Pakistan – SEC Transparency Disclosure Enforcement

Pakistan – SEC Transparency Disclosure Enforcement

On 21 April 2026, PAK SEC directed firms re ultimate beneficial ownership information.

  • PAK SEC directed companies to ensure the timely submission of Ultimate Beneficial Ownership (UBO) information through Form-19 on its eZfile portal.
  • Disclosure of UBO information ensures corporate transparency, prevents misuse of corporate structures, and combats money laundering and illicit financial flows.
  • Follows PAK SEC Aug. 2025 company obligations to report UBOs.

Meaning of Ultimate Beneficial Owner

  • An UBO refers to the natural person(s) who ultimately own or control a company, whether directly or indirectly.
  • This includes individuals who exercise significant influence or control over the company, even if they are not formally listed as shareholders or directors.

Submission of Ultimate Beneficial Owner Information

  • Companies can file Form-19 through the eZfile portal by logging into their company account, selecting the relevant filing option, and providing details of UBO.
  • Companies must provide accurate disclosure of ownership structure, shareholding or control percentages, and particulars of beneficial owners.
  • They must also maintain an internal register of beneficial owners and ensure that such information is updated annually or whenever changes occur.

Compliance Warning

  • PAK SEC noted that a number of companies have yet to comply with this requirement and has advised them to complete the filing without delay.
  • They urge all companies to ensure compliance and warned that legal proceedings will be initiated against those failing to file Form-19 by Apr. 30, 2026.
  • Non-compliance may also result in penalties of up to PKR 1mn on directors, officers, or other responsible persons, and up to PKR 10mn on the company.

Effectiveness

  • Compliance deadline is Apr. 30, 2026.