MYT 2016-23: KE’s EoT adjustment claims draw serious concerns

ISLAMABAD: Serious concerns have been raised over K-Electric’s End of Term (EoT) adjustment claims under the Multi-Year Tariff (MYT) 2016-23, with stakeholders accusing the utility of introducing undisclosed claims and withholding critical information during regulatory proceedings.

In a formal representation submitted to National Electric Power Regulatory Authority (NEPRA), a stakeholder, Arif Bilwani has requested the regulator to ensure full disclosure of all updated submissions, presentations and supporting documents filed by KE in connection with its EoT claims.

The representation argues that the MYT framework, along with NEPRA’s subsequent Mid-Year Review (MYR) decision, clearly defines performance benchmarks, loss trajectories, investment parameters and permissible adjustments.

Any claim beyond this approved framework, it maintains, must undergo strict prudency checks and transparent stakeholder consultation.

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The stakeholder pointed out that although KE’s multiple submissions — filed between October 2023 and July 2025 — were uploaded for public comments, the utility provided key clarifications and supporting material only on May 11, 2026, just hours before the scheduled hearing. This delay, it said, undermined stakeholders’ ability to meaningfully review the claims and participate in the proceedings.

A major point of contention relates to write-off claims. While KE, in its latest reply, maintained that write-offs for MYT 2017-23 had already been determined by NEPRA and that no additional write-offs were being sought under EoT, the stakeholder noted an apparent contradiction. KE’s earlier submission reportedly included a cumulative claim of Rs 56.44 billion, including an “additional write-off” of Rs 13.17 billion for FY2023.

The representation questioned the legal basis for including such amounts in EoT adjustments if the matter had already attained finality through NEPRA’s notified decisions, arguing that previously settled issues cannot be reintroduced without explicit justification and fresh regulatory scrutiny.

Further concerns were raised over the introduction of new claims during the public hearing held on May 12, 2026. According to the stakeholder, KE presented fresh computations and demands that had not been disclosed beforehand or uploaded on NEPRA’s website, effectively taking participants by surprise.

Among these was a reported claim of around Rs 43 billion on account of cost of working capital linked to previously approved write-offs of over Rs 50 billion — an item that was not part of the original submissions available for public review.

The stakeholder argued that such practices violate principles of transparency, due process and fair hearing, especially given the quasi-judicial nature of NEPRA proceedings, which require full prior disclosure of all material and assumptions relied upon by petitioners.

The representation also criticized KE’s request for an open-ended adjustment mechanism that would allow recovery of additional liabilities arising from pending assessments, audits or unresolved MYT-related matters in the future. It termed the proposal inconsistent with the core objectives of the MYT regime, which is designed to ensure predictability, efficiency and tariff stability.

Allowing indefinite future claims, it warned, could expose consumers to unforeseen tariff burdens and effectively convert the MYT framework into a perpetual pass-through system, undermining regulatory discipline.

The stakeholder has urged NEPRA to immediately upload all updated and complete submissions, including revised computations and supporting documents presented during the May 12 hearing, and to grant adequate time for stakeholders to review the material and submit comprehensive feedback.

Copyright Business Recorder, 2026