SECP Sets October 28 Deadline for AGM, Annual Return and UBO Filings

The Securities and Exchange Commission of Pakistan (SECP) has advised companies whose financial year ended on June 30, 2026, to hold their Annual General Meetings (AGMs) by October 28, 2026 and complete the required annual regulatory filings. The regulator has reminded companies of their obligations relating to Annual Returns (AR) and Ultimate Beneficial Ownership (UBO) information as part of the annual corporate compliance process.

Under the applicable requirements, companies are required to hold their AGMs within 120 days of the close of their financial year. Companies with a financial year ending on June 30, 2026 therefore have until October 28, 2026 to conduct their AGMs. The SECP has encouraged companies to complete the process within the prescribed period and ensure that their corporate records remain current.

Following the AGM, companies are required to submit the relevant Annual Return documentation based on whether there have been changes in the particulars contained in their previous return. Where particulars have changed, the company is required to file Form A with the relevant information. Where there has been no change in the particulars reported in the previous Annual Return, companies are required to file Form 24.

The regulatory requirements also provide an exemption for certain companies from filing an Annual Return where there has been no change in the relevant particulars. Single-member companies and private companies with paid-up capital of not more than Rs3 million are exempt from filing an Annual Return in cases where the particulars contained in their last return remain unchanged.

Alongside the Annual Return process, companies are required to complete their annual Ultimate Beneficial Ownership requirements. This includes issuing the required notices, obtaining the necessary declarations and updates, maintaining the Ultimate Beneficial Ownership Register and submitting Form 19 to the registrar along with the Annual Return where an Annual Return is required.

For companies that are not required to file an Annual Return, the SECP has specified a separate timeline for Form 19. In such cases, Form 19 must be filed within 30 days of the end of the calendar year. Companies therefore need to determine their applicable filing requirements and ensure that the relevant forms are submitted within the prescribed deadlines.

The UBO requirements are intended to keep information concerning the individuals who ultimately own or control companies updated within the corporate regulatory framework. Maintaining accurate records and submitting the required declarations and forms allows the regulator to keep corporate ownership information current and supports broader transparency and compliance requirements.

The SECP has advised companies to review their corporate records and prepare their required filings in advance rather than waiting until the deadline. Companies are also expected to ensure that information submitted through their regulatory filings is accurate and reflects their current corporate particulars.

The October 28 deadline therefore applies to companies whose financial year closed on June 30, 2026 and covers the requirement to hold their AGM within the prescribed 120-day period. After the AGM, companies must complete the relevant Annual Return and UBO filings according to their circumstances, including Form A, Form 24 or Form 19 where applicable.

By reminding companies ahead of the deadline, the SECP has highlighted the importance of timely corporate compliance and maintaining updated company information. Businesses covered by the requirements are expected to review their records, identify the forms applicable to them and complete the AGM and associated filings within the required timelines.

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