The Digital Nation Act, 2025, represents Pakistan’s attempt to institutionalise digital governance, data exchange, and digital public infrastructure as part of a broader national modernisation agenda. While the Act foregrounds efficiency, interoperability, and centralised coordination through the National Digital Commission and the Pakistan Digital Authority, it adopts a predominantly administrative orientation that is not anchored in technical and inclusive knowledge nor in international human rights norms. When examined through a gender lens and with attention to the rights of religious minorities and transgender persons, the Act reveals significant normative and structural gaps that risk digitising existing inequalities rather than dismantling them.

Pakistan is a State party to the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), which obliges States to eliminate both direct and indirect discrimination and to address structural conditions that disproportionately disadvantage women. Digital governance systems are not neutral tools; when designed without gender-responsive safeguards, evidence suggests that they exacerbate women’s exposure to surveillance, coercion, and technology-facilitated gender-based violence. The Digital Nation Act does not recognise women as a distinct category of rights holders in digital ecosystems, nor does it mandate gender impact assessments, consent-based data processing, or safeguards against misuse of personal data. In a context where women already face high levels of online harassment, blackmail, and digital monitoring, centralised data exchange and digital identity infrastructures without explicit protections are inconsistent with CEDAW’s substantive equality framework, particularly Articles 1, 2, and 5.

From the perspective of the International Covenant on Civil and Political Rights (ICCPR), the Act raises serious concerns relating to privacy, equality before the law, freedom of expression, and access to an effective remedy. Article 17 of the ICCPR protects individuals........

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