Pakistani law does not hand an online store a ready-made set of website terms or a privacy policy, but several laws decide what those documents must cover and what they cannot do. The Electronic Transactions Ordinance 2002 makes online contracts and records valid; provincial consumer laws, such as the Punjab Consumer Protection Act 2005, require a return and refund policy before the sale, bar terms that exclude liability, and since 2025 expressly cover online transactions in Punjab; and the Prevention of Electronic Crimes Act 2016 governs marketing messages and the misuse of customers’ identity information.
Are click-to-accept terms binding in Pakistan?
The Electronic Transactions Ordinance 2002 deals with this directly. Section 3 says no document, record, information, communication or transaction is to be denied legal recognition, validity or enforceability on the ground that it is in electronic form and has not been attested by a witness. Section 4 treats a legal requirement for writing as met by an electronic record that stays accessible for later reference. Section 13 treats an electronic communication sent by an automated information system programmed by or on behalf of the originator as the originator’s own, unless otherwise agreed, so the safe course is to treat automatic order confirmations as your own communications. Section 6 allows records to be kept electronically if, among other conditions, they remain accessible for later reference.
Checklist:
- Show the terms before payment and record which version each customer accepted, with the date.
- Keep order confirmations and accepted terms in a form you can retrieve and print later.
- Say when an order becomes a contract, for example when you confirm it rather than when the customer clicks “buy”.
Which consumer law applies to an online store?
Pakistan has separate consumer protection Acts for Islamabad and each province. The Punjab Consumer Protection Act 2005, as amended by the Punjab Consumer Protection (Amendment) Act 2025, now defines buying a product or hiring a service to include online transactions through electronic means, teleshopping, direct selling and multi-level marketing (section 2(c), Explanation). The federal government’s e-Commerce Policy of Pakistan (Commerce Division, 2019; archived copy) lists the other consumer laws: the Islamabad Act of 1995, the Sindh Act of 2015, the Khyber Pakhtunkhwa Act of 1997 and the Balochistan Act of 2003. If you sell across Pakistan, we confirm in each matter which provincial Act applies. The points below follow the Punjab Act.
What must the terms say about returns, prices and receipts?
- Return and refund policy: section 20 requires a seller to disclose its return and refund policy clearly before the transaction is completed. The Act refers to “a sign at the point of purchase” and does not mention websites, so the safe course is to show the policy on the product page and at checkout.
- Receipt: section 19 requires a receipt showing the date of sale, a description of the goods, the quantity and price, and the seller’s name and address. An emailed order confirmation can carry all four.
- Prices: section 18 requires a manufacturer or trader to display prices prominently in the shop or display centre unless a price catalogue is available. The e-Commerce Policy’s Code of Conduct also says prices should be clearly displayed on the website or app.
- Product information: where ingredients, quality or manufacture and expiry dates matter to the buyer’s decision, section 11 requires the manufacturer to disclose them.
Can website terms limit the store’s liability?
Only within limits. Under sections 12 and 17 of the Punjab Act, liability for defective products and faulty services cannot be limited or excluded by contract terms or by notice. Section 21(j) prohibits false, deceptive or misleading representations about the existence, exclusion or effect of any condition, right or remedy, among other matters. The safe course is to avoid a clause telling customers they have “no right to a refund under any circumstances”. Section 22 also bars advertising goods at a price you do not intend, or cannot reasonably expect, to supply them at.
What should an online store’s privacy policy cover?
The e-Commerce Policy of Pakistan (Commerce Division, October 2019) annexes a Code of Conduct for all e-commerce businesses. It says platforms will make full disclosure about data protection on their websites or apps, including the country or legal jurisdiction where data is stored and the purpose for which it may be used. The Policy is a government policy, not an Act; the safe course is to treat its disclosure list as a minimum.
Two sections of the Prevention of Electronic Crimes Act 2016 are also relevant. Section 16 makes it an offence to obtain, sell, possess, transmit or use another person’s identity information without authorisation. Section 25(1) treats intentionally sending unsolicited information to a person without the recipient’s permission as spamming, and section 25(2) requires anyone engaged in direct marketing to give recipients the option to unsubscribe.
Checklist:
- List what you collect, why, where it is stored (including the country), and who receives it, such as couriers and payment providers.
- Get permission before using customer data for marketing, and put a working unsubscribe link in every marketing message.
- Limit staff access to customer identity and payment data.
The 2019 Policy mentions a Personal Data Protection Bill. A bill is not law until it is enacted, so this checklist does not rely on any draft.
What seller and complaint details should the site show?
The Policy’s Code of Conduct says sites should give the seller’s name, address, phone number and email, display a complaint form with contact details, acknowledge complaints, and state the process and timelines for resolving them. A business trading under a different name or domain should show the name registered with the SECP and its CUIN.
Where are consumer disputes heard in Punjab?
Claims for damages under the Punjab Act go to a Consumer Court (section 25). Since the 2025 amendment, the Lahore High Court designates a District Judge or Additional District Judge in each district as the Consumer Court (section 26). Before a claim, the consumer must give written notice, and the seller has fifteen days to reply (section 28(1)–(3)). A claim is generally filed within thirty days of the cause of action, which the court may extend for sufficient cause (section 28(4)). Your terms should name a contact who can answer such a notice in time.
For help drafting or reviewing these documents, see our e-commerce law services.
Frequently asked questions
Is a privacy policy legally required for a Pakistani online store?
The 2019 e-Commerce Policy’s Code of Conduct expects platforms to disclose their data practices, including where data is stored and why it is used. PECA 2016 also restricts the use of identity information, so a clear policy is the practical way to show how you handle it.
Does the Punjab Consumer Protection Act apply to online sales?
Yes. The 2025 amendment says buying or hiring under the Act includes offline or online transactions through electronic means.
Can my terms say all sales are final?
You must disclose your return and refund policy before the sale (section 20). You cannot exclude liability for defective goods or faulty services by contract or notice (sections 12 and 17), or mislead buyers about their rights (section 21(j)).
Are emailed order confirmations valid records?
Under sections 3, 4 and 6 of the Electronic Transactions Ordinance 2002, electronic records are legally recognised and can meet writing and retention requirements if they stay accessible for later reference.
The statutes and the e-Commerce Policy cited here were checked on 15 October 2026 (the Policy from the Internet Archive copy of the Commerce Division file, because the official site did not serve it to us that day). Provincial consumer laws differ; confirm the law of the province where you sell. This post is general information, not legal advice.
