How to Find Your Company's Beneficial Owners and File Form 19 With SECP

Short answer: To comply, list every company member, multiply ownership percentages up the chain to find the real people behind the shares, record those people in your register of ultimate beneficial owners (UBO), and file the beneficial ownership return, reported as Form 19, with the Securities and Exchange Commission of Pakistan (SECP). Notices to 28,761 companies were issued on 3 September 2026.

An ultimate beneficial owner is the real person who owns or controls a company, even when the shares sit in another company's name. A bank, a tax office or a supplier wants that name. The SECP wants it on file.

We read the SECP's own UBO frequently asked questions and its press release list. The SECP's notice page itself would not open for us, so the Form 19 filing and the notice terms below are marked as reported.

SECP sent notices to 28,761 companies on 3 September

The SECP's press release list shows a release dated 3 September 2026 titled "SECP issues Notices to 28,761 Companies Over Failure to Disclose Beneficial Owners". Reports of it say the companies had not filed Form 19 and were given 30 days to do so.

If you were one of them, that period has probably run out. If you were not, the next date to watch is the annual return. The SECP asked companies with a 30 June year end to hold their annual general meeting by 28 October 2026, and the return and beneficial ownership steps follow it. Our guide to filing the company annual return with SECP covers that sequence.

The threshold differs between sources, so confirm yours

The SECP's UBO FAQ, which explains Circulars 16 and 20 of 2018, uses a threshold of not less than 10 per cent ownership or control. Reports of the September notices describe 25 per cent or more. We could not open the notice, so we cannot say which applies to you.

Use the lower figure when you build your register. A person at 12 per cent is inside the older 10 per cent rule and outside a 25 per cent rule. Recording that person costs you little. Missing a required person costs more. Then read your own SECP notice or eZfile message for the rule that applies to you.

Work out your beneficial owners by multiplying percentages

The SECP's FAQ gives the method. For a person who owns shares in a company that is a member of yours, multiply the person's percentage in that company by that company's percentage in yours. The answer is the person's indirect holding in your company.

The FAQ's own example: Company X has Company Y as a member with 50 per cent. Y has two individuals, A with 90 per cent and B with 10 per cent. A's indirect stake in X is 45 per cent. B's is 5 per cent. A goes on the register. B does not, because 5 is below 10.

1. Open your register of members and mark every member that is a company, not a person.
2. Keep only those companies that hold at least the threshold of your shares.
3. Write to each of them and ask for the natural persons behind them, with their share percentages.
4. Repeat the request up the chain until you reach individuals.
5. Multiply the percentages down the chain to get each person's indirect holding.
6. Enter every person at or above the threshold in your register of UBO.

Natural persons already on your register need no extra entry

The SECP's FAQ says that a member who is a natural person holding the threshold or more is already recorded in the register of members under section 119 of the Companies Act, 2017. That person need not be entered again in the UBO register.

The circulars apply only to companies that have one or more legal persons as members, and where such legal persons hold at least the threshold. A company whose members are all individuals, such as a small private company owned by two brothers, is not caught by that method. The register of members is its record.

That does not mean you can ignore the filing. If the SECP notified you, or if your annual return asks for the beneficial ownership return, check the filing in eZfile. The setup steps are in how to register a private limited company with SECP, and a director change has its own form, shown in how to report a director change on Form 29.

File the return and keep the proof

Reports of the SECP notices say the return is Form 19, and the SECP lists eZfile as its online filing portal. Use the company account, attach the details of each person on your register, and save the filing receipt with your company records. Keep copies of the letters you sent to corporate members.

We did not log in to eZfile and we did not read the Form 19 template, so we cannot list its fields or describe its screens. The SECP FAQ names the circulars that set out the details the register must hold, so read Circular 16 of 2018 on the SECP website before you collect them.

Common questions

What is Form 19 for?

Reports of the SECP notices say Form 19 is the return for reporting ultimate beneficial owners under the Companies Act, 2017.

Who is an ultimate beneficial owner?

It is the natural person who owns or controls the company, directly or through other companies, at or above the SECP's ownership threshold.

Is the threshold 10 per cent or 25 per cent?

The SECP FAQ based on its 2018 circulars says 10 per cent. Reports on the 2026 notices say 25 per cent. Follow the figure in your own notice.

Do small companies with only individual shareholders need a UBO register?

The SECP's FAQ applies the circulars to companies that have legal persons as members. Check eZfile or your notice to see if a filing is still required of you.

What if I missed the 30 day period?

Reports say the SECP warned of legal action. File as soon as you can and keep your proof. We found no penalty figure on the pages we read.

Can a corporate service provider do this for me?

You can use a professional, but the company stays responsible, so check the receipt and the names yourself.

How we verified this

What we checked, where we read it, and what we could not confirm.

Last checked on Sunday 11 October 2026. We read the SECP frequently asked questions, including the Ultimate Beneficial Ownership section, and the list of SECP press releases for 2026. We could not open the text of the 3 September release, so the form number, the 30 days and the 25 per cent figure are reported. We found no fee or penalty figure and give none.