1996 and the PTA's Consumer Protection Regulations. Similarly, the National Electric Power Regulatory Authority (NEPRA) under the Regulation of Generation, Transmission and Distribution of Electric Power Act 1997 mandates complaint handling procedures for electricity distribution companies (DISCOs), and the Oil and Gas Regulatory Authority (OGRA) under the OGRA Ordinance 2002 requires gas utilities to maintain complaint registers and resolution systems.

The Securities and Exchange Commission of Pakistan (SECP) under the Companies Act 2017 and its regulated entity frameworks requires insurance companies, non-banking finance companies, and listed companies to implement investor and customer grievance redress mechanisms. The SECP's Complaint Portal receives complaints against regulated entities and monitors their resolution. The Insurance Ombudsman and the Mohtasib (Wafaqi Mohtasib/Federal Ombudsman) established under the Wafaqi Mohtasib (Ombudsman's) Establishment Order 1983 provide additional escalation pathways for unresolved customer complaints against federal government agencies and public utilities.

A Customer Complaint Policy in Pakistan is required by regulation for businesses in supervised sectors and is best practice for all customer-facing enterprises seeking to build trust, reduce disputes, and comply with applicable legal obligations.

A Customer Complaint Policy is needed when a bank or microfinance institution regulated by the State Bank of Pakistan (SBP) must comply with the SBP's Consumer Protection Framework, which requires every supervised financial institution to have a written, published complaint policy, a designated complaints officer, internal resolution timelines (typically 10 working days for routine complaints), and escalation procedures to the SBP's Consumer Protection Department for unresolved matters.

A Customer Complaint Policy is required when a telecom operator licensed by the Pakistan Telecommunication Authority (PTA) must comply with PTA's Consumer Protection Regulations, which mandate a published complaint procedure for mobile, broadband, and fixed-line customers, maximum response timelines, and escalation to PTA's complaint resolution system where the operator fails to resolve complaints internally.

A Customer Complaint Policy is needed when an insurance company licensed by the Securities and Exchange Commission of Pakistan (SECP) under the Insurance Ordinance 2000 must demonstrate to SECP examiners that it has adequate policyholder grievance redress mechanisms meeting SECP's minimum standards for complaint handling.

A Customer Complaint Policy is required when an e-commerce platform or online marketplace registered in Pakistan wants to meet the expectations of international payment processors (such as Visa, Mastercard, and PayPal), which require merchants to have a published complaint and dispute resolution policy as a condition of accepting card payments.

A Customer Complaint Policy is needed when a consumer goods company, retail chain, or food business regulated by the Punjab Food Authority, the Sindh Food Authority, or the Balochistan Food Safety and Halal Food Authority wishes to establish a structured mechanism for handling product quality complaints, recalls, and refunds, reducing the risk of regulatory enforcement action and reputational damage.

A Customer Complaint Policy is required when a healthcare provider regulated by the Pakistan Medical Commission (PMC) under the Pakistan Medical Commission Act 2020 or a hospital accredited by the Pakistan Health and Nutrition Policy framework needs to document its patient grievance procedures for accreditation and regulatory compliance purposes.

A thorough Customer Complaint Policy in Pakistan under the Contract Act 1872 and applicable sector-specific regulations must contain the following essential elements.

Scope and Purpose: The policy must state its purpose — to provide a fair, accessible, and timely mechanism for customers to raise complaints about products, services, or conduct — and its scope, identifying which products, services, and customer categories are covered. The policy should affirm the company's commitment to treating all complaints seriously and using complaint data to improve service quality.

Definition of Complaint: The policy must define what constitutes a complaint — typically, any expression of dissatisfaction by a customer about a product, service, employee conduct, billing, or delivery, whether made verbally, in writing, by email, through the company website, or via social media — and distinguish it from a routine service request or enquiry. Clear definitions prevent front-line staff from improperly reclassifying genuine complaints as routine queries to suppress complaint statistics.

Complaint Channels: The policy must list all channels through which customers can submit complaints: in-person at branches or offices; by telephone to a dedicated complaints number; by written letter to the registered business address; by email to a specified complaints email address; through an online complaint form on the company website; through the company's mobile application; and via social media platforms (Facebook, Instagram, X/Twitter). Pakistan's SBP Consumer Protection Framework requires banks to maintain at least a helpline, email, and written channel.

Acknowledgement Timelines: The policy must state the maximum time within which the company will acknowledge receipt of a complaint — typically one working day for electronic complaints and three working days for postal complaints. Acknowledgement must confirm the complaint reference number, the name of the handling officer, and the expected resolution timeline.

Investigation and Resolution Timelines: The policy must specify the internal resolution timeline — the SBP requires banks to resolve routine complaints within 10 working days and complex complaints within 45 working days; PTA regulations require telecom operators to resolve complaints within 7 working days. The policy should define what constitutes a resolved complaint — a mutually agreed outcome, a refund, a replacement, an explanation — and the form in which the resolution will be communicated to the customer.

Escalation Procedure: The policy must describe the internal escalation path — from front-line staff to a supervisor, then to the complaints officer, then to senior management — and the external escalation options available to the customer if internal resolution fails. External escalation options include: the SBP Banking Mohtasib for banking complaints; PTA's complaint management system for telecom complaints; SECP's complaint portal for insurance and capital market complaints; provincial Consumer Courts under the provincial Consumer Protection Acts; the Wafaqi Mohtasib for federal government services; and civil courts under the Code of Civil Procedure 1908.

Record Keeping: The policy must require maintenance of a complaints register — recording the complaint reference number, date received, channel, description, steps taken, resolution, and closure date. The SBP requires banks to maintain complaint records for at least five years. Records are essential for regulatory inspections, trend analysis, and staff training.

Confidentiality and Non-Retaliation: The policy must confirm that customer information provided in complaints will be treated confidentially under the company's data protection practices and consistent with PECA 2016 obligations, and that customers will not face any adverse action (such as termination of service) for making a complaint in good faith.

Staff Training and Accountability: The policy must assign responsibility — naming the Complaints Officer or Customer Experience Manager responsible for implementation — and commit to regular staff training on complaint handling procedures, including sensitivity training for handling distressed or vulnerable customers.

Policy Review: The policy must state the review period — typically annually — and the process for updating the policy in response to regulatory changes, complaint trend analysis, and business developments. Forms-legal.com provides this Customer Complaint Policy (Pakistan) template to help businesses of all sectors implement compliant, customer-centric grievance procedures meeting SBP, PTA, SECP, and provincial consumer protection standards.

Under the Companies Act 2017, the Securities and Exchange Commission of Pakistan (SECP) maintains the register of Pakistani companies. Section 16 of the Companies Act 2017 governs company incorporation. The Contract Act 1872 governs general contractual obligations. The Federal Board of Revenue (FBR) administers corporate tax under the Income Tax Ordinance 2001. The High Courts (Lahore, Sindh, Peshawar, Balochistan, Islamabad) have original and appellate jurisdiction.