The Rs500 million illusion: how inflation changed NAB law

For the past few years, one figure has defined the jurisdiction of NAB: Rs500 million. Introduced through the 2022 amendments to the National Accountability Ordinance, 1999, this threshold was meant to ensure that NAB remained focused on large-scale corruption rather than being drawn into relatively smaller financial disputes.

At the time, the objective was clear. Cases involving amounts below Rs500 million were, in principle, meant to fall outside NAB's domain. The reform was widely seen as an attempt to streamline accountability and prevent overreach.

That clarity, however, no longer exists.

A recent amendment enacted in 2026 through Act No. XIV of 2026 has significantly altered how this threshold operates. The law now provides that the threshold shall be adjusted annually in accordance with the inflation index published by the Pakistan Bureau of Statistics, starting from 1st July 2022.

This single clause transforms the nature of the threshold. What was previously understood as a fixed figure is no longer static. Instead, Rs500 million now serves as a base value, one that must be recalculated each year to reflect inflation. In practical terms, the threshold is no longer Rs500 million in any real sense. It is a moving figure, rising as the purchasing power of money declines.

Inflation-indexation is not unfamiliar in. It is commonly used to preserve the real value of statutory limits over time. Without such mechanisms, inflation gradually erodes the effectiveness of monetary thresholds, undermining their purpose.

The amendment also states that it shall be deemed to have taken effect from the commencement of the Ordinance in 1999. This creates a legal fiction requiring courts to read the law as if this mechanism had always existed. At the same time, the statute clearly specifies that the adjustment begins from July 2022. Read together, the more coherent interpretation is that indexation is now embedded in the law, but its practical application is forward-looking from that date.

Even on this reading, the consequences are significant.

Pakistan has experienced sustained and at times severe inflation since 2022. Annual inflation has remained in double digits, with certain years witnessing sharp increases. When compounded over successive financial years, this inflation materially alters the real value of money.

Applying a conservative estimate of cumulative inflation from July 2022 to 2026, the Rs500 million threshold would now stand at approximately Rs900 million to Rs1 billion. Thus, a case involving Rs600 or 700 million, once comfortably within NAB's jurisdiction, may no longer meet the threshold.

This shift goes to the core of legal authority. Jurisdiction determines whether an investigative body or court has the power to proceed. If it is wrongly assumed, the validity of the entire proceeding may be questioned.

Under the amended framework, it is no longer sufficient for NAB to rely on the nominal figure of Rs500 million. Before asserting jurisdiction, it must identify the relevant inflation index, calculate the adjusted threshold for the applicable year, and demonstrate that the alleged amount exceeds that revised figure. Without this exercise, jurisdiction becomes open to challenge.

The introduction of a monetary threshold in 2022 was intended to focus accountability on cases involving substantial public funds. The inflation-adjustment clause reinforces that objective by ensuring the threshold retains its real value over time.

At the same time, it introduces complexity. What was once a simple numerical test now requires calculation, interpretation and potentially judicial scrutiny. More importantly, it undermines a widely held but now outdated assumption: that NAB's jurisdiction is triggered simply by crossing Rs500 million. That assumption no longer reflects the law.

The 2026 amendment has quietly but fundamentally reshaped NAB's jurisdictional framework. The threshold is no longer fixed. It is dynamic, tied to inflation and subject to annual revision.

The real question in any case today is not whether the alleged amount exceeds Rs500 million, but whether it exceeds the inflation-adjusted equivalent of Rs500 million. Until this shift is fully understood and properly applied, there is a real risk that jurisdictional limits will continue to be misunderstood.