SECP Form 19 and Ultimate Beneficial Ownership (UBO) Compliance in Pakistan: Professional Guidance and Assistance
Companies Must Maintain and Report Ultimate Beneficial Ownership Information
Updated 20 September 2026. Section 123A of the Companies Act and the current SECP framework require companies to maintain information about ultimate beneficial owners and make the prescribed compliance filing. Form 19 is the current declaration of compliance with section 123A.
Taxocrate can review the ownership chain, member declarations, company UBO register and Form 19 filing position before annual or event-based compliance.
Updated 16 September 2026.
What Is an Ultimate Beneficial Owner?
A UBO is the natural person who ultimately owns or controls the company within the applicable statutory definition and thresholds.
Member and Company-Level Records
The current statutory forms include Form 16 notice to members, Form 17 member declaration, Form 18 declaration of change and Form 19 company compliance declaration.
Form 19
Form 19 is the prescribed declaration of compliance with section 123A. SECP guidance states that companies must maintain UBO information and make the required filing within the current statutory framework.
Changes in Ownership or Control
Where beneficial ownership or particulars change, the company should update the underlying declarations and register and review whether a fresh filing is required.
Annual Filing Connection
UBO compliance should be reviewed alongside the annual return so ownership and control records remain consistent.
Related Pages
See Form A / Form 24 Annual Return, Company Bank Account Opening and SECP Forms Guide.
Frequently Asked Questions
What is Form 19?
Form 19 is the current SECP declaration of compliance with section 123A of the Companies Act relating to ultimate beneficial ownership.
Are there other UBO forms?
Yes. Current statutory forms include Forms 16, 17 and 18 for notices and member declarations connected with beneficial ownership.
Is UBO the same as a shareholder?
Not always. UBO analysis looks through ownership or control to the relevant natural person under the law.
Should UBO records be reviewed annually?
Yes. UBO compliance should be kept current and reviewed with annual filing.
Can a change in ownership require an updated declaration?
Yes. Changes in beneficial ownership or particulars can trigger updates to member and company records.