Key Points
- Companies have 120 days from their financial year-end to hold the meeting
- ‘Annual returns’ must be filed within 30 days of the meeting
- Ultimate beneficial ownership records must also be maintained and reported
ISLAMABAD: Pakistan’s corporate regulator has set October 28, 2026, as the deadline for companies whose financial year ended on June 30 to hold their annual general meetings and complete related statutory requirements.
The Securities and Exchange Commission of Pakistan (SECP) reminded corporates that an annual general meeting (AGM) is mandatory within 120 days of the close of the financial year, with subsequent filings to be completed within prescribed deadlines.
Companies must file annual returns after AGM
Registered firms must file their annual return within 30 days of the AGM. In case there is a change in information in the previous annual return, ‘Form A’ must be submitted. Where there is no change, companies must file Form 24, known as the no-change intimation.
For companies holding their AGM on October 28, Form A or Form 24 would, therefore, be due by November 27, 2026.
If no AGM is held, or the AGM is not concluded, the relevant annual filing must be completed by January 30, 2027, according to the SECP guidance.
The regulator said private companies and single-member companies with paid-up capital of up to Rs 3 million are exempt from filing the annual return if there is no change in the particulars contained in the previous return.
The SECP has also reminded companies of their ultimate beneficial ownership (UBO)obligations — the individuals who ultimately own or control a company.
Companies must issue Form 16 notices to members. For listed companies, they must issue such notices to every member or representative of a legal person or legal arrangement holding at least 5 per cent of shares or voting rights.
Companies must obtain UBO declarations through Forms 17 and 18, maintain a UBO register and file Form 19.
Where an annual return is required, Form 19 must be filed along with the annual return within 30 days of the AGM.
Where an annual return is not required under the law, Form 19 must still be filed within 30 days of the end of the relevant calendar year.
For a company with a December 31, 2026 year-end, for example, the Form 19 deadline would be January 30, 2027.
Penalties for non-compliance
The SECP warned that failure to meet annual filing and UBO requirements can result in penalties.
Non-compliance with annual return requirements can attract penalties under the applicable scale. UBO violations can result in a fine of up to Rs 10 million on the company and up to Rs 1 million on each responsible director or officer.
The regulator has urged companies to complete their statutory filings within the prescribed timelines and has assisted through its helpline, WhatsApp service and online filing platforms.
