On the seventh International Day of Clean Air for blue skies, Fair Finance Pakistan (FFP), in collaboration with the University of California, Davis Air Quality Research Center (AQRC), called for Pakistan to move from policy ambition to time-bound, financed implementation of the National Clean Air Policy (NCAP). The partners stressed that clean-air finance is not a synonym for broad green investment: public and private capital should support technologies and transition measures that demonstrably reduce population exposure to PM2.5 and emissions of particulate matter and its precursors.
The call accompanies the joint policy brief, “Air Pollution: A Solvable Problem — Findings and Recommendations for the National and Punjab Clean Air Policies,” released by FFP and UC Davis AQRC. Assessing the National Clean Air Policy (2023) and the Punjab Clean Air Policy (2023) against the 2021 WHO Global Air Quality Guidelines, the review finds that Pakistan has moved from policy adoption to the harder test of delivery. It identifies nine structural gaps in the national framework and five in Punjab’s framework.
A first-order gap is the absence of a nationally consistent, quality-assured baseline for population-weighted PM2.5 exposure, supported by updated emissions inventories and source-apportionment studies for priority airsheds. Without that foundation, targets, sector selection, investment eligibility and claims of impact cannot be assessed credibly.
The NCAP models potential PM2.5-emission reductions of 38 percent by 2030 and 81 percent by 2040 against its baseline scenario. FFP proposes a public delivery compact: by June 2027, establish the national PM2.5 baseline and publish updated emissions inventories and source-apportionment plans for priority airsheds; by December 2027, issue costed sector implementation plans with named institutions, annual milestones and financing pipelines; from 2027 onward, publish annual progress against exposure, emissions, compliance and financing indicators; and in 2030, independently review performance and reset the pathway to 2040 where necessary.
Airsheds must shape governance. The Punjab Clean Air Plan’s analysis indicates that, in 2021, 53 percent of Punjab’s PM2.5 originated within the province, 9 percent came from other Pakistani provinces and 13 percent from other countries. Local enforcement, interprovincial coordination and regional cooperation are therefore complementary—not competing—responsibilities.
Financing must be tied to verified air-quality outcomes. A renewable-energy or energy-efficiency investment may be environmentally beneficial, but it should not automatically be labelled a clean-air investment. Eligibility should require a credible baseline, quantified reductions in PM2.5 or relevant precursors—including SO2, NOx, VOCs, ammonia and black carbon—safeguards against pollution shifting, and monitoring, reporting and verification proportionate to the project.
On the release, Asim Jaffry, Country Programme Lead, Fair Finance Pakistan and lead author, stated: “Pakistan does not need to choose between economic development and breathable air. The real choice is whether we keep paying for pollution after the damage is done or finance prevention and a just industrial transition before those losses deepen. Clean air must become a measurable public duty and an investable national priority. That means financing proven emission-control and transition technologies—not simply rebadging conventional green investment—and ending finance that locks firms and transport systems into polluting assets.”
Air pollution in Pakistan is a year-round public-health and economic emergency, not a seasonal smog problem. FFP estimates that around 43.6 million people—nearly a fifth of the population—live within 50 kilometres of fossil-fuel power plants, including approximately 15 million women, 5.5 million children and 2.8 million older people. Exposure erodes health, learning and productivity. The NCAP’s modelling indicates that full implementation of its priority measures could avoid nearly 129,500 premature deaths annually by 2040, generate about USD 24.6 billion in annual health benefits, and reduce PM2.5 emissions by 38 percent in 2030 and 81 percent in 2040 relative to the baseline scenario.
Huma Iqbal, IVLP (Air Quality) alumna and co-author of the brief, said: “Air pollution in Pakistan is no longer a seasonal inconvenience; it is a year-round public-health emergency. The burden is deeply unequal: women and girls, young children, workers and low-income households living near roads, kilns, industrial clusters and power plants face higher exposure while having the fewest resources to protect themselves. Clean-air implementation must therefore be designed around exposure reduction and a just transition, not technology deployment alone.”
The World Bank’s Pakistan Country Climate and Development Report estimates that air pollution and lead exposure together impose economic losses equivalent to at least 6.5 percent of GDP each year. A subsequent World Bank appraisal for Punjab reports average annual PM2.5 exposure of about 52 micrograms per cubic metre across the province—more than ten times the WHO annual guideline of 5 micrograms—with annual averages of 110–130 micrograms measured in central Lahore.
Responding to the scale of these losses, Nadeem Iqbal, CEO, TheNetwork for Consumer Protection, and Council Member, Consumers International, said: “The UN Guidelines for Consumer Protection recognise the responsibility of businesses and industry to contribute to sustainable consumption and to minimise the environmental impacts of their activities. Businesses should be able to commit to reducing emissions from their operations, supply chains and products, and to supporting cleaner air in the communities where they operate.”
“Air pollution’s deeper damage is to human capital. Severe smog has repeatedly disrupted schooling for millions of children, while sustained exposure impairs health and cognitive development. These impacts deepen inequality. Financing clean air today is more than an environmental investment; it is an investment in Pakistan’s productivity and social mobility,” said Dr Abid Burki, Professor Emeritus of Economics at LUMS.
The brief recommends legally enforceable, sector-specific emission-reduction milestones anchored in the WHO guideline and its interim targets; named federal, provincial and municipal responsibilities; stronger provisions for short-lived climate pollutants such as black carbon and methane; and airshed institutions capable of coordinating action across jurisdictions. It also calls for pollution-risk due diligence and disclosure by financial institutions and major corporate borrowers, connected where relevant to IFRS S1 and IFRS S2 and Pakistan’s climate commitments, but supported by air-pollution metrics that climate disclosure alone does not provide.
Representing the private sector, Ahtesham Mazhar Gillani, President, Sialkot Chamber of Commerce & Industry, said: “Pakistan’s industrial future will be defined not only by what we produce, but by how we produce it. Clean air is no longer solely an environmental concern—it is a prerequisite for export competitiveness, investment, productivity and the health of the workforce that sustains our economy.”
Irfan Mannan, General Secretary, Rawalpindi Chamber of Commerce & Industry, added: “For Pakistan’s manufacturers, clean air represents both a public-health imperative and a strategic economic opportunity. Initiatives such as the Pakistan Clean Air Finance Framework can help mobilise affordable transition finance, particularly for SMEs, and enable cleaner, more competitive industrial growth.”
Mukhtar Ahmad Ali, Executive Director, Centre for Peace and Development Initiatives (CPDI), and former Chairman of the Punjab Right to Information Commission, said: “Decarbonisation is not a voluntary sustainability agenda—it is ultimately about our right to life. Clean air must be anchored within Pakistan’s fundamental-rights discourse. Pakistan’s clean-air transition will succeed only when institutional sequencing, enforcement capacity and financing mechanisms move together.”
To translate these recommendations into investable action, FFP is advancing the Pakistan Clean Air Finance Framework (PCAFF). Building on FFP’s policy assessments and consultations with regulators, banks, chambers of commerce, researchers and public institutions, PCAFF is intended to connect a Sensor–Governance–Finance Triad: measure exposure and emissions; convert evidence into enforceable standards and accountable sector plans; and channel credit, guarantees, concessional finance and transition support to verified clean-air interventions.
Priority interventions include quality-assured monitoring networks and low-cost sensors; continuous emissions monitoring for major industrial sources; bag filters, electrostatic precipitators and cleaner combustion systems; cleaner brick-kiln and industrial processes; crop-residue collection and value chains; municipal waste-burning prevention; dust control; clean household energy; and transport finance tied to inspection and maintenance, fuel-quality enforcement and retirement of high-emitting vehicles. PCAFF would screen each intervention for additionality, affordability, worker and community safeguards, and measurable reductions in exposure—not merely for a green label.
