A multinational digital services conglomerate operating digital marketplace platforms across transport, commerce, logistics, entertainment, and enterprise solutions engaged RIAA Barker Gillette for comprehensive advice on Pakistan’s regulatory framework. The client operates a super-app platform providing technology-enabled services across multiple jurisdictions..
The engagement required analysis across consumer protection, advertising regulation, and competition law. On consumer protection, we advised on obligations for accuracy, transparency and clarity in promotional communications, confirming that advertisements must be truthful, legible and not omit material information. We addressed liability for non-compliance, including consumer tribunals’ powers to impose fines, order compensation and withdraw misleading promotions.
Competition law complexities formed a crucial component, particularly as to analysis of provisions concerning deceptive marketing and anti-competitive practices. We analyzed potential risks arising from deep discounts, promotional codes and subsidized delivery offers under the Competition Act, 2010, including the Competition Commission of Pakistan’s powers to investigate predatory or exclusionary conduct. We provided an analysis of the CCP’s investigative procedures, including obligations to determine the “relevant market” and the power to issue warnings and initiating formal proceedings, providing guidance on managing regulatory scrutiny.
The advice covered also regulation of advertisements across broadcast, online, and outdoor media channels. We guided the client on responsibilities imposed by the Pakistan Electronic Media Regulatory Authority Ordinance, 2002 for their digital services operations, alongside local government requirements for physical promotional placements. This comprehensive framework ensured the client understood enforcement mechanisms across different advertising mediums.
“This assignment combined different strands of law – advertising, consumer protection, and competition – within the context of Pakistan’s rapidly growing digital economy,” observed Mazhar Bangash, Partner and Head of International Trade at RIAA Barker Gillette. “Our comprehensive advice provided the client with clarity on how enforcement may unfold in practice while ensuring their operations align with Pakistan’s regulatory framework. The engagement demonstrates RIAA’s capability to advise technology ecosystems navigating regulatory frameworks in Pakistan. As super-app platforms expand across multiple service verticals, such advice becomes essential for ensuring compliance while maintaining operational efficiency.”
Our team advising on this matter was led by Mazhar Bangash (Partner – Pakistan), with support from Momin Taufiq Khan, Senior Associate.
For guidance on local law compliance for digital services platforms, please contact Mazhar Bangash today.
This article is not legal advice; it provides information of general interest about current legal issues.
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RIAA Barker Gillette is Pakistan’s premier law firm, with an on-the-ground presence in three major cities in Pakistan: Karachi, Islamabad and Lahore, and affiliated offices in Dubai (DIFC) and London.
The firm practices in all areas of corporate, commercial and dispute resolution law. Leading international legal directories consistently recognise the firm as a top-tier law firm in Pakistan.
RIAA Barker Gillette is the exclusive member firm in Pakistan for Lex Mundi, the world’s leading network of independent law firms with in-depth experience in over 125 countries worldwide.
