ISLAMABAD: Transparency International Pakistan (TIP) has for years scrutinised corruption, governance and transparency in public institutions.
But who scrutinises the watchdog itself — its legal structure, hundreds of millions of rupees in funding, donor relationships, governance arrangements, complaint-handling mechanisms and the methodology it uses to measure corruption?
An examination by The News of TIP’s trust deed, published financial statements, annual reports, governance documents, corruption surveys and court proceedings, along with responses provided by the organisation, raises questions about the extent of independent scrutiny over the anti-corruption watchdog.
TIP is registered as a trust in the Industries and Commerce Directorate of Sindh under the name Transparency International Pakistan Trust. Its trust deed, originally executed in 2002 and subsequently amended, gives the organisation a broad mandate covering transparency in governance, politics and business transactions, combating corruption, implementation of laws and policies, and transparency in the functioning of law-enforcement agencies and government departments involved in regulatory, supervisory or investigative functions.
The Trust Deed expressly covers transparency in governance, politics and business transactions, monitoring corruption, government and private-sector transactions, implementation of laws and policies, and the conduct of law-enforcement and government agencies with regulatory or investigative roles. The questions, therefore, concern the breadth and oversight of that mandate: whether every present activity can be directly linked to the stated objects; whether the broad incidental-powers clause is being used to extend the mandate; who independently determines compliance with the objects; how conflicts are independently resolved when the Board itself oversees them; whether statutory third-party audits and financial reports required under Section 32 of the Sindh Trusts Act 2020 are being filed; and whether TIP’s registration has been renewed annually since its 2021 registration.
Rs832.7m in grants and other income
TIP’s published financial statements show that between 2010 and 2025 it reported grants of about Rs764.6 million and other income of about Rs68.1 million, making a combined reported income of approximately Rs832.7 million over the period.
The annual figures vary considerably. Grants and other income together stood at about Rs28.4 million in 2010, rose to more than Rs84.2 million in 2015 and reached about Rs100.2 million in 2020. They subsequently fell sharply before rising again to about Rs45.4 million in 2024 and Rs55.4 million in 2025.
TIP told The News that its financial information is available in its published audit reports. Its response also said that, during the last five years, its donor was the Transparency International Secretariat, with project details and amounts contained in the financial statements.
However, TIP’s own 2025 Civil Society Governance Diagnostic Assessment acknowledges financial support from the European Union. The available response does not explain whether that support was provided directly to TIP or through the Transparency International Secretariat, nor does it provide the amount in response to questions seeking details of major foreign funding.
The USAID hotline and family connection
TIP operated the USAID Anti-Fraud Hotline project from January 2011 to November 2019. According to TIP, complaints were handled under standard operating procedures approved by USAID’s Office of Inspector General and TIP.
Historical TIP and USAID material shows that the hotline dealt with thousands of complaints and referrals during its operation. But the organisation did not provide in its response a consolidated figure for all complaints handled during the entire project or a detailed assessment of how complaints were independently verified before referral.
The project also raises a governance question concerning the appointment of Fawad Gilani as project manager.
TIP says “Gilani was appointed through public advertisement, shortlisting and a selection committee.” It also says that his relationship with former TIP chairman Syed Adil Gilani was disclosed during his appointment in 2011, when Sohail Muzaffar was chairman.
The issue is, therefore, not simply how the appointment was made, but how potential conflicts of interest were identified and handled under TIP’s own governance rules. The available records also indicate several other instances raising questions of potential conflicts of interest during the tenure of the former TIP chairman, warranting greater scrutiny of the organisation’s conflict-of-interest safeguards.
TIP’s trust deed contains provisions concerning conflicts involving immediate family members of board members in relation to certain paid assignments and employment. The relevant governance records would determine how those provisions applied at the time of the appointment.
Watchdog challenging public contracts
TIP has also increasingly intervened in public procurement matters. Its 2025 annual report says a complaint concerning Nadra originated in May 2022 over a $29.7 million contract for 30 million smart cards. TIP alleged violations of PPRA rules, a single-bid process and pricing above international market levels. It estimated a potential loss of around $25 million.
The Ministry of Interior subsequently directed PPRA to examine the matter, while PPRA constituted a committee. TIP’s annual report says the matter eventually led to an FIA corruption case in 2025.
In another case, TIP said it took up a complaint in November 2025 concerning a more than Rs60 billion dredging contract of Port Qasim Authority and alleged that the contract had been awarded through direct contracting. According to TIP, the federal government subsequently directed that the work be put to public tender.
These cases underline the significance of the organisation’s own complaint-handling and verification mechanisms: when TIP questions the legality or transparency of government procurement, how its own complaints are assessed becomes an important accountability issue.
No independent organisational or forensic audit
TIP told The News that it submits its financial audits to the Federal Board of Revenue (FBR) annually and to the Economic Affairs Division when project funding is approved.
But it also confirmed that it has not undergone an independent organisational, governance or forensic audit beyond its regular financial audit.
The distinction matters because a financial audit primarily examines financial statements and related records. It does not necessarily provide the same level of scrutiny of governance arrangements, institutional independence, research methodology, complaint verification or potential conflicts of interest.
Research for government and IMF
TIP’s 2025 Civil Society Governance Diagnostic Assessment contains 54 recommendations and was submitted to the government of Pakistan and the IMF.
The report examines the functioning of civil society and governance institutions and proposes reforms. TIP’s response says the organisation engages with governments, development partners and international financial institutions to share reports and recommendations and promote their uptake.
The organisation did not provide details in its response about the terms of reference, cost or remuneration arrangements for the diagnostic assessment, instead referring to donor information contained in the report. The report itself acknowledges EU financial support.
Perception is not lived experience
Questions also arise over the methodology used to measure corruption.
TIP’s 2025 National Corruption Perception Survey covered 3,989 respondents in 20 districts across the four provinces. Police were identified as the sector most frequently perceived as corrupt, followed by tendering and procurement and the judiciary. At the same time, 66 percent of respondents said they had not paid a bribe during the preceding 12 months.
A separate Ipsos-FPCCI survey conducted in late 2025 and early 2026 provides an indication of the gap that can exist between perceptions and personal experience. It found that 68% believed bribery was common, while 27% said they had personally faced a demand for a bribe. Similarly, 56% believed nepotism was widespread, compared with 24% who said they had personally experienced favouritism.
The difference does not establish that corruption is low. It shows that perception and lived experience are different measures and should not automatically be treated as interchangeable.
Former deputy chairman of the Planning Commission, Dr Nadeem Haque, has questioned the approach more broadly. He said TI “never questions donors and NGOs working in Pakistan” about the transparency of their own workings and is “merely fixated upon Pakistan’s public sector institutions.”
He also questioned the reliance on perception surveys, saying such surveys fail to account for the underlying context and drivers of institutional performance and reduce complex phenomena to numbers. “Merely relying on numbers is academically ill-advised,” he said. Going through TI’s methodology and record, Haque said, “makes one feel that the levels of corruption are directly correlated to skin color” because white and European-descent countries appear to be the most transparent while non-white countries remain lower in the rankings.
He further questioned the sampling and methodology behind TI reports, saying there was “a little or no sampling” and that detailed sampling methodology remained unexplained, making cross-checking and verification of data difficult.
Haque also questioned the absence of panel-data assessments and methodology application needed for meaningful comparative analysis. In his view, statistical snapshots alone do not explain the underlying complexity and processes behind differences between countries or institutions.
PHC questioned TIP survey methodology
A judicial precedent has also raised questions about TIP’s methodology.
In April 2024, the Peshawar High Court ordered TIP to recall and republish its 2023 National Corruption Perception Survey after examining findings concerning the Khyber Pakhtunkhwa judiciary. The court found deficiencies in “ethical and methodological rigour” and held that the findings concerning the KP judiciary were not credible.
The court examined TIP’s treatment of responses to a question asking whether respondents had actually paid a bribe to access public services. TIP had reported 760 responses to that question, while another 788 responses were not adequately explained.
The court described the unexplained responses as a major flaw undermining the reliability and validity of the findings. It also criticised TIP for failing to adequately disclose the limitation that perception does not necessarily represent reality.
The court directed TIP to explain the unexplained responses, clarify the number of rejected forms, include relevant findings that had not appeared in the original report, state the limitations of the survey and revise the wording concerning the judiciary.
Former Supreme Court judge Justice (R) Dost Muhammad has also questioned the ability of a survey of around 4,000 people to represent a country of more than 240 million people. He raised concerns about the accessibility of large parts of KP and Balochistan and difficult access to interior Sindh and southern Punjab.
He also questioned what “perception” means when used to assess corruption and stressed that a finding should identify where and at what stage alleged corruption occurred, whether procurement, service delivery, construction or another process, rather than simply declaring an institution corrupt on the basis of perceptions.
TIP’s response
TIP rejected any suggestion that its research is influenced by donors or institutions.
“Our research and findings are independent, with no donor or institutional influence, and that our Board provides oversight while internal and external reviews are conducted,” it said.
The organisation said its governance processes, register of interests and complaint-handling procedures are available through its official documents.
On the USAID hotline, TIP said complaints were handled under approved standard operating procedures. On the appointment of Fawad Gilani, it said the recruitment was conducted through public advertisement and a selection process and that his relationship with the former chairman was disclosed. TIP also said it has no corrections to report regarding its published material.
Who scrutinises the watchdog?
The TIP has spent years asking Pakistan’s public institutions to provide greater transparency, disclose information and strengthen accountability.
Its own published records now provide a different set of questions: who independently reviews its governance beyond financial audits, how are donor relationships independently scrutinised and how are complaints verified before they become findings, and how are the sampling and methodology behind national corruption assessments independently tested? TIP said it has not undergone an independent organisational, governance or forensic audit beyond its regular financial audit, while saying its research is subject to Board oversight and internal and external review. For an organisation whose central message is transparency, those questions are part of the transparency test itself.
Originally published in The News
2026-10-08 11:00:00
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