The commission said it re-described seats after the province created new districts and tehsils, but it redrew no boundary, so the Section 22 hearing process did not apply.
The ECP re-described Khyber Pakhtunkhwa constituencies after the provincial government changed its administrative units.
The commission said no constituency boundary has been redrawn, so the seats remain as they were in the 2024 general elections.
The changes included new districts and tehsils, and changes to some existing tehsils.
The ECP cited Rule 15 of the Election Rules 2017 as its power to re-describe constituencies.
It said Section 22 of the Elections Act 2017, which requires inviting and hearing representations, does not apply.