At Josh and Mak International, we are committed to providing detailed legal guidance on regulatory and technical standards for the energy sector. This article offers a comprehensive overview of the Pakistan Gas Network Code, which was established to regulate the use of the gas pipeline transportation system. This code outlines the framework for third-party access to the gas transportation network, promoting fair, transparent, and non-discriminatory practices.

Scope and Application

The Pakistan Gas Network Code was developed to support the government’s objective of opening the gas market to third parties. This initiative aims to address the country’s energy shortfall, secure energy supplies, and promote economic growth by enhancing competition in the gas market. The code applies to various stakeholders, including gas transmission and distribution licensees, gas sale and system use licensees, and connected system operators.

Key Articles and Provisions

Article 1: Definitions and Interpretation This section provides detailed definitions and interpretations of key terms used throughout the code. Understanding these definitions is crucial for ensuring compliance and clarity in applying the code’s provisions.

Article 2: Capacity This article outlines the capacity allocation methodology, including transportation obligations, capacity provision, application, and allocation processes. It also covers capacity overruns, hoarding, and transfers (both permanent and temporary). The methodology ensures efficient use of the gas pipeline transportation system and prevents anti-competitive practices.

Article 3: Balancing The balancing provisions ensure that gas deliveries and withdrawals are appropriately managed. It details the responsibilities of the transporter and shipper, balancing charges, and the reconciliation process. The article also outlines the daily discipline and monthly reconciliation processes, ensuring accurate and fair allocation of gas quantities.

Article 4: Shrinkage Shrinkage refers to the additional gas required to maintain system integrity, including system use gas (SUG) and transportation losses (TL). This article explains how shrinkage gas is accounted for and the procedures for adjusting shipper withdrawal quantities.

Article 5: Entry Points This section specifies the requirements for connecting to the gas pipeline transportation system at various entry points. It includes provisions for connected systems agreements and system entry conditions, ensuring that gas delivered meets the required specifications.

Article 6: Exit Points The exit points article outlines the requirements for withdrawing gas from the system. It covers system exit provisions, transporter entitlements, and restrictions on gas withdrawal. The article also includes provisions for non-acceptance of specification gas by the shipper.

Article 7: Nominations and Renominations This article details the process for scheduling gas deliveries and withdrawals. It covers types of nominations, nomination schedules, and the daily nomination process. It also includes provisions for handling under/over deliveries and scheduling charges.

Article 8: Delivery of Gas: Title and Risk This section explains the transfer of custody and risk of gas between the shipper and transporter at entry and exit points. It outlines the responsibilities of both parties to ensure safe and efficient gas delivery.

Article 9: Allocations The allocations article describes the procedures for allocating gas quantities at entry and exit points. It ensures that gas deliveries are accurately measured and allocated based on agreed methodologies.

Article 10: Measurement and Testing This article sets out the procedures for measuring and testing gas quantities. It includes requirements for metering equipment, calibration, and error correction, ensuring accurate and reliable measurement of gas deliveries.

Article 11: Specifications: Quality and Pressure The specifications article defines the quality and pressure standards for gas delivered and withdrawn from the system. It ensures that gas meets the required specifications for safe and efficient transportation.

Article 12: System Planning This section covers the planning and expansion of the gas transportation system. It includes requirements for system expansion plans and the procedures for approving and implementing these plans.

Article 13: Operation, Maintenance, and Repair of Facilities This article outlines the requirements for maintaining and repairing the gas transportation system. It includes provisions for scheduled and unscheduled maintenance, ensuring the system remains safe and reliable.

Article 14: Emergencies The emergencies article details the procedures for handling emergencies affecting the gas transportation system. It includes steps for responding to emergencies, emergency contacts, and the responsibilities of the transporter and shipper during emergencies.

Article 15: Taxes and Duties This section outlines the responsibilities for paying taxes and duties related to gas transportation. It ensures compliance with applicable tax laws and regulations.

Article 16: Dispute Resolution The dispute resolution article provides procedures for resolving disputes between parties. It includes provisions for technical disputes, arbitration, and handling claims related to gas theft.

Article 17: Confidentiality This article ensures that confidential information shared between parties is protected. It outlines the obligations of parties to maintain confidentiality and the consequences of breaching confidentiality agreements.

Article 18: Invoicing, Payment, and Gas Theft This section covers the procedures for invoicing, payment of tariffs, and handling gas theft. It includes provisions for late payment surcharges, set-offs, and remedies for non-payment.

Article 19: Force Majeure The force majeure article defines events that may excuse parties from their contractual obligations due to circumstances beyond their control. It includes procedures for handling force majeure events and the consequences of such events on contractual obligations.

Article 20: Liabilities and Indemnities This article outlines the liabilities and indemnities of parties involved in gas transportation. It includes provisions for indemnifying parties against claims and limiting liability for certain types of damages.

Article 21: Modifications The modifications article provides procedures for amending the network code. It includes provisions for the approval process, urgent modifications, and the role of the Code Modification Panel.

Article 22: Credit Issues This section addresses credit requirements for shippers, including transportation tariffs and commodity deposits. It ensures that shippers meet the financial requirements for accessing the gas transportation system.

Article 23: Governing Law The governing law article specifies the jurisdiction and applicable law for the network code. It ensures that the code is interpreted and enforced under the relevant legal framework.

Article 24: Notices This article outlines the methods for delivering notices between parties. It includes provisions for delivery methods, timing, and the language of notices.

Article 25: Tariff The tariff article details the calculation and payment of tariffs for gas transportation. It includes provisions for capacity charges, utilization charges, and examples of tariff calculations.

Article 26: Customer Point Administration This section covers the administration of customer points, including transfer applications and objections. It ensures that customer points are managed efficiently and transparently.

Article 27: Miscellaneous The miscellaneous article includes various provisions related to the network code, such as assignment of rights, headings, appendices, and ineffective provisions.

Legal and Operational Implications

Compliance: Adherence to the Pakistan Gas Network Code is essential for ensuring safe, efficient, and fair access to the gas transportation system. Non-compliance can result in legal and financial penalties, as well as operational disruptions.

Safety and Risk Management: The code provides a comprehensive framework for managing safety and risks associated with gas transportation. By following the guidelines, parties can mitigate risks and enhance the overall safety of the gas transportation system.

Fair and Transparent Practices: The code promotes fair and transparent practices in the gas market, ensuring non-discriminatory access to the transportation system. This fosters competition and helps achieve the government’s objective of a competitive gas market.

Dispute Resolution: The dispute resolution mechanisms outlined in the code provide a structured approach for resolving conflicts between parties. This ensures that disputes are handled efficiently and fairly, minimizing disruptions to gas transportation.

Financial Implications: The code includes detailed provisions for invoicing, payment, and handling financial disputes. This ensures that financial transactions related to gas transportation are transparent and predictable.


The Pakistan Gas Network Code establishes a robust framework for regulating the use of the gas pipeline transportation system. At Josh and Mak International, we are dedicated to helping our clients navigate these complex regulations, ensuring compliance and efficient operations. For detailed advice and support, please contact our expert team at 

Critical Analysis of the Pakistan Gas Network Code


While the Pakistan Gas Network Code provides a comprehensive framework for regulating the use of the gas pipeline transportation system, several areas require critical examination. At Josh and Mak International, we aim to provide a balanced analysis by highlighting potential shortcomings and areas for improvement in the code.

Identified Shortcomings

Complexity and Accessibility The Pakistan Gas Network Code is dense and highly technical, which can be challenging for stakeholders who lack extensive experience or legal expertise in the gas industry. The complexity of the document may hinder smaller or new market entrants from fully understanding and complying with the regulations, thus potentially limiting competition.

Ambiguity in Definitions While the code provides detailed definitions in Article 1, some terms remain ambiguous or overly broad. For instance, the definition of “force majeure” could benefit from more precise language to prevent disputes over what constitutes a qualifying event. Additionally, the term “confidential information” could be better defined to avoid potential conflicts regarding what information should be protected.

Capacity Allocation and Hoarding The capacity allocation methodology outlined in Article 2 aims to ensure efficient use of the gas pipeline system. However, the provisions related to capacity overruns and hoarding might not be stringent enough to prevent anti-competitive practices. There could be more robust measures to penalize or prevent capacity hoarding, which can undermine fair access to the network.

Balancing Mechanism Article 3 on balancing lays out the responsibilities for gas delivery and withdrawal management. While comprehensive, the balancing charges and reconciliation process might be too complex, leading to administrative burdens for shippers. Simplifying these processes could reduce operational inefficiencies and compliance costs.

Dispute Resolution Mechanism The dispute resolution provisions in Article 16 are crucial for handling conflicts between parties. However, the reliance on arbitration and technical dispute resolution might not be accessible or affordable for all parties. There is a need for a more streamlined and cost-effective dispute resolution process that can quickly and fairly address smaller disputes without resorting to expensive arbitration procedures.

Confidentiality Provisions Article 17 emphasizes the importance of maintaining confidentiality. However, the penalties for breaching confidentiality agreements are not clearly defined, which could lead to inconsistent enforcement. More explicit penalties and clearer guidelines on managing confidential information could strengthen these provisions.

Force Majeure Article 19 deals with force majeure events. The code could improve by providing a more exhaustive list of events considered as force majeure and the specific procedures for invoking and handling such events. This would reduce the risk of disputes and ensure that all parties have a clear understanding of their obligations during unforeseen circumstances.

Credit and Financial Requirements Article 22 on credit issues sets out financial requirements for shippers, including tariffs and deposits. These requirements might be burdensome for smaller companies or new market entrants, potentially stifling competition. Introducing more flexible financial requirements or providing support mechanisms for smaller entities could help foster a more competitive market environment.

Regulatory Oversight and Enforcement While the code outlines various responsibilities and procedures, there is a need for stronger regulatory oversight and enforcement mechanisms. The current provisions may not adequately deter non-compliance or address violations effectively. Enhanced oversight and stricter penalties for non-compliance could improve adherence to the code.

Periodic Review and Updates The code should include a more structured approach for periodic review and updates. The energy sector is dynamic, and regulatory frameworks need to adapt to technological advancements and market changes. Establishing a regular review process involving all stakeholders can ensure that the code remains relevant and effective.


The Pakistan Gas Network Code is a well-structured and comprehensive regulatory framework for managing the gas pipeline transportation system. However, addressing the identified shortcomings can enhance its effectiveness, accessibility, and fairness. At Josh and Mak International, we are committed to helping our clients navigate and comply with these regulations while advocating for continuous improvements to the legal framework. For detailed advice and support, please contact our expert team.

By The Josh and Mak Team

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