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### Preface — mission, team, and stakeholders
- Mission: IMF Fiscal Affairs Department (FAD) visited Islamabad during December 5-18, 2023 at the request of the Minister of Finance, Revenue and Economic Affairs of Pakistan to identify key challenges in budget practices at planning and execution stages and make recommendations; mission also advised on digital solutions to streamline Pakistan's budgetary processes.
- FAD team: led by Fazeer Rahim (Senior Economist, FAD); team comprised Sybi Hida (Senior Economist, FAD), Richard Allen, and Soren Langhoff (both FAD experts); remote support by Graham Prentice, Claude Wendling, and Ismael Momoniat (all FAD).
- Stakeholder engagements: meetings with senior officials across Finance Division, Controller General of Accounts, Ministry of Law and Justice, Ministry of Planning, Auditor General Office, Accountant General of Pakistan Revenue, and consultations with World Bank, ADB and FCDO staff in Islamabad.
- Acknowledgements: appreciation to Arshad Hayat (Finance Division) and Resident Representative Office staff for support.

### Executive summary — fiscal context and objectives (selected highlights)
- Public debt-to-GDP rose by around 16 percentage points of GDP between FY17 and FY23.
- Interest payments now absorb 60 percent of budgeted revenue (stated also as 60 percent of tax revenue in the Introduction).
- Pakistan recorded a primary deficit of 1.3 percent of GDP for FY23 and aims to convert this into a primary surplus of 0.4 percent of GDP for FY24.
- Medium-term objective: bring down debt below 60 percent of GDP from 74 percent currently (as stated in the Introduction), in line with the Fiscal Responsibility and Debt Limitation Act (FRDLA) of 2005.

### Main findings on PFM weaknesses
- Macro-fiscal forecasting:
  - Macro-fiscal functions distributed across institutions (MFPU, FBR, DMO, Economic Affairs Division, Budget Wing, SBP) with weak coordination.
  - MFPU exists in Economic Adviser’s Wing but is at an early stage and not yet providing effective support to the Budget Wing.
  - National Macro-Fiscal Framework is prepared but does not kickstart budget preparation.
- Budget preparation:
  - Top-down strategic phase at the start of budget preparation is weak; spending ministries prepare submissions under weak constraints and insufficient guidance on fiscal space.
  - Dual budgeting system inefficiencies: bloated PSDP pipeline and separate decision-making for recurrent and development spending.
  - Budget Call Circular (BCC) provides little guidance on priorities and uses out-of-date spending ceilings.
  - Finance Division organization is fragmented and not well-tuned for effective policy advice and scrutiny.
- Budget execution:
  - Executive can award in-year supplementary grants without ex-ante approval from the National Assembly and without limits on size; extensive use in recent years.
  - Supplementary grants amounted to 14 percent of approved spending in the last two years; technical supplementary grants/reallocations amounted to another 13 percent of approved spending in the last two years.
  - Lack of comprehensive commitment control mechanisms threatens budget monitoring, can lead to overcommitment, unwanted supplementary grants, and arrears.
- Digitalization:
  - Measures in place to enhance digitalization (FABS, Data Warehouse, iPAS, ePADS) but budget processes still involve significant manual and paper-based steps.
  - Fully digitalized processes are yet to be prepared and implemented in FABS.
  - Data Warehouse and dashboards exist but are hampered by lack of timely data from some key entities; fiscal reporting not yet comprehensive and timely.
  - Regulatory framework and Fiscal Data Governance (FDG) practices do not yet fully address data delivery and quality issues.

### High-level recommendations (selected)
- Budget preparation and forecasting:
  - Strengthen capacity at the Finance Division to lead and coordinate macro-fiscal forecasts; increase forecast cycles and synchronize them with the budget.
  - Introduce a strategic top-down phase, in line with PFMA 2019 and the Budget Manual; include more guidance and binding ceilings in the BCC; minimize dual (“recurrent/capital”) budgeting.
  - Consider reorganizing the Finance Division to focus on budget and budget management functions, aligned with international good practice.
- Budget execution:
  - Implement the Supreme Court ruling No. 20 of 2013 that Supplementary Budget Statements be subject to the same scrutiny and procedure as the Annual Budget statement, including ex-ante approval by the National Assembly of supplementary grants.
  - Amend relevant laws and rules to ensure clarity on interpretation and application of the ruling, potentially including Article 84 of the Constitution.
  - Propose creation of a Contingency Reserve in the budget to maintain flexibility.
  - Auditor General of Pakistan (AGP) to conduct a special audit of mechanisms and effectiveness of supplementary grants in past years.
  - Review and strengthen commitment control mechanisms to prevent overcommitment and arrears.
- Digitalization:
  - Prepare a PFM Digitalization Master Plan and establish a high-level Steering Committee to oversee coordination and implementation.
  - Strengthen Fiscal Data Governance practices; ensure timely delivery of fiscal data to the FABS data warehouse.
  - Review budget preparation and execution business processes in FABS and consider next steps as SAP life support ends in 2025.

### Summary of selected recommended actions and time horizons (highlights from Table 1)
- Require line ministries to prepare budget submissions within binding budget ceilings; Budget Wing target FY2024/25.
- Include latest macro-fiscal projections and aggregate spending ceilings in BCC for FY2025/26; Budget Wing and Economic Advisor Wing target January 2025.
- Produce macro-fiscal forecasts before or concurrently with issuance of BCC for FY2025/26; Economic Advisor Wing target January 2025.
- Prepare monthly reports on budget performance and publish ex-post analysis of forecast accuracy; Economic Advisor Wing with other entities target FY2024/25.
- Increase participation of Budget/Expenditure Wings in budget negotiations on recurrent and development spending; Budget Wing, Expenditure Wing, Planning Division target FY2024/25.
- Expand scope of the BCC and consider joint issuance by Finance Division and Planning Division; Budget Wing target January 2025.
- Consider Finance Division reorganization supported by a functional review; Finance Division target FY2025/26.
- Initiate legal changes to limit discretionary powers over supplementary grants while retaining some flexibility; Next elected government target FY2024-25.
- Undertake a special audit on supplementary grants over the last ten years; Auditor General target FY2024-25.
- Review and revise commitment controls and redesign the Budget Execution Process; FABS with CGA and Finance Division target December 2025.
- Prepare a costed PFM Digitalization Masterplan; MoF, Finance Division and CGA target February 2025.
- Establish a high-level Steering Committee for Digitalization Masterplan implementation; MoF target July 2025.
- Review and update regulatory framework to ensure MoF authority to request timely delivery of fiscal data and prepare FDG guidelines; MoF target December 2024.
- Review process designs of budget preparation and execution to reflect new and future requirements; CGA (FABS department) target June 2025.

### Federal fiscal performance versus budget projections — key facts
- Actual fiscal deficit exceeded the budgeted deficit by 25 percent on average over the period FY17 ̶ 23.
- Budget estimates for revenue have consistently been overestimated.
- Non-tax revenue experienced a year-on-year drop of 53 percent in FY19 and 43 percent in FY22 (against budgeted amounts).
- In FY23, the sum of supplementary grants and technical supplementary grants exceeded 50 percent of budget spending.
- Provinces have generated fiscal surpluses since FY19; last NFC Award allocates divisible pool vertically in ratio 58:42 (Provinces:Federal).
- Floods of 2022 caused losses estimated at 5 percent of GDP.

### Budget process: legal framework, calendar, and lack of strategic top-down phase
- Legal instruments: PFMA, Budget Manual 2020, Manual for Development Projects 2020.
- BCC: issued in January to 44 divisions; requests PAOs prepare submissions for recurrent expenditure based on Indicative Budget Ceilings (IBCs) set in April the year before.
- Main budget timeline summary: PAO submissions mid-March; Demand Review Committee meetings late March; Budget Strategy Paper approved by Cabinet mid-April; final IBCs late April; APCC/NEC technical meetings April/May; compilation May; cabinet presentation May/June; Annual Budget Statement to National Assembly June.
- Gap: Budget Strategy Paper published in April—three months after BCC—so strategic, top-down guidance is absent at the launch of the budget process.
- Options to add strategic/top-down phase:
  - Option 1: Bring forward Budget Strategy Paper to January with BCC (drawback: data assembly difficulty).
  - Option 2: Retain BSP timetable but include a preliminary MTFF and updated IBCs in BCC (preferred incremental improvement).

### Macro-fiscal forecasting — institutional fragmentation, timing, and recommendations
- Institutional fragmentation:
  - MFPU (established 2022, created January 2020) in Economic Adviser’s Wing; not yet authorized to prepare macro-fiscal forecasts for budget preparation.
  - FBR: tax revenue forecasts; Budget Wing: non-tax revenue forecasts; Economic Affairs Division: external borrowing; DMO and SBP: domestic borrowing and interest; Budget Wing: expenditure forecasts.
- Timing misalignment:
  - Macro-fiscal forecasts produced once a year (usually March) as part of BSP; budget process starts in January with BCC; MTFF does not guide initial submissions.
- Illustrative deviations (BSP vs Annual Budget Statements example):
  - BSP April 2021 (BSP for FY22 – FY24) vs Annual Budget Statements deviations highlighted: expenditure and deficit deviations including Rs. 1,162 billion (1.2 percent of GDP) in FY23 and Rs. 4,988 billion (around 5 percent of GDP) in FY24.
- Recommendations:
  - Strengthen MFPU and Economic Adviser’s Wing role in forecasting and fiscal risk management.
  - Produce MTFF before or concurrently with BCC issuance; use leading indicators to provide preliminary MTFF in January.
  - Establish protocols/templates for information exchange; publish ex-post forecast accuracy and assumptions; present projected and actual fiscal data under consistent classifications.

### Addressing dual budgeting and improving the Budget Call Circular (BCC)
- Dual budgeting issue:
  - Recurrent budget (Finance Division) and development project decisions (Planning Division) are separated; PSDP contains more than 1,400 investment projects requiring at least 14 years to complete.
  - Project proposals often omit full recurrent cost estimates; Finance Division assesses recurrent costs after projects become operational.
  - Suggested approach: increase role of Budget/Expenditure Wings in joint decision-making with Planning Division and ministries.
- BCC improvements:
  - Current BCC includes only detailed instructions/forms; missing elements commonly included by peers: economic/fiscal context, statement of budgetary goals, macro-fiscal projections, aggregate resource envelope, indicative/binding ceilings, economic assumptions, infrastructure priorities.
  - Recommendation: expand BCC scope to include latest macro-fiscal projections, aggregate resource envelope, and updated IBCs; consider joint issuance by Finance Division and Planning Division.

### Reorganizing the Finance Division and consolidated budget office rationale
- Current fragmentation limits strategic budgeting: lack of specialized staff, fragmented management, weak contestation, excessive operational focus, under-resourced policy functions.
- Proposal: merge Budget and Expenditure Wings into a single Budget Office organized by sectoral teams supervising ministries; suggested resource split: sectoral teams ~two-thirds, remaining one-third for cross-cutting functions.
- Comparative examples: France Budget Directorate (~180 staff with central unit and seven sector units), Netherlands (two-thirds resources for supervision grouped by sectors); Planning Division has around 600 staff divided into 20 sector teams.

### Supplementary grants — empirical patterns, legal context, and reform options
- Empirical patterns:
  - Large increase in supplementary grants in recent years driven by floods, rising interest payments, policy slippages.
  - Figure 5 selected figures (Differences between Budget Estimates and Revised Estimates, FY2016-17 – FY2022-23) preserved exactly as shown for key items (Rs Billion and in %); selected entries:
    - Interest Payment, Rs Billion: 35.1, 1.1, 163.2, 367.1, -182.1, -95.4, 83.9, 1,570.4 — in %: 2.7, 0.1, 12.0, 22.7, -6.3, -3.2, 2.7, 39.8.
    - Subsidies, Rs Billion: 58.9, 28.4, 8.8, 80.2, 78.0, 221.0, 832.9, 439.1 — in %: 42.8, 20.2, 6.3, 45.9, 28.7, 105.7, 122.1, 66.1.
    - Total Recurrent Expenditure (a), Rs Billion: 115.9, -2.5, 393.0, 482.0, -62.5, 218.4, 1,007.9, 1,819.1 — in %: 3.7, -0.1, 11.3, 11.5, -1.0, 3.4, 13.4, 20.9.
    - Development Expenditure - Federal PSDP (b), Rs Billion: -38.7, -84.9, -251.0, -300.0, -167.8, -20.0, -350.0, -12.8 — in %: -5.5, -10.6, -25.1, -37.5, -23.9, -3.1, -38.9, -1.8.
    - Total (a+b), Rs Billion: 77.2, -87.4, 142.0, 182.0, -230.3, 198.4, 657.9, 1,806.3 — in %: 2.0, -2.1, 3.2, 3.7, -3.3, 2.8, 7.8, 19.1.
  - Net Domestic Borrowing series (Figure 6) values preserved: 3.67, 3.72, 7.35, 5.69, 4.26, 6.65, 8.69 for FY2016-17 through FY2022-23.
- Legal and oversight context:
  - Article 84 of the Constitution permits supplementary/excess grants; Supreme Court judgment (2013) concluded Supplementary Budget Statement should be subject to same scrutiny and procedure as Annual Budget Statement and that assent of National Assembly should be obtained before funds are made available.
  - Government practice often regularizes supplementary grants after the fact; proposals exist to amend PFMA, GFR 2019, or Article 84 to enshrine ex-ante approval with exceptions for emergencies.
- Reform options:
  - Set upper limits on supplementary grants and establish a contingency reserve.
  - Determine reserve size by examining historical unexpected calls; set rules in PFMA and Finance Division guidelines for accessing reserve.
  - Intensify Finance Division and National Assembly Finance Committees scrutiny; require endorsement of supplementary grants after reviewing in-year performance and forecasts and mandate publication.
  - Auditor General to undertake special audit of supplementary grants over the past decade.

### Commitment control weaknesses and recommended system actions
- Commitment controls shortcomings:
  - Commitments registered in FABS only when Payment Voucher is presented to CGA, allowing multiple procurement activities on single budget line and late capture of commitments.
  - Commitment controls exclude interest payments, payroll expenses and pensions; spending covered by commitment controls in 2021-22 constituted less than 10 percent of total Federal expenditure.
  - Several expenditure stages are manual and not captured in FABS.
- Best practice and system recommendations:
  - Apply pre-commitment/reservation principle to set aside allotments prior to legal commitment, especially for lengthy procurement.
  - Implement SAP O&M Module to lock payroll against sanctioned posts.
  - Link IT systems across EAD, Debt Office, PF Wing and FABS to include interest payments and provincial transfers.
  - Redesign budget execution process to capture all commitment stages and reduce arrears risk.

### DIPAT assessment, FABS status, FDG, and Digitalization Masterplan
- DIPAT findings:
  - Budget preparation predominantly manual; development project budgeting digitalized in iPAS but recurrent budget preparation remains manual and uses FABS only at consolidation stage.
  - Budget execution has several manual steps though FABS supports many functions; full digitalization expected in 2-4 years with online bill submission, ePADS, e-Office, EFT, automated bank reconciliation, and SAP commitment module—yet pre-commitment and some expenditure classes may remain excluded.
- FABS overview and constraints:
  - FABS: core SAP-based system since 2006 with 14 SAP modules; supports more than 33,000 cost centers across government (5,500 federal).
  - FABS department: established with 61 staff but only about half positions filled; lost about half staff since 2019; recruitment approved and expectation that most vacancies filled in first quarter of 2024.
  - IT infrastructure: several data centers without ‘Tier-3’ security status; network access expansion planned.
  - Custom SAP methods hinder standard upgrades; re-coding of customized modules recommended to allow version updates; SAP life support ends in 2025.
- Fiscal Data Governance (FDG) and Data Warehouse:
  - Data Warehouse collects fiscal data from multiple sources but FABS has not been able to monitor and ensure data quality; some external data delivered with delays up to 90 days.
  - Regulatory framework lacks explicit mandates for FABS use and data delivery obligations; no FABS user manual; limited online support.
- Digitalization Masterplan elements (Box 7 selected):
  - Master plan objectives, governance with High-level Steering Committee and FABS Secretariat, prioritized initiatives: improve commitment controls, full electronic payments, integration with iPAS/ePADS, fully digitalized budget preparation, FDG improvements, staff capacity building, re-coding of FABS modules, data center upgrades, increase online access.
  - Note: consider alternative approaches as SAP life support ends in 2025.
- Quick digitalization gains:
  - Review/revise FABS support to budget execution to improve commitment controls and roll out electronic payments.
  - Review and implement fully digitalized budget preparation process.
  - Review FDG practices and regulatory framework to ensure timely delivery of quality fiscal data.
  - Prepare a costed Digitalization Masterplan and establish a high-level Steering Committee.

### Consolidated recommendations (selected, numbered from source)
- Recommendation 1–7 (strengthening budgeting and forecasting):
  - 1. Require line ministries to prepare submissions within binding ceilings and explain additional requests.
  - 2. Include latest macro-fiscal projections prepared by MFPU and aggregate spending ceilings in BCC; build Budget Wing–MFPU relationship.
  - 3. Produce macro-fiscal forecasts before BCC issuance; establish protocols/templates for information exchange.
  - 4. Prepare monthly budget performance reports and publish ex-post analysis of forecast accuracy.
  - 5. Increase Budget/Expenditure Wings participation in capital spending negotiations.
  - 6. Expand BCC scope; consider joint issuance by Finance and Planning Divisions.
  - 7. Consider Finance Division reorganization supported by a functional review.
- Recommendation 8–10 (supplementary grants and commitment controls):
  - 8. Initiate legal changes to limit discretionary powers over supplementary grants while maintaining some flexibility.
  - 9. Request the Auditor General to undertake a special audit on mechanism, efficiency, and effectiveness of supplementary grants over the last ten years.
  - 10. Review stages of commitment controls to align with international good practices and redesign budget execution accordingly.
- Recommendation 11–14 (PFM digitalization and FDG):
  - 11. Prepare a costed PFM Digitalization Masterplan with time-bound objectives and priorities.
  - 12. Establish a high-level Steering Committee to monitor and guide Masterplan implementation.
  - 13. Review and update regulatory framework to ensure MoF authority to request comprehensive and timely fiscal data delivery to FABS Data Warehouse and prepare FDG guidelines.
  - 14. Review process designs of budget preparation and budget execution to reflect new and future requirements.

*Source: IMF Fiscal Affairs Department mission report to Pakistan (December 5-18, 2023) as summarized in the Preface and Executive Summary.*

### Preface ____________________________________________________________________________ 6

### Preface

### Mission, timing, and purpose
- At the request of the Minister of Finance, Revenue and Economic Affairs of Pakistan, a team from the IMF’s Fiscal Affairs Department (FAD) visited Islamabad during December 5-18, 2023 to identify key challenges in budget practices at planning and execution stages, and make recommendations to improve these practices.
- The mission also advised on how digital solutions can be leveraged to streamline and improve Pakistan's budgetary processes.

### FAD team composition and support
- Team led by Fazeer Rahim (Senior Economist, FAD) and comprised Sybi Hida (Senior Economist, FAD), Richard Allen, and Soren Langhoff (both FAD experts).
- Remote support provided by Graham Prentice and Claude Wendling (both FAD), and Mr. Ismael Momoniat (FAD expert).

### Stakeholder engagements
- Meetings with senior officials in the Ministry of Finance, Revenue and Economic Affairs, including:
  - Dr. Shamshad Akhtar, Minister of Finance, Revenue and Economic Affairs
  - Mr. Imdad Bosal, Finance Secretary
  - Mr. Iftikhar Amjad, Additional Finance Secretary Budget
  - Mr. Shehryar Sultan, Additional Finance Secretary Expenditure
  - Mr. Qumar Sarwar Abbassi, Additional Finance Secretary Corporate Finance
  - Mr. Amjed Mehmood, Additional Finance Secretary Internal and Provincial Finance
  - Dr. Imtiaz Ahmed, Economic Adviser
  - Mr. Mohsin Chandna, Director General Debt
  - Mr. Arshad Hayat, Joint Budget Secretary II
  - Mr. Obeid Rana, Joint Budget Secretary III
  - Ms. Iffat Malik, Joint Secretary Provincial Finance
  - Mr. Adnan Azeem, Director Budget Computerization
  - Staff of the Budget, Economic Advisor, Expenditure, Corporate Finance, Provincial Finance, Investment and External Finance Wings of the Finance Division
- Meetings with other key institutions and officials, including:
  - Mr. Maqbool Gondal, Controller General of Accounts
  - Mr. Raja Naeem Akbar, Secretary Law, Ministry of Law and Justice
  - Mr. Mushraque, Joint Chief Economist, Ministry of Planning, Development and Special Initiatives
  - Mr. Ammar Naqvi, Deputy Auditor General
  - Mr. Owais Ahmed, Director Financial Accounting and Budgeting System (FABS)
  - Mr. Mujhid Shedil, Finance Secretary Punjab
  - Mr. Habib-ur-Rehman, Finance Special Secretary Baluchistan
  - Staff of the Accountant General of Pakistan Revenue (AGP), Controller General of Accounts, Ministry of Planning, Development, and Special Initiatives, Ministry of Law and Justice, the Auditor General Office of Pakistan
- Consultations with World Bank, ADB and FCDO staff based in Islamabad.

### Acknowledgements
- Appreciation expressed to Mr. Arshad Hayat in the Finance Division for facilitating mission organization, and to Ms. Esther Perez, IMF Resident Representative, Mr. Muhammad Ali, Office Manager, and staff of the Resident Representative Office in Islamabad for support.

### Executive summary — fiscal context and objectives (selected highlights)
- Public debt-to-GDP rose by around 16 percentage points of GDP between FY17 and FY23.
- Interest payments now absorb 60 percent of budgeted revenue (stated also as 60 percent of tax revenue in the Introduction).
- Pakistan recorded a primary deficit of 1.3 percent of GDP for FY23 and aims to convert this into a primary surplus of 0.4 percent of GDP for FY24.
- Medium-term objective: bring down debt below 60 percent of GDP from 74 percent currently (as stated in the Introduction), in line with the Fiscal Responsibility and Debt Limitation Act (FRDLA) of 2005.

### Main findings on PFM weaknesses
- Macro-fiscal forecasting:
  - Macro-fiscal functions are distributed across different institutions responsible for forecasting macroeconomic indicators, tax revenue, public debt service, and development spending, but coordination is weak.
  - A macro-fiscal policy unit (MFPU) exists in the Economic Adviser’s Wing but is at an early stage and does not yet provide effective support to the Finance Division’s Budget Wing.
  - A National Macro-Fiscal Framework is prepared but does not kickstart the budget preparation process.
- Budget preparation:
  - The top-down, strategic phase at the start of budget preparation is weak; spending ministries prepare submissions under weak constraints and with insufficient guidance on fiscal space.
  - Dual budgeting system inefficiencies: a bloated pipeline of projects in the Public Sector Development Plan (PSDP) and separate decision-making processes for recurrent and development spending.
  - Budget Call Circular (BCC) provides little guidance on priorities and uses out-of-date spending ceilings.
  - Finance Division organization is fragmented and not well-tuned to provide effective policy advice and scrutiny of budget proposals.
- Budget execution:
  - The Executive can award in-year supplementary grants without ex-ante approval from the National Assembly and without limits on size; extensive use in recent years.
  - Supplementary grants amounted to 14 percent of approved spending in the last two years; technical supplementary grants/reallocations amounted to another 13 percent of approved spending in the last two years.
  - Lack of comprehensive commitment control mechanisms threatens budget monitoring, can lead to overcommitment, unwanted supplementary grants, and arrears.
- Digitalization:
  - Measures have been put in place to enhance digitalization of budget preparation and execution and to improve fiscal monitoring and reporting.
  - Budget processes still involve significant manual and paper-based steps; fully digitalized processes are yet to be prepared and implemented in FABS.
  - A data warehouse and dashboards exist but are hampered by lack of timely data from some key entities; fiscal reporting is not yet comprehensive and timely.
  - Regulatory framework and Fiscal Data Governance (FDG) practices do not yet fully address data delivery and quality issues.

### High-level recommendations (selected)
- Budget preparation and forecasting:
  - Strengthen capacity at the Finance Division to lead and coordinate macro-fiscal forecasts; increase forecast cycles and synchronize them with the budget.
  - Introduce a strategic top-down phase in the budget process, in line with PFMA 2019 and the Budget Manual; include more guidance and binding ceilings in the BCC; minimize dual (“recurrent/capital”) budgeting.
  - Consider reorganizing the Finance Division to focus on budget and budget management functions, aligned with international good practice.
- Budget execution:
  - Implement the Supreme Court ruling No. 20 of 2013 that Supplementary Budget Statements be subject to the same scrutiny and procedure as the Annual Budget statement, including ex-ante approval by the National Assembly of supplementary grants.
  - Amend relevant laws and rules to ensure clarity on interpretation and application of the ruling, potentially including Article 84 of the Constitution.
  - Propose creation of a Contingency Reserve in the budget to maintain flexibility.
  - Auditor General of Pakistan (AGP) to conduct a special audit of mechanisms and effectiveness of supplementary grants in past years.
  - Review and strengthen commitment control mechanisms to prevent overcommitment and arrears.
- Digitalization:
  - Prepare a PFM Digitalization Master Plan and establish a high-level Steering Committee to oversee coordination and implementation.
  - Strengthen Fiscal Data Governance practices; ensure timely delivery of fiscal data to the FABS data warehouse.
  - Review budget preparation and execution business processes in FABS and consider next steps as SAP life support ends in 2025.

### Summary of selected recommended actions and time horizons (highlights from Table 1)
- Require line ministries to prepare budget submissions within binding budget ceilings; Budget Wing target FY2024/25.
- Include latest macro-fiscal projections and aggregate spending ceilings in BCC for FY2025/26; Budget Wing and Economic Advisor Wing target January 2025.
- Produce macro-fiscal forecasts before or concurrently with issuance of BCC for FY2025/26; Economic Advisor Wing target January 2025.
- Prepare monthly reports on budget performance and publish ex-post analysis of forecast accuracy; Economic Advisor Wing with other entities target FY2024/25.
- Increase participation of Budget/Expenditure Wings in budget negotiations on recurrent and development spending; Budget Wing, Expenditure Wing, Planning Division target FY2024/25.
- Expand scope of the BCC and consider joint issuance by Finance Division and Planning Division; Budget Wing target January 2025.
- Consider Finance Division reorganization supported by a functional review; Finance Division target FY2025/26.
- Initiate legal changes to limit discretionary powers over supplementary grants while retaining some flexibility; Next elected government target FY2024-25.
- Undertake a special audit on supplementary grants over the last ten years; Auditor General target FY2024-25.
- Review and revise commitment controls and redesign the Budget Execution Process; FABS with CGA and Finance Division target December 2025.
- Prepare a costed PFM Digitalization Masterplan; MoF, Finance Division and CGA target February 2025.
- Establish a high-level Steering Committee for Digitalization Masterplan implementation; MoF target July 2025.
- Review and update regulatory framework to ensure MoF authority to request timely delivery of fiscal data and prepare FDG guidelines; MoF target December 2024.
- Review process designs of budget preparation and execution to reflect new and future requirements; CGA (FABS department) target June 2025.

*Source: IMF Fiscal Affairs Department mission report to Pakistan (December 5-18, 2023) as summarized in the Preface and Executive Summary.*

### 2.      In recent years, actual fiscal outcomes at the Federal level have fared worse than the

### 2.      In recent years, actual fiscal outcomes at the Federal level have fared worse than the projections

### Federal fiscal performance versus budget projections
- The actual fiscal deficit exceeded the budgeted deficit by 25 percent on average over the period FY17 ̶ 23.
- Budget estimates for revenue have consistently been overestimated.
- Non-tax revenue (against budgeted amounts) experienced a year-on-year drop of 53 percent in FY19 and 43 percent in FY22.
- In years prior to FY20, revenue shortfalls were met by spending offsets, particularly by cuts in non-interest recurrent expenditure and development expenditure.
- In recent years, authorities failed to contain spending despite making large cuts to development spending.
- Interest payments have risen sharply due to:
  - an increase in public debt (largely domestic and non-concessional in nature), and
  - a rise in borrowing costs.

### Provincial finances and fiscal balances
- Provinces have generated fiscal surpluses since FY19.
- Four provinces have a direct call on the “divisible pool” of Federal taxes as defined by Amendment 18 (2011) of the Constitution.
- The last National Finance Commission Award allocates the divisible pool vertically between Provinces and the Federal government in the ratio 58:42.
- Provinces’ revenue from the divisible pool represents around three quarters of their total revenue.
- Provincial spending composition:
  - roughly two-thirds recurrent,
  - one-third development (largely in education and health).
- In recent years, each Province has signed a Memorandum of Understanding with the Federal government which includes a desired, but non-binding, level of fiscal surplus.

### Drivers of the Federal government’s recent poor fiscal performance
- Devastating floods of 2022, with losses estimated at 5 percent of GDP.
- Substantial volatility in commodity prices.
- Tightening external and domestic financing conditions.
- The government undertook emergency measures in response to:
  - the floods,
  - the slowdown in economic growth,
  - the rise in consumer prices.

### Policy slippages and revenue impacts
- In FY23, unplanned and untargeted subsidies, and delays in rolling out planned revenue measures delayed planned fiscal adjustments.
- Restrictions on imports throughout the year hampered revenue collection from import-related sales tax and custom duties and contributed to a decline in tax revenue through:
  - a downturn in economic activities, and
  - the closure of several industrial facilities.
- In FY22, amid political tensions, a relief package included:
  - generous subsidies on petrol and diesel,
  - lowered electricity tariffs,
  - tax exemptions and a tax amnesty,
  - increases in public wages and pensions,
  - additional food subsidies.

### In-year changes to spending and parliamentary scrutiny
- In-year changes occur through:
  - technical supplementary grants (virements between grants), and
  - supplementary and excess grants (additional grants approved during the year not met by the surrender of existing grants, as defined by Article 84 of the Constitution).
- In FY23, the sum of these supplementary grants exceeded 50 percent of budget spending.
- Extraordinary latitude taken by the Executive in its interpretation of Article 84 to approve these grants without the prior approval of the National Assembly means a significant proportion of spending does not undergo prior scrutiny by the National Assembly.

### Imperative for stronger fiscal institutions
- Effective control over the budget will be paramount this year and in the foreseeable future.
- Stronger fiscal institutions can help deliver a more credible budget and tighten its execution.
- This report focuses on addressing key shortcomings of the PFM system in Pakistan by:
  - strengthening budget preparation, and
  - tightening budget execution.
- Specific recommendations include using digitalization as an enabling factor.
- Other critical PFM reforms (outside the scope of this report) include:
  - SOE reforms,
  - implementation of the Treasury Single Account (TSA),
  - proactive cash and debt management.

### Budget process: legal framework and institutional roles
- The budget process is defined in legislation: the PFMA sets principles behind budget preparation and presentation and clarifies roles.
- The Budget Manual 2020 (prescribed by the PFMA) clarifies roles and responsibilities, the budget cycle and calendar, budget documentation, and processes for preparing and presenting a medium-term based budget.
- The Manual for Development Projects 2020 guides preparation of capital infrastructure (“development”) projects for inclusion in the budget.
- The Budget Wing and Expenditure Wing of the Finance Division lead preparation for recurrent expenditure; supported by other units (e.g., Corporate Finance Wing, Economic Adviser’s Wing/Macro-Fiscal Policy Unit).
- Budget Wing staff: nearly 40 professional staff.
- Expenditure Wing staff: around 30 professional staff divided into ten teams (each covering 3-4 ministries/divisions).
- Expenditure Wing outsources an officer to some line ministries to support Chief Finance and Accounting Officer work and act as the Finance Division’s eyes and ears.

### Calendar and main steps in the budget process
- The Budget Call Circular (BCC) is issued in January each year to 44 divisions.
- BCC requests PAOs to prepare submissions (“demands”) for recurrent expenditure for the next budget year, separating employee-related expenditure from other recurrent spending.
- PAOs are asked to base submissions on Indicative Budget Ceilings (IBCs) set in April the year before, as part of rolling Medium-Term Budget Estimates.
- The Planning Commission leads a parallel process for PSDP projects via a PSDP Call Circular (PSDP-CC) and PSDP-I forms; approvals are reviewed by Demand Review or Priorities Committees led by the Finance Division.
- Main steps (summary timeline):
  - Submission of proposals by PAOs (mid-March).
  - Demand Review Committee meetings (starting in late March).
  - Issuance of a Budget Strategy Paper with medium-term macro-fiscal projections, priorities, IBCs, and a fiscal risk statement, approved by Cabinet (mid-April).
  - Finance Division issues final IBCs for recurrent spending and aggregate ceiling for development spending (late April).
  - Technical meetings by APCC and NEC to finalize recurrent and development budgets (April/May).
  - Planning Commission allocates individual IBCs for Ministries and Divisions (April/May).
  - Compilation of the budget by the Budget Wing (May).
  - Presentation of the budget to the Cabinet (May/June).
  - Submission of the Annual Budget Statement by the Federal Government to the National Assembly (June).

### Lack of a strategic and top-down phase
- The current budgetary process is largely bottom-up and designed to gather information from divisions/ministries.
- No up-to-date fiscal projections or budget ceilings are included in the BCC that launches the budget process in January.
- IBCs issued by the Finance Division are generally based on the previous year’s ceilings and are not adjusted for inflation, new policy proposals or recent fiscal developments.
- The Budget Strategy Paper, which includes medium-term macro-fiscal projections and an assessment of available fiscal space, is released in April—three months after the launch of the budget process.
- The PFMA and Budget Manual 2020 both require a strategic phase that is not currently applied:
  - PFMA: Budget Strategy Paper should indicate “strategic priorities of the Government’s revenue and spending policies and specify indicative levels of spending in various Ministries and Divisions.” (Chapter 3, Article 3).
  - Budget Manual 2020: “The budgeting cycle starts with setting of budget strategy and completes with approval of budget .... the Federal Government sets priorities and a comprehensive budget strategy to be followed by all the Public Sector Entities” (Paragraph 5.1).
- The current practice—divisions preparing submissions based on last year’s estimates and the Budget Strategy Paper published three months after process launch—is inconsistent with these principles.

### Options for adding a strategic/top-down phase
- Two options presented:
  1. Bring forward the Budget Strategy Paper to January and issue it with the Budget Call Circular.
     - Drawback: difficult to assemble necessary data in time to update economic and fiscal projections.
  2. Retain the existing timetable for the Budget Strategy Paper but include a preliminary analysis in the BCC:
     - preliminary macro-economic developments,
     - updated macro-fiscal projections,
     - calculation of available fiscal space,
     - updated IBCs.
     - This second option would substantially improve current practice by including the latest assessment from the Economic Adviser’s Wing and most recent data on fiscal trends and indicators.

### Role and development of the Macro-Fiscal Policy Unit (MFPU)
- The MFPU was established in 2022.
- The MFPU has demonstrated commendable performance across various functions.
- The relationship between the MFPU and the Budget Wing is currently under development (with technical support from the World Bank).
- Further developing this relationship will be key to strengthening the budget process.
- Top-down budgeting requires close coordination between the Budget Wing and the MFPU so the Budget Wing has immediate access to the latest economic data and timely estimates of revenues, expenditure, borrowing, debt, and available fiscal space.

### International practice and rationale for top-down budgeting
- A top-down approach (strategic phase) links the finance ministry’s policy objectives with aggregate resource envelopes and indicative or binding ceilings for spending ministries.
- A recent survey showed that 21 out of 25 OECD countries set aggregate and/or sector ceilings in a budget circular that launches the budget process.
- Box 1 illustrates top-down budgeting in France and the Netherlands (process descriptions provided in the source).

*Source: IMF.*

### 19.      Credible macro-fiscal forecasts are crucial for governments in formulating effective fiscal

### 19.      Credible macro-fiscal forecasts are crucial for governments in formulating effective fiscal

### Importance of credible macro-fiscal forecasts
- Timely and accurate macro-fiscal forecasts serve as the foundation for a credible budget and provide information on necessary actions to meet government macroeconomic goals.
- Pakistan has adopted a fiscal rule through its fiscal responsibility framework, setting a public debt limit at 50 percent of GDP by FY2032-33 to guide fiscal policy.
- The FRDLA, enacted in 2005 and amended in 2022, mandates a reduction in total public debt to 60 percent of GDP by FY 2018-19 and further to 50 percent of GDP by FY2032-33, which represents the hard limit thereafter. Currently, the total public debt stands at 74 percent of GDP.
- This makes the role of forecasting and a credible budget more relevant for achieving the debt limit target.

### Institutional responsibilities and fragmentation
- Macro-fiscal forecasting responsibilities are distributed:
  - MFPU of the Economic Adviser Wing (EAW) tasked with macro-fiscal functions; MFPU created January 2020 and started to operate in 2022, skills and capacities still developing; not yet authorized to prepare macro-fiscal forecasts for budget preparation.
  - Tax revenue forecasts: Federal Board of Revenue (FBR).
  - Non-tax revenue forecasts: Budget Wing coordination.
  - Borrowing and interest payment forecasts: Economic Affairs Division (external borrowing), Debt Management Office (DMO) of the Finance Division (domestic), State Bank of Pakistan (domestic).
  - Expenditure forecasts: Budget Wing.
- Dispersion of functions requires strong coordination; MFPU intended to ensure consistency between macroeconomic developments and projected revenues and expenditure but lacks full authority and capacity.

### Issues in revenue forecasting and incentives
- FBR prepares tax revenue forecasts but its primary responsibility is optimizing government revenue and ensuring compliance, raising potential conflict-of-interest concerns between revenue optimization and accurate forecasting.
- Spending ministries/divisions may have incentives to overestimate non-tax revenues to secure larger resource envelopes; analysis of the past ten years revealed that non-tax revenue has been overestimated in seven of those years.

### Timing and alignment with the budget cycle
- Macro-fiscal forecasts are produced only once during the fiscal year, usually in March, as part of the Budget Strategy Paper (BSP).
- Budget preparation starts in January with issuance of the Budget Call Circular; as a result, the MTFF's potential to guide fiscal policy is restricted because the latest macro-fiscal indicators are based on the previous year’s BSP and are not revised during budget preparation.
- Illustrative discrepancies between BSP projections and annual budget statements (Figure 4):
  - BSP April 2021 (BSP for FY22 – FY24) vs Annual Budget Statements:
    - Gross Federal Revenue: 7,989; 8,775; 9,004; 10,533; 12,163; 7,909; 9,405; 12,378; deviations: 630; 1,845
    - Transfer to Provinces: 3,527; 3,796; 4,100; 4,975; 5,276; 3,412; 4,373; 5,399; deviations: 577; 424
    - Net Federal Revenue: 4,462; 4,979; 4,904; 5,558; 6,887; 4,497; 5,032; 6,979; deviations: 53; 1,421
    - Total Federal Expenditure: 8,056; 8,570; 9,502; 9,965; 14,460; 8,661; 9,732; 14,953; deviations: 1,162; 4,988
    - Federal Deficit: -3,594; -3,591; -4,598; -4,407; -7,573; -4,164; -4,700; -7,974; deviations: -1,109; -3,567
  - Specific highlighted deviations:
    - In FY23, expenditure forecast in the BSP for FY22 – FY24 (published in April 2021) were Rs. 1,162 billion (1.2 percent of GDP) less than approved in the annual budget statement.
    - In FY24, projections in the BSP for FY23 – FY25 (published in June 2022) were Rs. 4,988 billion (around 5 percent of GDP) less than the annual budget statement estimates.

### Recommendations to strengthen macro-fiscal forecasting and budget credibility
- Strengthen macro-fiscal functions within the Finance Division:
  - Increase role of Economic Adviser’s Wing and MFPU in macro-fiscal forecasting and fiscal analysis.
  - Economic Adviser’s Wing staffed with 15 economists, of which 5 hold a PhD in economics, can support MFPU mission; should take active role in both budget preparation and budget execution.
  - Complement with the fiscal risk management function tasked to MFPU.
- Align the MTFF with the budget cycle:
  - Economic Adviser’s Wing should produce the medium-term macro-fiscal framework before or concurrently with issuance of the Budget Call Circular.
  - Economists should leverage leading and partial economic indicators (e.g., new car registrations, number of construction permits, electricity/fuel consumption) to provide a preliminary MTFF in January to kickstart the budget process.
  - Practice aligns with international examples (Box 2).
- Enhance coordination among stakeholders:
  - Economic Adviser’s Wing, through MFPU, should lead the process, ensure consistency between macroeconomic developments and projected revenues and expenditures as per its Terms of Reference.
  - Establish protocols and templates to facilitate exchange of information among key players.
  - Economic Adviser’s Wing could provide customized forecasting models to other stakeholders.
- Improve forecast assessment and transparency:
  - Economic Adviser’s Wing should examine past forecast errors and analyze reasons for forecast errors.
  - Publish macroeconomic projections regularly, underlying assumptions, and ex-post analysis of forecast accuracy.
  - Publish and explain reasons for differences between consecutive MTFF/BSP forecasts and differences between budget projections and actual outturns, either as standalone documents or as part of the BSP.
- Improve fiscal reporting and data presentation:
  - Projected fiscal data and actual data presented in BSP and budget reports should adhere to the same classification.
  - Fiscal operations reports should include a column for initial budget estimates to allow performance comparison.
  - Publish macro-fiscal data in easily readable formats, such as Microsoft Excel.

### Box 2 — Macro-Fiscal Forecasts in South Africa (international practice example)
- Forecasts of key economic indicators and their components are presented twice a year, with underlying assumptions.
- The Medium-Term Budget Policy Statement, published six months before the end of the fiscal year, sets out the macro-fiscal framework underpinning the budget, and includes forecasts for the budget year, three outer years and outcomes for the three previous years.
- The Budget Review, published 1-2 months before the end of the fiscal year, sets out budget narrative, economic outlook, and key policies underpinning the budget numbers, and provides forecast revisions incorporating latest economic developments.
- Source: IMF Mission and South Africa Fiscal Transparency Evaluation 2023.

### Addressing the dual budgeting process
- Pakistan’s dual budgeting system at federal level separates preparation of recurrent budget (Finance Division) and decision-making on development (capital) projects (Planning Division).
- Risks and inefficiencies:
  - Prevents finance ministry from taking a holistic view of spending priorities and trade-offs between capital and recurrent spending.
  - Planning Division’s incentives focus on promoting new projects; Public Sector Development Program (PSDP) is enormous—contains more than 1,400 investment projects which would require at least 14 years to complete.
  - Project proposals often do not account for full recurrent costs once projects are operational; Finance Division assesses such costs only after projects are operational.
- International evidence:
  - About 50 percent of OECD countries have a fully integrated approach for considering recurrent and capital spending.
  - IMF (2021) study finds about half of developing countries have separate planning ministries or commissions, and about half have a PSDP or equivalent; but finance ministries typically lead in determining budget allocations for capital investment projects.
- Coordination exists in principle in Pakistan (e.g., Priority Committee discussions, IBC consultation), and Pakistan’s 2023 PIMA report finds planning of public investment relatively well managed by the Planning Division, but the bloated PSDP remains a challenge.
- Suggested approach:
  - Within existing procedures, increase role of Finance Division’s Budget and Expenditure Wings in dialogue with Planning Division and ministries/divisions, and pursue joint decision making on budget allocations.

### Improving the Budget Call Circular (BCC)
- Current BCC contains only detailed budget instructions and forms; lacks strategic elements common in peer countries.
- Elements commonly included by other countries (many absent in Pakistan’s BCC):
  - (i) information on the economic and fiscal context for the budget;
  - (ii) a statement of budgetary goals and objectives;
  - (iii) macro-fiscal projections;
  - (iv) an aggregate resource envelope available for the next budget, and indicative (or binding) budget ceilings;
  - (v) economic assumptions (e.g., on GDP, inflation, interest rates) for spending agencies;
  - (vi) an assessment of infrastructure priorities;
  - (vii) detailed budget instructions and forms (currently the only element included in Pakistan).
- Inclusion of macro-fiscal projections, an aggregate resource envelope, and updated IBCs would give a strong top-down focus to budget preparation.
- Consider adding overview of budget/infrastructure priorities, more analysis of current fiscal/budget position, and assessment of previous fiscal year budget projections and outcomes.

### Reorganizing the Finance Division
- Current organization is fragmented, limiting a strategic approach to budgeting:
  - Weaknesses include lack of specialized staff, fragmented management, weak budget contestation, excessive focus on operations rather than policy, lack of coordination of federal-provincial relations, limited use of IT, and under-resourced functions (e.g., tax policy, debt management).
- Proposal:
  - Consider merging the Budget and Expenditure Wings into a single Budget Office to pool resources and organize teams by sector or ministry.
  - “Sectoral” teams would both challenge sector budget proposals and supervise budget operations; act as Finance Division representatives in monitoring execution, approving changes, preparing budget decisions, establishing baseline estimates, supervising budget preparation, and leading demand review committee discussions.
  - Suggested resource allocation: sectoral teams could represent around two-thirds of the Office’s resources; the remaining one-third to consolidate overall budget preparation and cross-cutting issues.

*Source: IMF mission content as presented in the provided chapter.*

### 36.      A consolidated budget office with much stronger expertise across key sectors is the

### 36.      A consolidated budget office with much stronger expertise across key sectors is the 

### Comparative organization of budget functions
- The total number of staff working in the French Budget Directorate is roughly comparable to the combined staff complement in the Budget and Expenditure Wings in the Finance Division,16 but:
  - the skills/experience of the staff, and the distribution of functions is different;
  - the French structure comprises one single Directorate.
- A similar organizational structure and staff complement can be found in the UK.
- France, the UK and the Netherlands have well-functioning macro-fiscal units that provide:
  - regular and timely information for the Budget Directorate on fiscal trends and fiscal space;
  - medium-term macro-fiscal projections; and
  - analysis of the fiscal implications of budget proposals required by a top-down approach to budget preparation (see Section II A).
- Footnote: The Planning Division has a vastly superior staffing complement compared to the Finance Division: around 600 staff divided into 20 sector teams.

Box 3 — Organization of the Budget Directorates in France and the Netherlands
- France:
  - The Budget Directorate of the Finance Ministry contains a total of around 180 staff.
  - About 30-40 staff work in a central unit responsible for coordinating annual budget and medium-term budget framework preparation, issuing guidelines and instructions to line ministries, monitoring budget execution, and managing related IT systems.
  - The central unit is complemented with seven sector units, each comprising around 20 staff, responsible for main budget areas (agriculture, defense, education, heath, etc.).
  - Staff roles: accountants, economists, financial analysts, political scientists, and lawyers. Some staff have line ministry experience.
- Netherlands:
  - A key function of the Budget Directorate in the Ministry of Finance is to supervise the policies and budgets of line ministries and related entities.
  - Two-thirds of the resources of the Directorate are devoted to supervision work, grouped in teams by sectors (line ministries).
  - There is a unit responsible for consolidating the overall preparation of the budget (budget policy).
  - Guiding principles include:
    - (i) close oversight of line ministries;
    - (ii) close integration of planning and executing the budget;
    - (iii) sufficient resources for supervising spending outturns and raising red flags if needed;
    - (iv) sufficient capacity to challenge new projects, programs and policies;
    - (v) close involvement in planning and implementation of expenditure reviews.
  - Line ministries each have their own finance/budget directorates (approximately 50-60 staff) with a functional relation to the Budget Department in the finance ministry.
  - Typical staff rotation to avoid “turning native”.

*Source. IMF Mission*

### Recommendations to strengthen budgeting (Recommendations 1–7)
- Recommendation 1. Top-down budgeting.
  - Require line ministries to prepare their budget submissions within a binding budget ceiling and explain any request for additional resources.
  - The IBCs should reflect the latest estimate of the resource envelope (based on up-to-date macro-fiscal projections) as well as Cabinet-level policy decisions on ministry/division priorities.
- Recommendation 2. Top-down budgeting.
  - Include in the BCC the latest macro-fiscal projections prepared by the MFPU, as well as aggregate spending ceilings for the next budget year and updated budget ceilings for line ministries.
  - Continue to build a strong working relationship between the Budget Wing and the MFPU.
- Recommendation 3. Macro-Fiscal analysis and forecasting.
  - Produce macro-fiscal forecasts before the issuance of the BCC.
  - Establish protocols and templates to facilitate exchange of information among key players engaged in macro-fiscal forecasting.
- Recommendation 4. Macro-fiscal analysis and forecasting.
  - Prepare monthly reports on budget performance, including potential measures to achieve budget targets if projections indicate deviations, for the Finance Secretary.
  - Publish ex-post analysis of the accuracy of previous macro-fiscal forecasts and budget estimates in Monthly Economic Update and Outlook.
- Recommendation 5. Addressing dual budgeting.
  - Increase the participation of the Budget/Expenditure Wings in the budget negotiations with the ministries/divisions on capital spending.
- Recommendation 6. Improving guidance on budget preparation.
  - Expand the scope and coverage of the BCC to align it with international good practice. Changes could be introduced incrementally if required.
  - Issue the Budget Call Circular jointly by the Finance Division and the Planning Division.
- Recommendation 7. Strengthening capacity at the Finance division.
  - Consider a reorganization of the Finance Division to reduce fragmentation and improve effective decision-making.
  - Support the reorganization with a functional review of the Division’s structure and staffing, focusing on the Budget and Expenditure Wings or the whole Finance Division.

### Strengthening budget execution — managing supplementary grants
Findings and procedural context
- Article 84 of the Constitution empowers the Federal Government to sanction additional grants from the Federal Consolidated Fund within the fiscal year to cover expenditures surpassing limits approved by the National Assembly, with conditions:
  - Additional expenditure for an existing service in the current financial year is warranted only if previously authorized funds prove insufficient, and applies to new services not included in the initial Annual Budget Statement.
  - The Federal Government must present a Supplementary or Excess Budget Statement to the National Assembly in such instances.
  - The Supplementary or Excess Budget Statement must adhere to guidelines set out in Articles 80 to 83 of the Constitution; Article 83 emphasizes that “no expenditure from the Federal Consolidated Fund shall be deemed to be duly authorized unless it is specified in ...[a] schedule laid before the National Assembly.”
- Government practice:
  - Supplementary grants have become a regular feature of the budgeting process in Pakistan.
  - Traditionally, the Government authorizes grants as necessary within the fiscal year; approval from the National Assembly is sought when the Annual Budget Statement for the next fiscal year is presented (typically a month before the fiscal year concludes).17
  - This process regularizes supplementary grants after the fact and often undergoes limited scrutiny in the National Assembly.
- Box 4 — Internal Approval of Supplementary Grants:
  - The Budget Manual (2020) and the General Financial Rules (GFR) of 2019 guide management of supplementary grants.
  - Ministries and divisions cannot spend beyond appropriated amounts and must submit proposals for supplementary grants to the Finance Division before mid-May or earlier if unforeseen needs arise.
  - Proposals are assessed by the Budget Wing; once approved, requests are submitted to the Cabinet's Economic Coordination Committee. Technical supplementary grants follow the same procedures but authority remains in the Finance Division.
  - Source: IMF Mission
- Footnote on timing: Supplementary grants approved by the Federal Government until May 15th of the current year are presented for approval by Parliament. Grants approved between May 15th and June 30th are presented for approval in the following year.

Empirical patterns and fiscal impact
- Recent years have seen a notable increase in the volume of supplementary grants, particularly in the last two fiscal years, attributed to:
  - responses to devastating floods;
  - rising interest payments;
  - significant policy slippages (detailed in Table 2 and Figure 5).
- Technical supplementary grants reallocate funds by decreasing approved funds in certain areas to bolster others; development spending has frequently been the target of significant reductions over the past decade (illustrated in Figure 5).
- Key figures from Figure 5 (Differences between Budget Estimates and Revised Estimates, FY2016-17 – FY2022-23), units and values preserved exactly as shown:
  - Interest Payment, Rs Billion: 35.1, 1.1, 163.2, 367.1, -182.1, -95.4, 83.9, 1,570.4
    - in %: 2.7, 0.1, 12.0, 22.7, -6.3, -3.2, 2.7, 39.8
    - Average Absolute Average: 8.8, 11.2
  - Pension, Rs Billion: 5.0, 0.0, 85.4, 0.0, 42.4, 0.0, 60.0, 0.0
    - in %: 2.2, 0.0, 34.4, 0.0, 10.1, 0.0, 12.5, 0.0
    - Average Absolute Average: 7.4, 7.4
  - Defence Affairs and Services, Rs Billion: -5.3, -18.7, 79.1, 37.4, 74.9, 8.8, 110.2, 23.9
    - in %: -0.7, -2.2, 8.6, 3.4, 6.5, 0.7, 8.0, 1.5
    - Average Absolute Average: 3.2, 4.0
  - Grants and Transfers, Rs Billion: 8.4, -59.2, 31.4, 0.4, 65.8, 27.8, -77.1, -19.3
    - in %: 2.0, -13.4, 7.3, 0.1, 7.9, 3.1, -6.6, -1.6
    - Average Absolute Average: -0.2, 5.3
  - Subsidies, Rs Billion: 58.9, 28.4, 8.8, 80.2, 78.0, 221.0, 832.9, 439.1
    - in %: 42.8, 20.2, 6.3, 45.9, 28.7, 105.7, 122.1, 66.1
    - Average Absolute Average: 54.7, 54.7
  - Pay and Pension Increase, Rs Billion: 0, 0, 0, 0, -79, 0, -160, 0
    - in %: -100.0, -100.0, -100.0, 100.0
  - Running of Civil Government, Rs Billion: 13.7, 46.0, 25.2, -3.1, 52.5, 11.3, 51.0, 0.0
    - in %: 4.2, 13.0, 6.7, -0.7, 12.2, 2.4, 10.6, 0.0
    - Average Absolute Average: 7.9, 8.2
  - Provision for Emergency and others, Rs Billion: 0.0, 0.0, 0.0, 0.0, -115.0, 45.0, 107.0, -195.0
    - in %: -100.0, 90.0, 85.6, -100.0, -6.1, 93.9
  - Total Recurrent Expenditure (a), Rs Billion: 115.9, -2.5, 393.0, 482.0, -62.5, 218.4, 1,007.9, 1,819.1
    - in %: 3.7, -0.1, 11.3, 11.5, -1.0, 3.4, 13.4, 20.9
    - Average Absolute Average: 7.9, 8.2
  - Development Expenditure - Federal PSDP (b), Rs Billion: -38.7, -84.9, -251.0, -300.0, -167.8, -20.0, -350.0, -12.8
    - in %: -5.5, -10.6, -25.1, -37.5, -23.9, -3.1, -38.9, -1.8
    - Average Absolute Average: -18.3, 18.3
  - Total (a+b), Rs Billion: 77.2, -87.4, 142.0, 182.0, -230.3, 198.4, 657.9, 1,806.3
    - in %: 2.0, -2.1, 3.2, 3.7, -3.3, 2.8, 7.8, 19.1
    - Average Absolute Average: 4.1, 5.5
- Resulting fiscal pressures:
  - The net result of employing supplementary and technical grants has been an increase in domestic borrowing beyond initial projections (Figure 6) compounded by revenue shortfalls.
  - This surge in borrowing has had knock-on implications on interest costs and debt.

Figure 6 — Net Domestic Borrowing, FY2016-17 – FY2022-23 (Rs Billion)
- Values shown for Actual/Budget/FDRL (budget deficit) series:
  - 3.67, 3.72, 7.35, 5.69, 4.26, 6.65, 8.69
  - Axis annotations include: - , 1.00, 2.00, 3.00, 4.00, 5.00, 6.00, 7.00, 8.00, 9.00, 10.00
  - FY labels: FY2016-17, 17-18, 18-19, 19-20, 20-21, 21-22, 22-23
  - Legend entries: Actual, Budget, FDRL (budget deficit)

### International practice and oversight considerations
- The IMF Fiscal Transparency Code18 advises that "any significant amendments to the total budgeted expenditure should necessitate a supplementary budget beforehand." The Code defines advanced practice as requiring "a supplementary budget ahead of any substantial changes to the total budgeted expenditure or its composition."
- Many countries require prior legislative approval for supplementary spending. Box 5 — Supplementary Budgets – Country Experiences — summarizes practices in:
  - Chile: Expenditure exceeding the overall approved budget total can be authorized only by law requiring Congressional approval; executive flexibility within limits set in the annual budget law.
  - Colombia: Only Congress can approve changes/additions/transfers across budget lines; supplementary appropriations require established additional sources of funding and certification of availability.
  - France: Contingency reserve limit Euro 500 million (0.1 percent of total expenditure) with specified ex ante information requirements; changes above limits require a supplementary budget and legislative approval by both Chambers.
  - Ireland: Any increase in total expenditure or movements between Votes requires approval by the National Assembly via a Supplementary Estimate for specified circumstances.
  - South Africa: Virements between programs within a vote limited up to 8 percent without legislative approval; larger changes require legislative approval through an adjustments budget; PFM Act permits emergency use up to 2 percent of total appropriations without legislative approval (used once in past 10 years, 0.4 percent of total appropriations).
  - Source: IMF Fiscal Transparency Evaluation reports.

### Legal interpretation and reform options
- Supreme Court judgment (2013) on Article 84:
  - Observations from the judgment:
    - The Federal Government is obligated to present a Supplementary Budget Statement to the National Assembly that “is subjected to the same scrutiny and procedure as is applicable to the Annual Budget Statement”.
    - The Supplementary Budget Statement should be presented within the current fiscal year.
    - While Article 84 is not clear on timing of approval, the Supreme Court referenced the Rules and Procedures and Conduct of Business in the National Assembly 2007 to conclude that “in the case of supplementary grants, the assent of the National Assembly is to be obtained before these funds are made available.”
  - A petition to overturn this judgement was presented by the Government to the Supreme Court in 2014 but was dismissed.
- Despite the Supreme Court’s final and binding judgement supporting ex-ante approval, laws and rules can be amended to ensure greater certainty and clarity on interpretation and application:
  - In 2019, a Constitutional Amendment was proposed to the Senate to revise Article 84 to require prior resolution from the National Assembly before the approval of supplementary grants, except in emergencies; the Bill failed to secure the necessary Constitutional majority.
  - Possible mechanisms to enshrine the Supreme Court judgement include:
    - Amending the PFMA (e.g., Article 10) and the General Financial Rules 2019 (Rules 96-196);
    - Reinstating the principle of ex-ante approval in the GFR;
    - Another attempt at amending Article 84.
  - Legal experts within the Ministry of Justice are identified as best placed to advise the Federal Government on the approach in light of the Supreme Court judgment.

*Italic line: Source. IMF Mission*

### 46.      Future attempts to tighten the use of supplementary grants must tackle the primary

### 46.      Future attempts to tighten the use of supplementary grants must tackle the primary

### Supplementary grants and contingency reserves
- Central justification for current approach: maintaining flexibility in budget management.
- Caretaker government example: currently overseeing the budget without resorting to supplementary grants, illustrating that strong commitment can achieve effective budget management without total flexibility.
- Proposed viable solution: provide the government with limited, rather than unrestricted, flexibility by:
  - Setting upper limits on supplementary grants.
  - Establishing a contingency reserve.
- Country experiences (Box 6 summary):
  - A large majority of OECD countries set allowances for emergencies in their annual budget.
  - Sweden and Latvia: specific safety margins set in their budgets.
  - Australia, New Zealand, Germany: emphasize setting a prudent policy stance instead of a specific margin.
  - South Africa (under the PFM Act): the executive can allocate up to 2% of total appropriations for emergencies without legislative approval; significant modifications require an adjustments budget.
  - United Kingdom: reserve fund amounting to 2% of the last year's budget for unforeseen expenses.
  - France: contingency reserve of 0.1 percent of the total budget; French law permits limited transfer of funds within and across missions under programs and missions.
- Suggested process reforms:
  - Determine the size of the reserve margin by examining the size of unexpected calls on the budget in recent years (e.g., depreciation of the rupee, weather-related shocks).
  - Temper analysis with a relatively conservative approach to maintaining reserves to prevent unwarranted calls on them during budget execution.
  - Stipulate rules for accessing the fund in the PFMA, complemented by guidelines issued by the Finance Division.
  - Intensify examination by the Finance Division and Finance Committees in the National Assembly of the budgetary impact of requests for supplementary grants; formalize this process through legislative measures.
  - Require endorsement of supplementary grants only after reviewing in-year fiscal performance and forecasts for the rest of the year; make publication of these mandatory.
  - With a reasonable reserve margin set aside, Cabinet should make clear at the start of the financial year that there will be no recourse to supplementary grants, while technical supplementary grants will be highly regimented and only approved in exceptional circumstances.
- Audit proposal:
  - Undertake a special audit of the efficiency of supplementary grants over the past decade; the review could be assigned to the Auditor General to provide insights into reasons for and impact of supplementary grants and to support reform.

### Strengthening commitment controls
- Importance:
  - Commitment control is a key instrument to ensure budget implementation as planned and to avoid expenditure arrears.
  - International practice shows increased focus on ex-ante controls over expenditure commitments and controlling accumulation of accrued liabilities.
  - Commitment Control Guidelines refer to expenditure arrears from previous years as a major source of fiscal indiscipline and poor budget credibility.
- Legal and procedural framework:
  - PFM Act (section 26): Finance Division shall approve, and issue guidelines related to annual and multi-annual commitment control systems.
  - Release of budget is done through the Schedule of Authorized Expenditure to each ministry and to AGP (Accounting Policies and Procedures Manual section 3.3.11).
  - Accounting Manual section 4.2.2 defines sanctioning of expenditure: Budget Availability Review (Commitments Control) and raising of a Purchase Order.
  - Commitment Control Guidelines issued in March 2022 further outline procedures.
- Definition and gaps:
  - The Guidelines define an expenditure commitment as “an obligation to make a future payment, the funds for which are reserved against the allocated budget of an entity.”
  - Despite the definition, commitments are only registered in FABS when the approved Payment Voucher (Payment Order) is presented to the Controller General of Accounts, which may allow more than one procurement activity on a single budget line.
- Best practice recommendation:
  - Apply principle of pre-commitment or reservation to set aside an allotment for a future expenditure prior to legal commitment, useful for lengthy procurement processes.
  - Risk: linkage between FABS and e-Pakistan Acquisition and Disposal System (ePADS) has yet to be implemented.
- Scope limitations and international good practice:
  - Commitment controls in Pakistan exclude interest payments, payroll expenses and pensions.
  - Spending covered by commitment controls in 2021-22 constituted less than 10 percent of total expenditure at the Federal level.
  - International practices recommend all expenditure classes be covered; where expenditure is subject to ongoing contract or statutory obligations, an estimate should be treated as a commitment.
  - Specific system actions recommended:
    - Implement Organization & Management (O&M) Module of SAP to lock payroll against sanctioned posts.
    - Establish linkages of IT systems in the EAD, Debt Office and PF Wing in the Finance Division and close coordination with FABS for interest payments and provincial transfers.
- Systems and process capture:
  - Several expenditure stages are manual and not presently captured in FABS.
  - New FABS functionalities (e.g., On-Line Bill Submission) are being developed to capture commitments earlier, but FABS will still not capture all budget execution information as international good practice recommends.

### Digitalizing the budget process
- Progress and systems:
  - Pakistan has advanced in digitalizing PFM processes, particularly budget execution; according to the World Bank’s GovTech maturity index digitalization of PFM in Pakistan is broadly equivalent to its peers.
  - FABS supports budget preparation and execution; captures budget data and processes for more than 33,000 cost centers across government, of which 5,500 are at the federal level.
  - FABS department implemented a Data Warehouse providing dashboards to stakeholders.
  - Development projects planning/implementation supported by Intelligent Project Automation System (iPAS); procurement supported by ePADS.
  - FABS plans to employ the e-Office system to interface with FABS and reduce required FABS licenses.
- DIPAT assessment framework:
  - Analysis used the IMF's Digitalization of PFM Assessment Tool (DIPAT) which identifies five states of digitalization: (i) manual; (ii) digitization; (iii) paperless; (iv) re-engineering; (v) transformation.
  - DIPAT identifies five domains enabling effective digitalization (FEED): (i) IT system features; (ii) data governance; (iii) regulatory framework; (iv) IT infrastructure; (v) governance and capacity.
- Current state of budget preparation:
  - DIPAT assessment concluded budget preparation is predominantly manual.
  - Development project budget process fully digitalized in iPAS; recurrent expenditure budget preparation remains manual.
  - Process steps:
    - After BCC issuance, PAOs prepare budget submissions separately for recurrent and development spending.
    - Once BSP is approved and IBCs issued, PAOs prepare detailed budget estimates through budget orders and New Item Statement forms.
  - Use of FABS occurs only at the last stage of budget preparation for consolidation.
  - Due to lack of integration between iPAS and FABS, data for development projects are manually captured in FABS despite iPAS digitalization.
- Past digitalization attempt and next steps:
  - 2019 attempt: Ten divisions used SAP Budget Preparation Module; effort abandoned after key personnel left FABS.
  - Renewing this effort should include review and possible redesign of budget preparation process with stakeholder consultation (e.g., Planning Division).
  - Opportunity to incorporate elements relevant for budget execution currently not prepared, such as procurement plans and expenditure plans for all expenditure classes.
  - An expert is currently being hired at FABS to support this effort.

### Recommendations (Section C)
- Recommendation 8. Initiate legal changes required to limit the discretionary powers granted to the Federal Government over the use of supplementary grants, while maintaining some flexibility in budget execution.
- Recommendation 9. Request the Auditor General to undertake a special audit on the mechanism, efficiency, and effectiveness of supplementary grants over the last ten years.
- Recommendation 10. Review the various stages of commitment controls to make them comprehensive and aligned with international good practices and redesign the budget execution process accordingly.

*Source: IMF mission*

### 59.      The DIPAT found that some stages of the current budget execution process are still

### The DIPAT assessment of budget execution digitalization

### Current budget execution process and key findings
- Some stages of the current budget execution process are still manual:
  - Cost centers manually validate if planned expenditure can be accommodated by the budget released by the Budget Wing (commitment ceiling).
  - After procuring goods and services the Payment Voucher is presented to the Controller General of Account (CGA) department for registration in FABS; this is the first registration in FABS.
  - After successful processing, a check is issued, signed by CGA staff, and sent to the relevant Cost Center for handing over to the vendor.
  - After the check has cleared, a laborious process of devolving the used check from the bank to the CGA is carried out to finalize the bank account reconciliation.
- Most steps are undertaken through FABS, although some processes remain manual (examples: a budget availability check and preparation of claims, approval of expenditure, presentation of checks to vendors, and bank account reconciliation).
- The FABS department is working on several parallel initiatives that will partly digitalize budget execution; however, digitalization of commitment controls will be incomplete after these initiatives and several major expenditure classes (e.g., interest payments and payroll) will be excluded, as will the pre-commitment and reservation stages of the budget execution cycle.

### Transition plans, timelines, and expected functionalities
- Authorities are transitioning to a new model for budget execution; new systems and functionalities expected to be rolled out in the next 2-4 years:
  - (i) the online submission of bills;
  - (ii) the ePADS;
  - (iii) the e-Office, which would provide an interface to the FABS system and reduce the number of required FABS licenses to improve FABS access;
  - (iv) electronic payments (EFT – electronic funds transfer);
  - (v) automated bank account reconciliation.
- The FABS department is reviewing the SAP commitment control module to improve commitment controls.
- When all these initiatives have been implemented (the expected time horizon is 2-4 years) the budget execution process will be predominantly digitized with a few steps still manual, including pre-commitment control and funds reservation.

### FABS, staffing, and IT infrastructure
- FABS overview:
  - FABS has been the core of the Pakistan PFM system since 2006.
  - It is based on the SAP system and comprises a total of 14 SAP modules.
  - Accounts for all cost centers at federal and provincial level are processed through FABS.
  - The FABS department has not applied standard SAP methods for developing the FABS functionality which hinders upgrades of FABS provided by SAP.
- User access and terminals:
  - At the federal and provincial level 500 terminals across cost centers have access to enter transactions into SAP, but this number is expected to increase.
- Staffing:
  - The FABS department is established with 61 staff, but currently only half of these positions are filled.
  - Since 2019 FABS has lost about half of the staff, including many SAP programmers.
  - Due to a government-wide hiring freeze the department has not been able to replenish positions but recently the recruitment of new staff has been approved.
  - The FABS Director expects that during the first quarter of 2024 most of the vacant positions will be filled.
- IT infrastructure:
  - The FABS department administers the FABS infrastructure, including several data centers to support FABS operations and disaster recovery but none of these centers has a ‘Tier-3’ security status and is subject to some operational risk.
  - The FABS department is working to expand network access through secure channels which will enable an expansion of the number of connected FABS users.
  - User connectivity to FABS is generally stable but the FABS department could consider preparing plans for elevating the tier grading of data centers.

### Fiscal Data Governance (FDG) and data flows
- Data warehouse and quality:
  - The FABS department has implemented a Data Warehouse (DW) solution to collect and store fiscal data from various systems not directly linked to FABS; data are then presented through several dashboards.
  - The FABS department has not been able to monitor and ensure the quality of data delivered to the data warehouse.
  - Although the sources are audited by the Auditor General of Pakistan this does not guarantee the data quality.
- Data sources and timeliness:
  - The Data Warehouse collects data from various sources, including the Federal Revenue Board, SOEs, external and internal debt management, and the State Bank of Pakistan.
  - Budget execution and non-tax revenues at both federal and provincial level are captured (albeit often with some delay) in FABS.
  - Several data sources outside FABS deliver information to the Data Warehouse with significant delay: most external data is consolidated within 20 days and a few pockets of data are delivered with a delay of up to 90 days.
- Suggested FDG actions:
  - In the best case, FABS and the Ministry of Finance would have a legal mandate to request data sources to connect to the Data Warehouse and deliver information to FABS in real-time.
  - The FABS department could consider dedicating resources to monitor and ensure high-quality fiscal data in DW.
  - A tailored Fiscal Data Governance program could be designed to support strong FDG practices, including wider government policies. FAD can help the authorities in developing a tailored FDG program.

### Regulatory framework and governance of digitalization
- Regulatory framework:
  - The Electronic Transactions Ordinance Act (2002) legalizes the use of electronic signatures and electronic records.
  - The PFM regulatory framework generally lacks reference to FABS and does not specify the use of FABS as a mandatory element in digitalizing PFM processes.
  - No FABS user manual has been prepared and the on-line support to FABS is limited, though the FABS department has established a call/support center.
  - The regulatory framework fails to identify the Finance Division as the authoritative entity in questions concerning FABS, Fiscal Data Governance (FDG), data delivery and data exchange; this has the implication that several entities have not met requests of the Finance Division to deliver timely data to FABS.
  - Going forward, the legislation could be amended to include considerations regarding digital privacy, cybersecurity and provide guidelines for use of artificial intelligence in PFM related decision-making processes.
- Management and governance of PFM digitalization:
  - Digitalization efforts in the MoF are not supported by a costed medium-term reform strategy with time bound objectives and priorities.
  - A few projects (for example the implementation of the SAP commitment module and the roll-out of on-line Bill submission) have been incorporated in the development budget as capital expenditure.
  - There does not seem to be an overall costed plan for digitalization efforts, complicating prioritization, planning, monitoring, coordination, and evaluation.
  - The wide variety of stakeholders points to the need for overall coordination; other countries have established a high-level committee to coordinate digitalization efforts, a mechanism currently absent in Pakistan.
  - Process design and reengineering are required: FABS does not capture all steps in business processes, which prevents full automation and maintains manual interventions and paper documentation.

### Opportunities for leapfrogging and suggested masterplan elements
- The FEED analysis indicates conditions are in place for implementing a “Paperless” state of digitalization, but further work is needed to support the “Reengineering” state.
- Addressing governance, coordination, and planning could allow PFM digitalization to leapfrog the digitization and paperless stages directly to re-engineering.
- Box 7 suggested elements in a PFM Digitalization Masterplan (selected items):
  - Master plan objectives: Coordinate and prioritize PFM digitalization initiatives; plan and cost initiatives to ensure affordability and value.
  - Governance arrangements: Supported and monitored by a High-level Steering Committee; the FABS Department to constitute a Secretariat to service the Steering Committee.
  - Possible prioritized digitalization initiatives:
    - Review FABS support to the budget execution process to improve commitment controls, full roll-out electronic payments, integration with iPAS and ePADS, and use of e-Office.
    - Review and implement a fully digitalized budget preparation process.
    - Review FDG practices including interoperability to ensure high quality fiscal data to support data driven decision making.
    - Increase FABS Department staff and prepare a capacity building plan.
    - Finalization of re-coding of FABS (SAP) customized modules to allow for version update of FABS.
  - Note: As SAP life support to the current version comes to an end in 2025, this may be an opportunity to reconsider a different approach towards less centralized, open-source, scalable solutions.
  - Medium to longer term elements: build capacity in Fiscal Data Governance, Data Exchange, project management tools (PMI and PRINCE II); change management and communication strategy; plan for deployment of further functionalities based on the FABS Conceptual Framework; plan for investment in Data Center upgrades, increase of on-line access to FABS and an upgrade of user infrastructure.

### Quick digitalization gains identified by DIPAT
- Potential quick gains include:
  - (i) review and revision of FABS support to the budget execution process to improve commitment controls and fully roll-out electronic payments;
  - (ii) review and implementation of a fully digitalized budget preparation process;
  - (iii) review of FDG practices, including data exchange and regulatory framework, to ensure timely delivery of quality fiscal data thus enhancing fiscal monitoring and reporting;
  - (iv) overall improvement of the coordination and implementation of fiscal digitalization by preparing a Digitalization Masterplan supported and monitored by a high-level Steering Committee.

### Recommendations (as listed)
- Recommendation 11. Prepare a costed PFM Digitalization Masterplan with time bound objectives and priorities reflecting the considerations in Box 7.
- Recommendation 12. Establish a high-level Steering Committee to monitor and guide the implementation of the Digitalization Masterplan.
- Recommendation 13. Review and update the regulatory framework to ensure that the MoF has the authority to request comprehensive and timely delivery of fiscal data of adequate quality to the FABS data warehouse and prepare Fiscal Data Governance guidelines.
- Recommendation 14. Review process designs of budget preparation and budget execution to reflect new and future requirements.

*Source: IMF — DIPAT assessment and related sections (extract).*

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_Source: https://www.imf.org/-/media/files/publications/tar/2024/english/tarea2024099-print-pdf.pdf_