Source: ACFID Circular No. 02 of 2026, 13 October 2026 · Research date: 16 October 2026. Analysis is general information and should be read with the full instrument and subsequent amendments.
The 13 October circular moves the Banking on Equality programme into a second policy cycle. Its instructions apply to specified financial institutions, with individual obligations varying by institution type and further institution-specific targets to follow.
The policy framework and who is covered
ACFID Circular No. 02 of 2026 introduces the second edition of the Banking on Equality policy following SBP’s first policy cycle launched in 2021. SBP identifies commercial, Islamic, digital and microfinance banks as covered and extends relevant measures to DFIs, bank-owned exchange companies, electronic money institutions, credit bureaus and payment system operators and providers where applicable. The phrase where applicable matters: institutions should work from the actual directions rather than assume that every measure applies without qualification.
The circular links the policy with the National Financial Inclusion Strategy objective of reducing the gender gap in financial inclusion by 2028. It also indicates that institution-specific targets will be separately communicated by reference to June 2026 baselines. Policy-level aggregate ambitions must therefore be separated from institution-level supervisory directions.
Workforce and governance implications
The circular directs regulated entities to develop implementation plans to improve women’s representation in their workforces, with an identified sector-wide trajectory from 17 percent to 22 percent by December 2028. It addresses merit-based progression, mentorship, workplace protection and women’s participation in governance. Businesses should distinguish mandatory instructions from provisions expressed as encouragement, and document how existing employment policies and applicable workplace protections will be met.
The direction to designate a senior Banking on Equality champion places responsibility for implementation and reporting within the institution. Legal and compliance teams should consider whether the assignment is reflected in delegation instruments, reporting lines, board or management committee agendas and internal audit assurance.
Digital access, lending and reporting
The policy contemplates targeted drives for digital account opening, digital access for women entrepreneurs, women-owned or led businesses, financing support and financial education. Existing rules on customer identification, consumer protection, lending assessment, information security and AML/CFT are not displaced merely by a financial-inclusion objective.
SBP also calls for gender-disaggregated data repositories and analysis of customer activity. Institutions should examine source data, consent and lawful processing assumptions, analytics definitions, reporting processes and responsibility for correcting inconsistent records before reporting capability is promised to management or regulators.
What should affected organisations do?
The immediate task is an institution-level gap assessment, not a generic equality policy rewrite. Determine applicability, baseline evidence, controls and implementation owners.
Recommended action checklist
- Circulate the signed ACFID Circular No. 02 of 2026 and its enclosed policy to legal, compliance, HR, finance and digital banking teams.
- Create an applicability matrix distinguishing mandatory directions, targets and encouraged measures.
- Identify baseline metrics, responsible departments, implementation milestones and records of policy review.
- Track the further institution-wise targets expected from SBP.
Timing and legal status
Circular issued on 13 October 2026. Several policy outcomes target 31 December 2028. Follow subsequent institution-specific directions and clarifications.
The policy covers multiple types of regulated entities, with expressly qualified applicability. Do not represent the 2028 targets as identical immediately enforceable metrics for every participant.
State Bank of Pakistan — ACFID Circular No. 02/2026