Pakistan's SECP issues notices to 28,761 companies over missing beneficial ownership declarations
Pakistan's Securities and Exchange Commission issued show-cause notices to 28,761 companies that had not filed Form 19, the annual declaration of compliance with ultimate beneficial ownership requirements. They have 30 days to file and explain why they should not be penalised. Directors and officers face penalties of up to PKR 1 million and companies up to PKR 10 million.
Section 123A of the Companies Act 2017 requires every company to keep an accurate, up-to-date register of its ultimate beneficial owners and to give a declaration to the registrar. Regulation 48 of the Companies Regulations 2024 requires that declaration of compliance with the annual return, on Form 19.
What happened
- The SECP issued show-cause notices to 28,761 companies that had not filed Form 19.
- Recipients have 30 days to file the outstanding declarations, explain why a penalty should not be imposed and send certified copies as evidence. They can ask for a hearing.
- An ultimate beneficial owner is someone holding 25% or more of the shares or voting rights, or who directly or indirectly exercises effective control.
- Penalties under section 123A(3): up to PKR 1 million for directors, officers or other responsible people, and up to PKR 10 million for the company. If a company does not respond, the SECP can decide on the records it holds.
What to do
Check that each Pakistani company has filed Form 19 with every annual return, and that its beneficial ownership register is current.