Changeflow GovPing Securities & Markets SECP UBO Disclosure Enforcement Under Section 123A
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SECP UBO Disclosure Enforcement Under Section 123A

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Summary

The Securities and Exchange Commission of Pakistan (SECP) has directed all companies to submit Ultimate Beneficial Ownership (UBO) information through Form-19 on its eZfile portal by April 30, 2026. The enforcement notice cites Section 123A of the Companies Act, 2017, which mandates UBO disclosure to combat money laundering and illicit financial flows. Penalties reach up to Rs. 1 million on directors, officers, or other responsible persons, and up to Rs. 10 million on the company for non-compliance. Companies must also maintain and annually update an internal register of beneficial owners.

Why this matters

Companies that have not yet filed UBO information through Form-19 should prioritize this compliance action immediately, as the April 30, 2026 deadline carries personal liability for directors and officers separate from corporate penalties. Review internal beneficial ownership records for accuracy before submission, including natural persons exercising significant influence or control even if not formally listed as shareholders or directors.

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About this source

GovPing monitors SECP Pakistan for new securities & markets regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 9 changes logged to date.

What changed

The SECP has issued an enforcement notice requiring all companies to file Ultimate Beneficial Ownership information through Form-19 on the eZfile portal by April 30, 2026, under Section 123A of the Companies Act, 2017. Companies must also maintain and annually update an internal register of beneficial owners. Non-compliance constitutes a violation of Section 123A and may result in legal proceedings, with penalties reaching Rs. 1 million on individual responsible persons and Rs. 10 million on the company.\n\nAffected companies that have not yet filed Form-19 should prioritize this compliance action immediately to avoid penalties and legal proceedings. The UBO disclosure requirement applies to all companies, including those with existing corporate structures, and requires disclosure of natural persons who ultimately own or control the company.

What to do next

  1. File Form-19 through the SECP's eZfile portal by April 30, 2026
  2. Maintain an internal register of beneficial owners
  3. Update ownership information annually or whenever changes occur

Penalties

Up to Rs. 1 million on directors, officers, or other responsible persons; up to Rs. 10 million on the company

Archived snapshot

Apr 23, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN (SECP) PRESS RELEASESECP Enforces UBO Disclosure to Strengthen Transparency For immediate release April 21, 2026 ISLAMABAD, April 21: The Securities and Exchange Commission of Pakistan (SECP) has directed all companies to ensure timely submission of Ultimate Beneficial Ownership (UBO) information through Form-19 on its eZfile portal.Section 123A of the Companies Act, 2017, requires all companies to file Form-19 declar-ing Ultimate Beneficial Ownership along with their annual return. Disclosure of UBO infor-mation is essential to ensure corporate transparency, prevent misuse of corporate struc-tures, and strengthen Pakistan's framework for combating money laundering and illicit fi-nancial flows.UBO refers to the natural person(s) who ultimately own or control a company, whether di-rectly 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.The SECP has observed that a number of companies have yet to comply with this manda-tory requirement and has advised them to complete the filing without delay.Companies can file Form-19 through the SECP's eZfile portal by logging into their compa-ny account, selecting the relevant filing option, and providing details of ultimate beneficial owners. The form requires accurate disclosure of ownership structure, shareholding or control percentages, and particulars of beneficial owners.Companies are also required to maintain an internal register of beneficial owners and ensure that such information is updated annually or whenever changes occur. Non-sub-mission of Form-19 is a violation of Section 123A of the Act and may result in penalties of up to Rs. 1 million on directors, officers, or other responsible persons, and up to Rs. 10 mil-lion on the company.The SECP has urged all companies to ensure compliance within the stipulated timeline and warned that legal proceedings will be initiated against those failing to file Form-19 by April 30, 2026.󳗈󲃯󳚑 󲃯󲧶󲶩󲃯󲺿󰹯󱿉󱻽󲃯󱐍󳦘 Securities and Exchange Commission of PakistanNICL Building, 63 Jinnah Avenue, IslamabadSECURITIES AND EXCHANGE COMMISSION OF PAKISTAN (SECP) PRESS RELEASE          󳁞󲓒󳧴󲺿󰹯󲃯󱻺󰎝󱀊󲆪󳤵󳒺󲏵󱀊󱿋󳜩󲃯 󳗈󱿉󱻽󰋾󳕣󱷂 󱽅󳱆󳬊󰘬 󳪂󳭯21 󱉐   AFor immediate release                             April 21, 2026    󳁞󲓒󳣻󱶸󰟦  󲧶󲶩󲃯 󳰯󲆪19󱨶󱃗󳭯󱆑󳡫󱨶󳢊󲏵󲆪󱐍󳦘󲧶󲶩󲃯 󳰯 󳜡󳭞󰛐󳢩󱶸󰟦󳧹󱨶󳧏󱳨󳭊󳧴󳰯󳁞󲓒󰎝󱀊󲆪󳤵󳒺󲏵󱀊󱿋󳜩󲏵󳭯󱻽󰋾󰃚󲆪123󱑔󲆪2017󳨡󱻼                 󰎞󲃯󱂖󱧟󲆪󱻽󳕣󳨙󱿉󱭠󱖀󳄡󳒦󲋪 󱳨󲃯󱻽󲧶󲶩󲃯 󳰯 󳁞󲓒󳣻󱶸󰟦󳧹󲆪19    󳜩󱝔󲧴󲆪󳕣󲴽󱿉󲧶󱯯󰾔󲆪󳄢󳭧󱆅󲤨󲧶󳓪󳒹󱮵󱨭󳩲  󲏵󲿲                  󳁞󲓒 󳭠󱽣󰹯󱇀󲣡󳭯󳛌󲜝󲧶󱛦󲆪󱻺󱷵󰡦󳜡󲧶󲶩󳄡 󲆪 󲯨󱓭󳭊󳧴 󳰯      󳗈󳓞󲃯󳓞󰇾󲃯󱞗󰉆󳓪󳒹󱮵󳁍󲏵 󳕣󰡗󱻻󰋾󳦶󳛌󳒺󲺍 󳄡󳨢  󲗌󳛌󱚌󳭯󱠘󱝀  󱳨󳜩󰧕󳛌  󱨶󳪂󳭯30󳜩󲸚󳪂󳭯30󳦆󰷥󲃯󳕣󱶸󰟦19󱨶󳤵󳒺󲏵󱀊󲆪󱻽󳭉󱶸󲹚󳡱󱨶󲃯19󱨶󰿷 󱿋󳜩󰐷󰛐󲃯 󲎸󳣿󰛐󲃯󳢩󱳨󳓪󳒹󱮵󰾔󲆪󱻽󲤨󳕣󱶸󳒺󰟦19                        󳡫󱨶󳨢󲆪󱻽󳜩󱈃󰛐󲃰󳧹󲆪 󳡫󱨶󱃗󳭯 󱀊 󲃯󱐍󳦘󳧏 󱳨 󳰯 󳁞󲓒    󱽣󲗌󳛌󱚌󳉉󳜪󲆪󱻺󳄡󱨶󳜡 󱶸󰟦󱓭󳣿󳛌󰒈󱶸󲼙󱳨19󱨶󱃗󳢊󲏵󱶸󳛌󲏵󳄡 󱳨                 󳜡󰐷󳛌 󱶸󳙞 󰈮󲹚󲃯󳰯  󰌸󲆪              󳄡󱜝󲃯󳪧󰁊󱷵󱀊󱿉󲧶󲶩󳭉󱶸󳄡󰝘 󳭡󲆪󱻺󳭡󱳨󳰯 󱿋󳜩󱝔󳭋󲧴󲆪󱻽      󳭉󱶸     󳭯󱻺󰁀󱿦󲏵󳭯󳀄󳩲󳨢 󲆪󱻺󳭯󰝏󳜩󰾔󲃯123󱑔󲆪󳨡󱻼 󱶸󳒺󰟦19󱨶󱿋󳜩󱝊    󳜩󱈃󰛐󲃰󳭰󱡨󳒺󲧶  󰁀󱶸  A Securities and Exchange Commission of PakistanSecurities and Exchange Commission of PakistanNICL Building, 63 Jinnah Avenue, IslamabadNICL Building, 63 Jinnah Avenue, Islamabad

Named provisions

Section 123A Form-19 Ultimate Beneficial Ownership

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Last updated

Classification

Agency
SECP
Filed
April 21st, 2026
Compliance deadline
April 30th, 2026 (7 days)
Instrument
Enforcement
Branch
Executive
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
Section 123A of the Companies Act, 2017

Who this affects

Applies to
Companies
Industry sector
5231 Securities & Investments
Activity scope
UBO disclosure filing Beneficial ownership registration Annual compliance filing
Geographic scope
PK PK

Taxonomy

Primary area
Anti-Money Laundering
Operational domain
Compliance
Compliance frameworks
BSA/AML
Topics
Securities Corporate Governance

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