Factory Audit in Pakistan: The Supplier Checklist Buyers Should Require

Which audit answers which question

A factory audit checks a production unit against a standard, and the standard sets the scope. A social audit samples records and interviews workers. A quality audit samples process evidence and production data. Neither reaches the other's conclusion, so a supplier with a clean social file can still ship dimensional defects at scale. Most buyers sourcing from Pakistan need at least two of these:

What a SMETA or amfori BSCI report tells a buyer, and what it does not

The two schemes European buyers ask Pakistani suppliers for most often work differently. Neither is a certificate, and both audit one site at a time, so a subcontractor's unit needs its own audit.

Pick the scheme whose platform the buyer already uses, because the buyer's compliance team has to be able to open the report. SMETA audits can be announced, semi-announced (inside a window of at least three weeks) or unannounced; ask which one the report was. And read the date first: a report records what one audit team saw on the days it attended. A grade B from 2024 says little about the factory in 2026.

Where Pakistani audits find problems

Silenced, a Labour Behind the Label report published on 23 Jul 2026, interviewed 255 workers across eight garment factories supplying international brands, and interviewed auditors too. Nearly two thirds of the workers were paid less than the legal minimum once overtime and skill level were counted, 71% could not cover basic household needs, and 3 of the 255 earned anywhere near a living wage. Auditors described double records and coached workers, and said findings must rest on documents, so testimony that contradicts the paperwork is left out (Ecotextile News coverage).

Earlier work points the same way. Arisa's Jul 2025 report on garment export factories found wage theft and excessive hours, and notes forced labour concerns in cotton. The US Department of Labor's 2024 findings for Pakistan list garments, textiles, leather and surgical instruments as goods made with child labour, cotton as made with forced labour, and carpets, bricks and coal under both. The Ethical Trading Initiative reports some improvement in labour standards compliance at Sialkot's surgical instrument exporters, while the lower tiers, where exploitation is known to be common, have little visibility or oversight.

Responsibility now travels up the chain. In Nov 2025 Labour Behind the Label, with the Pakistani groups LEF and PILER, filed a complaint against Amazon with the UK National Contact Point for the OECD Guidelines over conditions in Pakistani factories supplying its marketplace sellers (Ecotextile News).

Worked example: testing overtime pay against the law

Wage findings are the easiest to test and the most often missed. In Punjab, the Factories Act 1934 limits an adult worker to 48 hours a week (50 in a seasonal factory) and 9 hours a day (section 34 and section 36). Hours beyond either limit are overtime, paid at twice the ordinary rate of pay (section 47). The ordinary rate counts all money pay due under the contract, but not the value of housing, utilities or the employer's pension contributions. Factories in other provinces follow their own provincial law.

Take an illustrative worker on PKR 40,000 a month for 26 eight-hour days, which is 208 ordinary hours:

• Ordinary rate: 40,000 / 208 = PKR 192.31 an hour. Overtime rate: PKR 384.62 an hour.

• The worker does 10-hour days for the whole month, which is 60 hours a week and 52 overtime hours a month.

• Overtime owed: 52 x 384.62 = PKR 20,000. If the register pays those hours at the single rate, it shows PKR 10,000.

• Shortfall: PKR 10,000 per worker per month. In a unit of 400 workers that is PKR 4 million a month, invisible in a register that adds up.

The test is to pick ten workers from the gate or biometric record, not from a list the factory chooses, and trace each one through attendance, the wage register, the payslip and the bank transfer for the same month. A register that reconciles only with itself proves nothing.

Write the checklist into the purchase agreement

An audit checklist can be enforced only if it sits in the commercial documents. Put these ten points in the purchase agreement, not in an email thread:

• Named production sites, with any change disclosed before production starts.

• A current audit report against a named scheme, with the report date and platform reference.

• A corrective action plan for every open finding, with an owner and a closure date.

• Written employment terms for every worker, in a language each worker reads.

• Wage and hours registers that reconcile to bank payment records, open for inspection.

• Chain of custody records to gin, spinner or tannery for each input material.

• A chemical inventory and restricted substance declaration for inputs in use.

• Environmental permits current for the operations the site actually runs.

• A grievance channel with a named contact outside line management.

• Consent to semi-announced and unannounced follow-up audits.

Point ten changes behaviour most. An audit that can only attend by invitation reviews arrangements, not conditions.

Set re-audit intervals by risk, and mark two EU dates

Both schemes give a baseline. amfori BSCI requires a full audit at least every two years for an A or B grade and a follow-up within 2 to 12 months for C, D or E; Sedex's SMETA guide recommends yearly audits for high-risk sites and every two years for medium risk. Tighten them where the risk is higher. The intervals below are a recommendation, not a scheme rule:

Two EU rules raise the cost of a stale file. The Forced Labour Regulation (EU) 2024/3015 applies from 14 Dec 2027 and bans placing, making available or exporting products made with forced labour. Before opening an investigation, the authority must ask the companies concerned what they did to identify, prevent and remediate forced labour risk, so a current audit with closed findings is part of the answer. The corporate sustainability due diligence rules, narrowed by Directive (EU) 2026/470, apply from 26 Jul 2029 to EU companies with more than 5,000 employees and EUR 1.5 billion turnover. For most Pakistani suppliers both arrive through buyer contracts and questionnaires, although a forced labour authority can also ask suppliers directly for information (European Commission overview).

What a supplier should have ready before the auditor arrives

Preparing is not concealment. Most failed audits involve records that exist but cannot be produced on the day:

• A site map showing production, storage and welfare areas.

• The current worker roster, reconciled to contracts.

• Wage and hours registers and bank payment records for the last 12 months.

• The subcontractor list, with declared units.

• Input material records with chain of custody evidence.

• The chemical inventory and safety data sheets.

• Environmental permits and monitoring reports.

• The last external audit report, with evidence of corrective action closure.

• Grievance records and their outcomes.

Worker interviews are where a well prepared file and a working system part ways, because records can be assembled and testimony cannot.

What Tti Labs offers supplier audit programmes

• Social compliance audits, SMETA audits covering the four pillars, buyer code of conduct audits, product safety audits, and traceability audits that map tier 1 to tier 3 suppliers.

• Product inspection by Tti Inspections Pvt Ltd under ISO/IEC 17020, PNAC accreditation IB-006 (listed on the PNAC register, valid to 12 Sep 2027). Its scope covers inspection of textiles, food and cosmeceutical products; factory and social audits sit outside it.

• ZDHC MRSL certification at Levels 1 and 2, and CE and UKCA certification support.

• Environmental assessment of wastewater, emissions and chemical management through the Sustainability Center.

• Laboratory testing under ISO/IEC 17025, PNAC LAB-022, where a finding needs analytical confirmation.

• Offices in Lahore (headquarters), Karachi, Faisalabad and Sialkot.

SMETA and amfori BSCI are not certifications, and Tti Labs does not certify social compliance on a supplier's behalf. The report states what the audit found, with dated evidence, and follow-up audits record whether each finding closed.

Book a factory audit with Tti Inspections Pvt Ltd. UAN 111 786 001. Supplier audits, findings closed with evidence.

Related guides: Third-Party Inspection in Pakistan: How Independent QC Actually Works, Pre-Shipment Inspection in Pakistan: The Complete Buyer's Guide, Which Certificates Win the Order, and What They Cost.