Identifying and Reporting Ultimate Beneficial Owners (UBO)

Every company must identify the real individuals who ultimately own or control it — even through layers of other companies — and keep SECP satisfied that this is being tracked properly. This guide walks through the annual notice-and-declaration cycle, what counts as a UBO, and when to update the register.

Steps

  1. Identify every member holding 25% or more of the company's shares or voting rights, directly or indirectly, or anyone else who effectively controls the company through other means — a chain of ownership, an agreement, or a personal/family connection.
  2. Issue Form-16 annually to every such member. Listed companies only need to notify members holding 5% or more.
  3. Collect each member's completed Form-17 declaration within 14 days of the notice, identifying the true underlying natural person(s) — including, for indirect ownership, the chain of intermediary companies or arrangements involved.
  4. Verify what you're told: check identity documents (CNIC/NICOP/passport), and where anything looks doubtful, cross-check via NADRA's e-Verisys or the individual's tax-filer status.
  5. Record the UBO's particulars in the company's UBO register — name, parentage, CNIC/NICOP/passport with issue/expiry, date of birth, gender, nationality, address, and the date the interest was acquired.
  6. Within 15 days of receiving a member's declaration, file Form-19 (declaration of compliance) with the registrar — and again alongside the company's annual return.
  7. If a UBO's particulars change, get a fresh declaration on Form-18 within 14 days of the change, update the register, and file another Form-19 within 15 days.
  8. Have the board formally authorise a CEO, director, or officer to liaise with the registrar — and any other authority that asks — on UBO matters.

Sections involved

§123A Section 123A — Record of ultimate beneficial owner

Forms you'll need

Form-16 Form-16 — Notice to Members for Providing Particulars of Ultimate Beneficial Owners Form-17 Form-17 — Declaration by Member About Ultimate Beneficial Owners Form-18 Form-18 — Declaration by Member About Change of Ultimate Beneficial Owners Form-19 Form-19 — Declaration of Compliance with Section 123A

How to file a form

New to SECP's eZfile / LEAP portal? See the step-by-step filing guide →

See Important Definitions

Key terms from Section 2 (Definitions) of the Companies Act, 2017 (and, where noted, the LLP Act, 2017) that matter for this task.

§2(4) associated companies / associated undertakings §2(7) beneficial ownership of shareholders or officer of a company §2(16) Commission §2(45) officer §2(57) registrar
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