Circular No. 21 of 2025 — Company’s Responsibility under Section 123A of the Companies Act, 2017 read with Regulation 48 of the Companies Regulations, 2024

Clarifies a company's obligations to maintain "adequate, accurate, and up to date" ultimate beneficial owner (UBO) information under Section 123A/Regulation 48. Requires companies to actively verify a UBO's identity (CNIC/NICOP/passport checks, NADRA e-Verisys where suspicion arises) and status (tax-return cross-checks, a risk-based approach for complex or multi-jurisdictional structures), to update the UBO register within a reasonable period (suggested: one month) of any change, and to share UBO information with financial institutions for KYC/account-opening purposes as well as with SECP and other authorities on request.