Yasir Ali, Lead Regulatory and EODB Core Group of OICCI Regulatory Subcommittee, represented OICCI in a Consultative Stakeholders’ Session organized by Board of Investment (BOI) on Zero Time to Start (ZTTS) policy draft. On the behalf of OICCI, Yasir Ali shared that:

• The draft is lengthy, complex and a bit technical. We believe that this should be simplified to make it easy to understand for the larger audience.
• Increasing a lot of legal work for the Pakistan Business Portal (PBP) because medium and high-risk entities that do not get approval / Compliance Verification Process (CVP), will opt to legally challenge decisions at every chance.
• A lot of NOC work is actually required when dealing with provincial regulatory authorities for example, SEPA, however this plan does not mention the provinces and does not even indicate an eventual plan of implementation for the provinces.
• It appears as if the Risk Classification exercise and preparing the Application Pack will be done simultaneously. However, it might be difficult to prepare a consolidated Application Pack without the clarification of Risk Classification.
• There are lengthy processes involved between the approval of the policy and actual implementation. We believe this stage should be streamlined so that the implementation could start earlier, which is the key.
• A clear timeline should be added indicating time periods of implementation of various intermediate steps till full implementation of the policy to give more clarity to the potential investors.

The feedback was well received and appreciated by BOI and ensured to improve the draft on the recommendations shared.