At Josh and Mak International, we provide comprehensive legal guidance on regulatory standards within the energy sector. This article offers an in-depth overview of the Performance and Service Standards Regulations, 2019, issued by the Oil and Gas Regulatory Authority (OGRA). These regulations establish the performance and service benchmarks for licensees engaged in the transmission, distribution, and sale of natural gas in Pakistan.

Scope and Applicability

The Performance and Service Standards Regulations, 2019, are designed to ensure high levels of service quality, safety, and reliability in the gas sector. These standards apply to all licensees undertaking the regulated activities of natural gas transmission, distribution, and sale.

Key Provisions of the Regulations

1. Short Title and Commencement

  • These regulations are cited as the Performance and Service Standards Regulations, 2019, and they came into force immediately upon their publication.

2. Applicability

  • The regulations are applicable to all licensees engaged in the regulated activities of transmission, distribution, and sale of natural gas. Compliance with these standards is mandatory for all such entities.

3. Compliance Compulsory

  • Licensees must comply with the performance and service standards prescribed in these regulations. The Authority, in consultation with licensees, may review, rescind, change, alter, or vary any performance and service standard specified in these regulations.

4. Performance and Service Standards

4.1 Gas Emergencies

  • In cases of gas escapes, fires, or other hazardous situations, licensees must attend as quickly as possible but within one hour for uncontrolled escapes and within two hours for controlled escapes.

4.2 Telephone Calls

  • All calls to service centers must be answered within 60 seconds to ensure prompt customer service.

4.3 Complaints Handling

  • All complaints must be recorded, whether received by phone, letter, electronically, or in person. Licensees must provide a complaint number to the consumer. Complaints about gas smell, asphyxiation, fire, gas pipe breakage, explosion, or building collapse must be addressed as per the standards for gas emergencies. Low-risk complaints should be responded to within 24 hours, while operational complaints are handled on a planned basis.

4.4 Investigation of Pressure Complaints

  • Pressure complaints must be investigated with a site visit within 36 hours of receipt.

4.5 Making and Keeping Appointments

  • For planned work, appointments are made on a morning or afternoon basis. If an appointment cannot be honored, the company must give the consumer a 24-hour notice.

4.6 Notification of Planned Work

  • Work requiring gas supply interruption and entry to the consumer’s premises must be notified at least 10 working days in advance for service line work and at least 5 days for meter-related work.

4.7 Connection to Distribution System

  • The company must promptly respond to all service requests and issue proposal letters as soon as the application falls on turn/merit, provided the connection is technically feasible and does not create discrimination with other consumers in the same locality. Specific distances are defined for domestic, commercial, and industrial premises from the existing gas main.

4.8 Energy and Safety Advice

  • Energy and safety advice must be provided to consumers facing problems. This advice can also be disseminated through gas bills, print, and electronic media.

4.9 Replies to Correspondence

  • Consumers must receive a written reply within 5 working days of receipt of their correspondence. Interim replies should indicate when a full reply can be expected.

4.10 Visits

  • Except in emergencies, meter reading, suspected pilferage, or consumer complaints, the company must attempt to make phone contact for an appointment within 4 days.

4.11 Estimating Procedures for Billing

  • Procedures for estimating gas usage should neither favor the company nor the consumer. Differences between actual and estimated usage must be resolved per the contractual obligations between the company and the consumer.

4.12 Meter Alteration and Replacement

  • Meters should be altered or replaced within 15 working days following acceptance and payment of relevant dues/charges.

4.13 Responding to Meter Problems

  • Complaints about blocked, not passing gas, burnt, or damaged meters must be addressed within 2 days, with replacement done within 5 working days after payment. Sticky or inaccurate meters must be replaced within two months of the complaint.

4.14 Meter Accounts (Meter Reading/Billing)

  • Gas bills should be based on actual meter readings issued every 30 to 45 days. Adjustments for price/tariff should be proportionate to the number of days. Payment due dates should allow a minimum of 7 days for consumers to make the payment.

4.15 Meter Reading Frequency

  • Meters should be read at least once every calendar month.

4.16 Special Meter Reads

  • Special meter read requests must be handled within 3 working days.

4.17 Appointment for Final Meter Reading

  • Final meter reading appointments should be given with at least two days’ notice, in the morning or afternoon.

4.18 Providing Additional Meter

  • Requests for additional meters are treated as new connections and processed on a turn/merit basis.

4.19 Notifying Consumer for Non-payment

  • Notices of non-payment must be printed on forthcoming gas bills in case of consumer default.

4.20 Termination of Service for Default

  • Service termination for non-payment should occur no later than 45 days after the default period allowed in the notice.

4.21 Reconnection after Payment of Dues

  • Reconnection should be completed within one working day after full payment and access availability.

4.22 Refunds to Consumers

  • Refunds should be dispatched within 30 days.

4.23 Backfill, Restoration

  • Trench backfilling and site restoration should be completed within 15 working days of gas supply commissioning.

4.24 Removal of Service Line after Disconnection

  • The service line should be removed if not reconnected within specified periods (180 days for domestic, 60 days for commercial, and 30 days for industrial consumers).

4.25 Contractual Pressure

  • Adequate pressure in transmission pipelines and distribution networks should be maintained to ensure the supply of contractual volumes.

4.26 Compensation

  • Compensation should be paid to consumers adversely affected by non-compliance with service standards as per the procedure approved by the Authority.

4.27 Issuance of First Bill after Commissioning

  • The first gas bill based on actual meter readings should be issued within 90 days of commissioning.

4.28 Issuance of Provisional Bills

  • If the meter is not read during any billing cycle, provisional bills should be issued as per the Gas Supply Contract/Gas Sales Agreement, not continuing for more than three billing cycles consecutively.

4.29 Identity of Company’s Officials

  • All company officials dealing with consumers should carry identification cards.

4.30 Accuracy Test of Meters/On-Site Flow Proving

  • Meter accuracy should be tested within 15 days of a request, with replacements made within two months if necessary.

4.31 Visit of Customer Meter Station

  • Customer meter stations should be visited as per a schedule: once in five years for domestic, once a year for commercial/special domestic, and once in three months for industrial consumers.

4.32 Complaints on Billing

  • Billing complaints should be acknowledged immediately if received in person, or within five working days if received by post. Resolutions should be provided within 15 days if no additional information is required, or within 30 days if additional information is needed.

4.33 Change of Name

  • Name changes should be effected within two billing cycles after receiving a complete application.

4.34 Delivery of Bills through E-mail

  • Consumers should have the option to receive gas bills via email.

4.35 Transparency in Gas Connection Provision

  • Companies should provide a link on their website for applicants to check the status and merit number of their applications.

4.36 Leak Detection and Control

  • Companies should conduct leak detection and rectification according to ANSI/ASME B 31.8 standards.

4.37 Meter Reading Verification

  • A monthly program involving meter reading verification and site checking of industrial/bulk sale consumers should be followed.

Legal and Operational Implications

Compliance: Adhering to these standards is mandatory. Non-compliance can result in legal and financial penalties and impact the reliability and quality of gas services.

Service Quality and Reliability: The regulations ensure high standards of service quality and reliability. Licensees must maintain strict adherence to these standards to ensure consumer satisfaction and operational efficiency.

Safety and Risk Management: By following these standards, licensees can mitigate risks associated with gas supply and distribution, ensuring safety for both consumers and operators.

Transparency and Accountability: The regulations promote transparency and accountability in the gas sector. Clear guidelines for service provision, complaint handling, and billing enhance consumer trust and regulatory compliance.

Consumer Protection: The standards provide robust consumer protection measures, including timely responses to emergencies, transparent billing, and compensation for non-compliance. These measures help safeguard consumer interests.


The Performance and Service Standards Regulations, 2019, establish a comprehensive framework for ensuring high-quality, safe, and reliable gas services in Pakistan. At Josh and Mak International, we are committed to assisting our clients in understanding and complying with these standards, ensuring smooth and efficient operations. For detailed advice and support, please contact our expert team.

By The Josh and Mak Team

Josh and Mak International is a distinguished law firm with a rich legacy that sets us apart in the legal profession. With years of experience and expertise, we have earned a reputation as a trusted and reputable name in the field. Our firm is built on the pillars of professionalism, integrity, and an unwavering commitment to providing excellent legal services. We have a profound understanding of the law and its complexities, enabling us to deliver tailored legal solutions to meet the unique needs of each client. As a virtual law firm, we offer affordable, high-quality legal advice delivered with the same dedication and work ethic as traditional firms. Choose Josh and Mak International as your legal partner and gain an unfair strategic advantage over your competitors.

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