Plenty of directors who never miss an FBR deadline still overlook their company's SECP obligations entirely — not realizing the two run on completely separate tracks, with separate forms, separate deadlines, and separate penalties. Ignore SECP long enough and the company can actually be struck off the register, which is a far more painful problem to fix than simply filing on time. Here's what every private limited company in Pakistan needs to stay on top of each year.
The Annual Compliance Cycle in Brief
- Hold an Annual General Meeting (AGM) within 4 months of financial year end
- File Form A (annual return) within 30 days of the AGM
- File audited financial statements within 30 days of the AGM
- File Form 29 within 15 days of any change in directors, secretary, or registered address
- Keep statutory registers of directors, members, and meeting minutes up to date
None of this depends on whether the company actually did business during the year — even a completely dormant company must go through the cycle, though its accounts and filing can be much simpler.
Form A — Confirming the Company's Current Status
Form A isn't a tax computation; it's a governance snapshot that keeps SECP's public register accurate. It records the registered address, current directors and their CNICs, the CEO, company secretary, auditors, shareholders and their holdings, and the company's share capital as of the AGM date. It's filed online through SECP's eServices portal along with the audited accounts as a PDF attachment, and the filing fee scales with the company's paid-up capital.
Form 29 — Reporting Changes as They Happen
Unlike Form A, which is an annual event, Form 29 is triggered any time something changes — a director resigns or is appointed, the company secretary changes, the registered office moves, or the CEO changes. It must be filed within 15 days of the change, and missing that window means SECP's public record still shows outdated information, which can create real problems: a director who resigned but was never removed via Form 29 technically remains associated with the company on SECP's books.
The AGM Itself
The AGM is where audited accounts get formally approved, dividends get declared, auditors get appointed or reappointed, and directors due for re-election are confirmed. It needs at least 14 days' notice to members, a proper agenda, and minutes recorded in the company's minute book afterward. Even in small, family-run companies where every shareholder is also a director, skipping the paperwork creates a gap that can cause trouble later during an SECP inspection or a due-diligence review.
Audited Accounts Are Mandatory, No Exceptions
Every SECP-registered company, regardless of size or revenue, must have its accounts audited by a chartered accountant firm registered with ICAP — there's no small-company exemption in the current law. The audit needs to cover a balance sheet, profit and loss account, cash flow statement, statement of changes in equity, and supporting notes, signed by at least two directors (or a director and the CEO) plus the auditor. These accounts, once approved at the AGM, get filed with SECP within the same 30-day window as Form A.
What Late Filing Actually Costs
- Late Form A or late accounts: Rs. 5,000 initial penalty, plus roughly Rs. 200 per day it remains outstanding
- Late Form 29: Rs. 5,000, plus the same daily penalty
- Failing to hold the AGM on time: Rs. 10,000, plus daily penalty
- Not maintaining statutory registers: Rs. 25,000, plus daily penalty
Let enough years pile up unfiled, and SECP can move to strike the company off the register entirely — at which point it legally stops existing as a corporate entity, can't hold a bank account or sign contracts, and reviving it requires a court order plus payment of everything owed. That's a far more expensive and slower fix than simply staying current.
SECP Compliance and FBR Compliance Are Not the Same Thing
These run on entirely separate rails: SECP is governed by the Companies Act 2017 and filed through its own eServices portal, while FBR compliance runs under the Income Tax Ordinance through IRIS, with its own September 30 return deadline for individuals and its own penalty structure. Being current with one doesn't excuse the other — a company needs to satisfy both every year to stay in good legal standing.