Regulatory Alerts2025-08-21
Added · Updated
Circular No. 21 of 2025 – Company Responsibility under Section 123A of CA 2017 read with Regulation 48 of CR 2024
Companies incorporated under the Companies Act, 2017, including foreign companies, must maintain an adequate and accurate Ultimate Beneficial Owner (UBO) register in compliance with Section 123A and Regulation 48. This register must identify natural persons exercising beneficial ownership or control through direct or indirect means, such as chain of ownership, joint control arrangements, or senior managerial positions, using minimum data from Form-16 and additional details from Form-17. Companies are required to verify the identity and status of beneficial owners using reliable documents and open-source information, updating the register within one month of any changes or identification of outdated data. Additionally, companies must provide UBO information to the Securities and Exchange Commission of Pakistan, other authorized authorities, and financial institutions, while reporting any shareholders who refuse to provide required information.