Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Author Note Waqas Faraz is a CA Finalist affiliated with the Institute of Chartered Accountants of Pakistan. The author is currently working as a senior Audit Associate at UHY International Hassan Naeem & Co, Lahore, Pakistan. Correspondence concerning this article should be addressed to: E-mail: waqasfaraz.uhy@gmail.com Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Disclaimer This research paper is an academic and policy-oriented study intended for educational, analytical, and informational purposes only. The views, interpretations, and recommendations expressed herein are those of the author and do not necessarily reflect the official position or policy of any government institution, regulatory authority, or affiliated organization. While every effort has been made to ensure the accuracy of the data, sources, and analyses presented, the author assumes no responsibility for any errors, omissions, or consequences arising from the use of this information. References to government reports, regulatory disclosures, or third-party data are cited in good faith and solely for scholarly critique and comparative analysis. This document is not intended to serve as financial, legal, or policy advice. Readers are encouraged to independently verify all information and consult appropriate experts before making decisions based on the content of this paper. Page 2 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Acknowledgment This research paper would not have reached its present form without the critical guidance and support of several individuals. I am especially grateful to Muhammad Afzal, ACA, Financial Advisor at J & G Group, KSA and Khyzer Tahir, Assistant Manager at PKF F.R.A.N.T.S, PK for their thorough review, constructive feedback, and valuable insights throughout the course of this study. I also wish to acknowledge the contribution of those who provided data access, editorial input, and policy references, as well as the organizations whose reports and publications formed the backbone of this research. Page 3 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Abstract The persistent circular debt crisis in Pakistan’s energy sector, now exceeding Rs. 5 trillion, continues to constrain economic growth, fiscal sustainability, and energy reliability. This research investigates the structural inefficiencies, pricing distortions, and financial mismanagement that have contributed to the chronic buildup of circular debt in the power and gas value chains Drawing on both domestic fiscal policy and international practices, the report evaluates how countries like India and Turkey, have successfully addressed similar circular debt issues through a combination of tariff rationalization, energy market liberalization, subsidy reform, and private sector participation. Comparative insights offer lessons for Pakistan in terms of improving governance, aligning consumer tariffs with economic cost, and implementing sustainable longterm strategies. We propose an integrated roadmap: privatize DISCOs under clear performance contracts; institutionalize automatic quarterly and multi-year tariff frameworks; replace blanket subsidies with targeted direct benefit transfers; empower NEPRA with true autonomy; operationalize the Competitive Trading Bilateral Contract Market (CTBCM); and accelerate renewable energy deployment via competitive auctions and smart-grid investments. Together, these measures aim to resolve liquidity gaps, disrupt the circular debt cycle, and build a resilient, sustainable power sector. Keywords: Circular Debt, Energy Sector Reform, Competitive Trading Bilateral Contract Market (CTBCM), Fiscal Policy, Tariff Rationalization, Energy Governance, Public Finance, Pakistan, India, Turkey Page 4 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Table of Contents I. Introduction ..................................................................................................................... 6 II. Pakistan’s Energy Sector ................................................................................................ 7 III. Causes of Circular Debt .............................................................................................. 10 IV. Global Lessons ............................................................................................................ 14 V. Proposed Solutions— A Holistic and Sustainable Framework to Resolve Circular Debt in Pakistan ......................................................................................................................... 15 VI. Conclusion .................................................................................................................. 18 References ......................................................................................................................... 19 Page 5 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures I. Introduction Circular debt refers to a chain of unpaid obligations where one entity’s failure to fulfill its payment responsibilities creates a domino effect across other entities in the value chain. In simpler terms, if Entity A owes money to Entity B, B owes to C, and C to D, and none of them clear their dues, a cycle of unresolved liabilities is formed — hence, the term "circular" debt. In the context of Pakistan's energy sector, this pattern has become deeply entrenched. Various entities across the energy supply chain — from power producers to distributors and fuel suppliers — owe substantial sums to each other. When one entity experiences a liquidity crunch and fails to make payments, it adversely affects the working capital and receivables of the next. This ongoing cycle of non-payment disrupts financial flows, deteriorates trust within the system, and hampers operational efficiency. The primary objective of this paper is to understand the phenomenon of circular debt in Pakistan’s energy sector—its root causes, structural weaknesses, and the broader economic impact. It seeks to analyze why circular debt arises and persists, and to explore how other countries, such as Turkey and India, have successfully addressed similar challenges through targeted reforms and policy interventions. The study is divided into seven sections for clarity and logical flow: Section 1: Introduction — Defines circular debt and introduces the context of the energy sector in Pakistan. Section 2: Understanding Pakistan’s Energy Sector —an overview of the energy value chain, key players, and Payment Process. Section 3: Root Causes of Circular Debt —examines pricing distortions, governance failures, and financial mismanagement. Section 4: Global Lessons —highlights how countries like India and Turkey tackled circular debt through privatization, tariff rationalization, and governance reforms. Section 5: Proposed Solutions—offers practical and sustainable recommendations for Pakistan, including privatization, fiscal discipline, and tariff alignment. Section 6: Conclusion —summarizes findings and outlines the need for long-term structural reforms. Page 6 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures II. Pakistan’s Energy Sector The key players in the energy sector of Pakistan are as follows. Primary Energy Suppliers These include exploration firms, gas providers, oil refineries, and marketing companies that extract, refine, and supply primary fuel inputs (gas, oil, petroleum) for electricity generation in Pakistan. Generation and Distribution Suppliers This segment covers power generation by independent producers and governmentowned GENCOs/WAPDA, along with transmission and distribution by NTDC/CPPA, K-Electric, and DISCOs responsible for delivering electricity to end users. Page 7 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures End Consumers The final consumers of electricity, including households, industrial users, government departments, and areas like FATA, who are affected by both the pricing and reliability of power supply. Illustration How Circular Debt Emerges As discussed above circular debt emerges due to blockage of cash within the energy eco-system. To understand the magnitude of circular debt, the following illustration how a single default at the consumer level escalates into a multi-layered financial crisis affecting multiple entities across the energy value chain, including generation companies (GENCOs), fuel suppliers, refineries, and exploration firms. 1. Consumer Non-Payment A household in the Federally Administered Tribal Areas (FATA) receives a monthly electricity bill of Rs. 5,000. Due to inadequate enforcement and weak recovery mechanisms, the consumer fails to make the payment. As a result, the local distribution company (PESCO) experiences a direct revenue loss of Rs. 5,000, weakening its liquidity position. 2. DISCO’S INABILITY TO REMIT TO PEPCO PESCO is obligated to remit Rs. 8,000 to PEPCO, which includes Rs. 5,000: Cost of purchased electricity. Rs. 3,000: Tariff differential subsidy (the gap between cost and consumer tariff). Due to the unpaid bill and the pending subsidy from the government, PESCO defaults on this payment. PEPCO, therefore, lacks the liquidity to settle its obligations with power producers. 3. Power Producers Face Cash Flow Disruption PEPCO’s default trickles upstream, disrupting payments to public and private generation companies: GENCO is owed Rs. 3,000 for thermal power production but is unable to pay SNGPL for the natural gas it uses. WAPDA Hydel is owed Rs. 1,000 for hydropower generation but cannot allocate funds for dam maintenance, jeopardizing future power capacity. Independent Power Producers (e.g., Hubco) are owed Rs. 4,000 and, in turn, default on payments to their furnace oil supplier, PSO. 4. Fuel Suppliers and Gas Distributors Affected The financial strain deepens as fuel supply companies face their own defaults: PSO, owed Rs. 4,000 by Hubco, is unable to clear its dues to PARCO, the refinery supplying furnace oil. SNGPL, owed Rs. 2,000 by GENCO, cannot pay OGDCL, the upstream gas producer. Page 8 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures 5. Refineries and Exploration Hit PARCO, deprived of Rs. 3,000 in payments from PSO, struggles to pay OGDCL for crude oil procurement. OGDCL, now facing a cumulative receivable shortfall of Rs. 5,000 (Rs. 2,000 from SNGPL and Rs. 3,000 from PARCO), is forced to scale back its exploration and production activities — undermining the country's long-term energy sustainability. 6. Government Intervention: Bridging the Gap To prevent a total supply chain collapse, the Government of Pakistan steps in through subsidies and borrowing: Subsidy Injection: The government allocates Rs. 3,000 to PEPCO to partially cover the tariff differential. Borrowing: An additional Rs. 5,000 is borrowed from commercial banks to finance urgent payments to OGDCL and PARCO. Total fiscal burden incurred: Rs. 13,000 (5,000(Customer default) + 3,000 (Tariff differential) + 5,000 (Borrowing)), arising from an initial Rs. 5,000 consumer-level default. Page 9 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures III. Causes of Circular Debt Circular debt in energy sector—amounting to Rs. 5.422 trillion as of June 2024—has emerged as a critical economic challenge. This persistent issue stems from a combination of systemic inefficiencies, policy flaws, and financial mismanagement across the entire energy value chain. Below are the major causes of circular debt: a. Operational Causes i. High Transmission & Distribution Losses Transmission and Distribution losses remain one of the most significant operational contributors to circular debt in Pakistan. Despite NEPRA setting allowable loss limits for each DISCO, actual losses have consistently exceeded those benchmarks, resulting in a heavy financial burden on the power sector. Massive Surge in Financial Impact The total financial impact of excess T&D losses has increased alarmingly from Rs. 51.89 billion in FY 2019-20 to Rs. 276.35 billion in FY 2023-24, according to NEPRA’s latest reports. This nearly 433% rise indicates a persistent and worsening inefficiency within the system. Worst Performing Distribution Companies (DISCOs) Below are the worst performers as per NEPRA State of industry report 2024. Page 10 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures ii. Proper Billing and recovery performance The consistent shortfall in recoveries by DISCOs and KE continues to be a critical operational contributor to the ballooning circular debt in Pakistan’s power sector. KE has experienced a steady decline in recovery rates: FY 2021-22: 96.69% FY 2022-23: 92.76% FY 2023-24: 91.54% This declining trend raises alarms about KE’s collection efficiency and reflects deeper structural issues. On the other hand, some DISCOs have reportedly engaged in overbilling practices to artificially reduce reported T&D losses. While this may reflect a lower technical loss figure, it inflates the amount billed to consumers, which remains unrecovered due to its unrealistic nature—thus exacerbating the actual recovery gap and adding up to circular debt. iii. Inefficiencies of Transmission System The under-utilization of transmission infrastructure presents a significant operational inefficiency within Pakistan’s power sector, contributing indirectly to the escalation of circular debt. Despite having substantial transmission capacity, the National Transmission and Dispatch Company (NTDC) reported a sharp rise in under-utilized transformers and lines between FY 2022-23 and FY 2023-24, indicating systemic issues in demand forecasting and load optimization. This inefficiency leads to higher per-unit transmission costs as fixed costs are spread over a reduced electricity volume, ultimately burdening end consumers and limiting reinvestment capacity. Addressing this challenge through better system planning, real-time grid management, and improved coordination with distribution and generation companies is vital for enhancing financial sustainability and operational efficiency. iv. The Burden of Capacity Payments Capacity payments to Independent Power Producers (IPPs) have emerged as a critical financial burden in Pakistan’s power sector, significantly contributing to the accumulation of circular debt. These payments are made to IPPs regardless of actual electricity generation, under long-term Power Purchase Agreements (PPAs) that guarantee a fixed return on investment. As demand stagnates or declines, a growing portion of the total cost is attributed to capacity charges rather than energy consumed, leading to underutilized generation assets and inflated consumer tariffs. In FY 2023– 24 alone, capacity payments reportedly crossed PKR 2 trillion, with nearly 60–70% of total payments made to IPPs being fixed in nature. This model, while initially designed to attract investment, has now strained the sector’s financial viability. Urgent reforms in contract renegotiations, demand forecasting, and alignment of generation with actual needs are essential to mitigate the long-term fiscal impact of these capacity obligations. Page 11 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures b. Leadership and Governance Issues Weak leadership and poor governance structures have significantly contributed to the worsening circular debt in Pakistan’s power sector. The lack of strategic oversight, delayed decision-making, and institutional inertia have impeded necessary reforms in the sector. Key appointments in regulatory bodies and distribution companies are often politically influenced, undermining merit and accountability. c. Political Interference According to NEPRA’s State of Industry Report 2024, recovery shortfalls and operational inefficiencies are exacerbated by a lack of accountability and frequent changes in leadership, driven by political agendas rather than performance metrics. Moreover, the World Bank (2023) has emphasized that depoliticizing energy sector governance is crucial to reducing fiscal burden and restoring investor confidence. Unless structural reforms are introduced to ensure institutional autonomy and transparency, the power sector will remain vulnerable to political cycles, undermining long-term stability and reform efforts. d. Financial Aspects The financial dimensions of Pakistan’s circular debt crisis are critical and multifaceted. One of the key contributors is the delayed payments to Independent Power Producers (IPPs) and fuel suppliers, which disrupts the liquidity flow and discourages further private investment in the energy sector. Additionally, inefficient subsidy payment mechanisms create prolonged financial gaps between the cost of electricity and government reimbursements, leading to cash shortfalls. Pakistan’s heavy reliance on imported fuel not only exposes the energy sector to global price shocks but also exacerbates the trade deficit, further straining the economy. Weak balance sheets of DISCOs (Distribution Companies)—characterized by low recoveries, high losses, and limited creditworthiness— undermine their ability to finance operations or invest in infrastructure upgrades. Lastly, the rising cost of servicing circular debt has placed a growing burden on public finances, diverting resources from other critical development sectors and increasing fiscal stress. Addressing these financial shortcomings is imperative for ensuring the long-term sustainability and resilience of the power sector. e. Other Aspects Beyond governance, financial, and political drivers, several external and structural issues contribute significantly to the circular debt crisis in Pakistan’s power sector. Underutilization of transmission infrastructure is a key inefficiency; despite having sufficient capacity, delayed expansion, low demand growth, and planning mismatches have led to rising fixed costs per unit. For instance, in FY 2023–24, NTDC reported 53 under-utilized 500 kV transformers and 49 under-utilized 220 kV transmission lines, reflecting idle capital and inefficient resource allocation. Moreover, lack of data transparency, regulatory weaknesses, and misaligned demand-supply forecasts continue to affect sectoral planning. Technological obsolescence in metering and billing systems, coupled with limited automation, further contributes to poor recoveries and untraceable losses. Additionally, the social acceptance of electricity theft, especially in high-loss areas, points to deeper behavioral and enforcement issues. These structural inefficiencies, unless addressed through investment in modernization, smart grid deployment, and public awareness, will continue to burden the power system and exacerbate the circular debt problem. Page 12 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures Page 13 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures IV. Global Lessons 1) Turkey’s Power Sector Reforms Turkey offers a compelling case study of how strategic reforms in the power sector can resolve chronic inefficiencies and mitigate the risk of circular debt. In the early 2000s, Turkey faced challenges similar to those currently seen in Pakistan, including non-cost-reflective tariffs, state-dominated electricity utilities, and mounting payment arrears. However, a well-orchestrated reform program enabled Turkey to transition from a financially stressed, state-run power system to a more efficient, market-driven, and financially viable energy sector. A cornerstone of Turkey’s reform was the unbundling of the state utility TEK into separate entities for generation (EUAS), transmission (TEIAS), and distribution. This separation clarified financial responsibilities and enhanced transparency across the energy value chain. Most notably, all electricity distribution companies were privatized between 2008 and 2013, under performance-based contracts. Private operators were held accountable for reducing technical and commercial losses, improving billing and collections, and investing in infrastructure upgrades. This reduced the fiscal burden on the government and improved operational efficiency. Turkey also adopted a cost-reflective tariff regime supported by automatic quarterly adjustments, allowing changes in global fuel prices and currency fluctuations to be passed on to consumers in a timely and transparent manner. Unlike Pakistan, where untargeted subsidies create large tariff gaps and strain public finances, Turkey focused on targeted subsidies to protect vulnerable consumers while ensuring the financial viability of utilities. The Energy Market Regulatory Authority (EMRA) was empowered as an independent regulator to oversee market conduct, ensure fair competition, and maintain investor confidence. Another critical component was the establishment of a competitive wholesale electricity market, including day-ahead markets and balancing mechanisms. This encouraged competition in power procurement and reduced reliance on expensive, inflexible long-term capacity payment contracts. 2) India’s Power Sector Reforms India’s approach to tackling circular debt in its power sector has evolved through two major reform programs: the Ujwal DISCOM Assurance Yojana (UDAY) and the Revamped Distribution Sector Scheme (RDSS). Launched in 2015, UDAY sought to resolve the financial distress of state-owned DISCOMs through a combination of debt restructuring, operational efficiency targets, and tariff rationalization. Under the scheme, 75% of DISCOM debt was taken over by respective state governments, while utilities were held accountable for reducing technical and commercial losses and closing the cost-revenue gap. Although UDAY provided initial fiscal relief and liquidity support, it lacked stringent enforcement mechanisms, which led to stagnation in reforms post-2018. Recognizing these gaps, India introduced RDSS in 2021—a performance-based successor program that links financial assistance to clearly defined outcomes, including Aggregate Technical and Commercial (AT&C) losses reduction, smart metering rollout, and digital monitoring of DISCOM performance. Together, these reforms reflect India’s shift toward a more accountability-driven model, where financial support is conditioned on measurable operational improvements. Page 14 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures V. Proposed Solutions— A Holistic and Sustainable Framework to Resolve Circular Debt in Pakistan Pakistan’s power sector has reached a critical tipping point. The circular debt—driven by systemic inefficiencies, financial mismanagement, and a weak regulatory framework—has grown unsustainably, threatening energy security and economic stability. Addressing this crisis requires a multi-pronged reform agenda that blends financial restructuring, institutional reform, market development, and a decisive shift toward sustainable energy sources. 1. Privatization of Distribution Companies (DISCOs) through Performance-Based Models Public sector DISCOs remain at the heart of Pakistan’s circular debt problem, characterized by poor recovery rates, high losses, and weak accountability. A phased, transparent privatization program must be implemented with: Performance-based contracts to ensure loss reduction, improved billing, and better service delivery. Regulatory oversight to protect consumers and enforce contractual obligations. Private investment incentives for metering, digital systems, and loss reduction technologies. Learning from Turkey All DISCOs were privatized between 2008–2013, under performance-linked frameworks. Post-privatization, recovery rates improved and distribution losses declined significantly. 2. Implementation of a Cost-Reflective, Automatic Tariff Adjustment Mechanism To ensure financial viability across the power supply chain: Quarterly tariff adjustments must be institutionalized by NEPRA to reflect changes in fuel prices, exchange rates, and capacity charges. Remove political delays in tariff notifications to prevent subsidy backlogs. Introduce multi-year tariff frameworks (MYTFs) to reduce uncertainty for investors and improve planning. India’s Approach Under UDAY and RDSS, tariff-setting timelines were tightened and revenue gaps (ACS–ARR) reduced significantly through consistent revisions. 3. Targeted Subsidy Reform and Fiscal Responsibility The existing subsidy structure in Pakistan is broad and inefficient, placing a heavy burden on public finances. The reform must focus on: Phasing out untargeted subsidies and introducing means-tested, digitally disbursed direct benefit transfers (DBTs) for low-income consumers. Publishing a transparent subsidy calendar for predictable fiscal planning. Shifting subsidies to budget allocations, rather than tariff distortions, to maintain market efficiency. Turkey’s Example Turkey’s energy pricing is mostly market-based, with limited government interference and minimal fiscal burden from electricity subsidies. Page 15 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures 4. Strengthening Regulatory and Institutional Governance To restore investor confidence and enforce discipline in the sector: Enhance NEPRA’s autonomy, allowing it to take binding actions without political interference. Mandate real-time reporting by DISCOs and power sector entities on performance, losses, and payments. Establish a unified energy sector dashboard to track progress on KPIs like recovery, losses, and subsidy flows. India’s RDSS model requires real-time, feeder-level monitoring, enabling better decision-making and accountability. 5. Development of a Competitive Wholesale Power Market Pakistan must move from a centralized, single-buyer model (CPPA-G) to a liberalized market framework: Accelerate CTBCM implementation to allow direct contracts between generators and large consumers. Encourage bilateral trading, spot market development, and power exchanges. Restructure IPP contracts, prioritizing competitive procurement, especially for new capacity additions. Turkey’s Market Transition The establishment of a balancing market and spot trading in Turkey ensured transparent pricing and efficient dispatch of power, minimizing idle capacity payments. 6. Integration of Sustainable and Renewable Energy Sources Long-term circular debt mitigation also requires transitioning toward affordable, clean, and domestically available energy sources to reduce fuel import dependence and generation costs: Accelerate renewable energy (RE) deployment through competitive auctions for solar, wind, and hybrid solutions. Implement the Alternative & Renewable Energy Policy 2019 (ARE-2019) in full, with clear targets and transparent procurement. Incentivize private sector investment in distributed generation (e.g., rooftop solar), net metering, and off-grid solutions. Develop local manufacturing capacity for solar panels, wind turbines, and storage systems to reduce forex pressure. India’s Transition Through auctions under the Solar Energy Corporation of India (SECI), India brought down solar prices to some of the lowest globally, reducing reliance on fossil fuels and mitigating long-term generation costs. Turkey’s Renewable Push Through its Renewable Energy Resource Zone (YEKA) model, Turkey introduced large-scale competitive bidding and long-term PPA guarantees to boost clean energy without burdening public finances. Page 16 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures 7. Investment in Grid Infrastructure and Smart Technologies Reducing technical losses and improving system efficiency require investments in: Smart metering and billing automation Feeder Segregation and Loss Mapping SCADA Systems for Transmission Control Energy Storage and Grid Integration for Variable Renewable Energy These technologies are crucial to support a decentralized and clean energy future while curbing losses and theft. 8. Incorporating Subsidy into the Fiscal Budget A critical reform in addressing Pakistan's circular debt is the transparent integration of power sector subsidies into the federal fiscal budget. Currently, delays and underprovisioning of subsidies—particularly the difference between cost-reflective tariffs and politically set consumer tariffs—create liquidity gaps across the value chain, which accumulate into circular debt. To prevent this, all electricity-related subsidies, including tariff differential subsidies (TDS) and agricultural or industrial support schemes, must be fully accounted for in the annual federal and provincial budgets. Budgetary allocations should be based on realistic consumption forecasts, linked to NEPRAapproved tariff structures, and released on a predictable and time-bound schedule. Page 17 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures VI. Conclusion In conclusion, resolving the circular debt crisis will not be achieved through incremental fixes or temporary financial injections. It demands a comprehensive, coordinated, and politically supported transformation, structural reform, regulatory discipline, and sustainable energy practices.— anchored in transparency, accountability, and sustainability. By adopting international best practices and tailoring them to the local context, Pakistan can chart a new course toward a resilient, efficient, and inclusive power sector that supports long-term economic growth, energy security, and social equity. Page 18 Reforming Pakistan’s Energy Circular Debt: A Comparative Study of Global Solutions and Domestic Failures References State of Industry Report 2024 https://nepra.org.pk/ Page 19
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