The Securities and Exchange Commission of Pakistan (SECP) has directed all companies to declare their Ultimate Beneficial Ownership (UBO). Consequently, businesses must submit Form-19 through the SECP’s eZfile portal. This mandatory requirement falls under Section 123A of the Companies Act, 2017. Therefore, companies must file this form alongside their annual return.
Disclosure of UBO information guarantees corporate transparency. Furthermore, it prevents the misuse of corporate structures. Ultimately, this enforcement strengthens Pakistan’s framework against money laundering and illicit financial activities.
A UBO refers to a natural person who ultimately owns or controls a company. This ownership can be direct or indirect. Additionally, the definition includes individuals exercising significant influence. This rule applies even if they are not formally listed as shareholders or directors.
The eZfile Submission Process
The SECP observed that many companies have not met this requirement yet. Therefore, the commission advises immediate compliance. Companies can submit Form-19 by logging into their eZfile account. Next, they must select the relevant filing option. Afterward, they must input accurate ownership structures, control percentages, and specific owner details.
Moreover, businesses must maintain an internal register of beneficial owners. Companies must update this internal record annually. They must also update it immediately whenever ownership changes occur.
SECP Sets Strict Penalties for Non-Compliance
Failing to submit Form-19 directly violates Section 123A of the Act. Consequently, non-compliant companies face severe financial penalties. The SECP can impose fines up to Rs. 10 million on the company itself. Furthermore, directors, officers, or other responsible individuals face separate penalties up to Rs. 1 million.
The SECP demands strict compliance within the stipulated timeline. Consequently, the commission will initiate legal proceedings against any entity failing to file Form-19 by April 30, 2026.
