The availability of a downloadable form does not necessarily mean that a company may submit it on paper. Under Pakistan’s corporate filing framework, the permitted method depends on both the company’s filing status and the particular document or transaction. Some filings are expressly subject to eZfile requirements, while physical submission remains available in other circumstances or with specific permission under the Companies Regulations, 2024, as amended.
This is Part III of a three-part series on ordinary private limited and Single Member Companies in Pakistan. It considers the Companies Act, 2017, the Companies Regulations, 2024 as amended, and relevant SECP notifications available as at 24 September 2026. The applicable filing mode should be checked for the particular company and transaction.
1. The General Rule Is Qualified by Mandatory Electronic Filing
Regulation 31 of the Companies Regulations, 2024 recognises electronic and physical submission of forms, returns, applications and documents. However, it does so subject to section 471(4) of the Companies Act, 2017, which enables mandatory electronic filing requirements.
The correct question is therefore not simply, “Does SECP accept paper forms?” It is: “Is physical filing permitted for this company, for this particular document, under the applicable notification and procedure?”
The answer may differ between companies and between two filings made by the same company.
2. Some Companies Fall Within the General Mandatory Online Regime
SECP’s mandatory electronic-filing notifications include private companies and SMCs with paid-up capital of Rs. 50 million or more. The framework also encompasses companies incorporated through the online system and companies whose last return or document was filed electronically, subject to the terms of the relevant notifications and the availability of the electronic filing process. The capital figure is in Pakistani rupees. The regime was introduced by S.R.O. 593(I)/2014, which also covers public companies.
Consequently, a low paid-up capital does not automatically create a right to file on paper. A small company incorporated online may already fall within the mandatory online regime.
A company within a mandatory category that faces a genuine obstacle to online submission should obtain the express permission of the registrar or other competent SECP authority before filing on paper. That is a request for permission—not an unrestricted choice to ignore the required online method. The general filing procedure must be read with the applicable mandatory online regime.
A legacy company outside the mandatory categories may retain a physical filing route for documents covered by the general rule. Even then, a document-specific online requirement may override that route.
3. Specified Director and Chief-Executive Changes Must Use eZfile
Regulation 50(2), as amended in September 2024, expressly requires eZfile submission for specified matters involving directors and chief executives. These include appointments and elections, resignations and retirements, and the prescribed processes for removal, vacation of office and death. The regulation specifies supporting evidence appropriate to the event.
This is not merely a matter of scanning a signed Form 9. The procedure includes electronic verification requirements, subject to the exceptions and safeguards stated in the regulation.
What happens when an outgoing officer does not verify?
Where the required verification is not completed within the prescribed five-day period, regulation 50(2) provides a route for reporting the impediment through eZfile so that the registrar can consider the matter after due diligence. An outgoing officer’s failure to cooperate should therefore be addressed through the prescribed procedure rather than by assuming that an unapproved paper filing will suffice.
When can paper be allowed?
Where the induction or cessation cannot be processed through eZfile, the Registrar of Companies may permit physical filing for special reasons recorded in writing, supported by the required evidence, under regulation 50(2).
The distinction is important: the exception requires the registrar’s permission; the company cannot grant itself the exception.
Not every item reported on Form 9 necessarily falls within the same director-and-chief-executive rule. Auditor, legal-adviser and other officer filings must be assessed under their relevant provisions and the company’s general electronic-filing status.
4. Form 19: SECP’s Current Direction Is Filing Through eZfile
SECP’s 21 April 2026 public compliance direction expressly instructs companies to submit Form 19 through eZfile, while keeping accurate and updated beneficial-ownership information. Companies should follow that direction and should not assume that a printed Form 19 is an interchangeable alternative.
That announcement included a specific compliance deadline of 30 April 2026. It should not be mistaken for a permanent annual deadline falling on 30 April every year. The recurring deadlines remain those prescribed by the regulations: filing with the annual return, or within thirty days after calendar year-end where no annual return is required, together with the relevant change-based filings.
The underlying UBO notices, declarations and records remain distinct from the company’s electronic submission. Maintaining signed records does not make the SECP filing itself a paper filing.
5. Practical Filing-Mode Guide
| Document or activity | Applicable approach |
|---|---|
| Form A or Form 24 | Use the electronic route where the company falls within a mandatory online category. Physical filing is conditional on eligibility under the general rules or an applicable permission. |
| Annual financial statements and annexures, where filing is required | The same company-level electronic-filing requirements apply; an accounts-filing obligation does not automatically carry a paper option. |
| Form 9 for specified director or chief-executive events | Follow regulation 50’s mandatory eZfile process. Physical filing requires the stated exceptional permission. |
| Form 19 and prescribed UBO information | Follow SECP’s current eZfile direction and the substantive requirements of regulations 48 and 48A. |
| Other applications, petitions or supporting documents | Check the governing provision, applicable online notification, available process and any specific approval for physical submission. |
| Internal minutes, registers, notices and declarations | These are not automatically separate SECP filings. Maintain, sign and serve them in the manner required by the relevant law and company documents. |
This guide should be applied alongside the Companies Regulations, mandatory online-filing requirements, Form 19 direction and the particular form’s instructions—not in place of them.
6. What Does a Permitted Paper Application Require?
Where physical filing is legally available, regulation 31 sets requirements concerning the form of the document, signatures, attachments and evidence of fee payment. Applications and appeals must contain the prescribed information, which may include the statutory provision invoked, relevant facts, grounds, relief sought and an affidavit verifying the contents.
An informal letter is not necessarily sufficient where the law prescribes a form or a structured application.
The distinction between dispatch and receipt also matters. Under regulation 34(1), a document is treated as received or delivered on the day it is received by the relevant office. Posting a document on the last day should not be assumed to satisfy a deadline requiring filing by that date.
For electronic submissions, preserve the submitted form, attachments, payment evidence and acknowledgement, and monitor any objection or deficiency. Paying a fee is not a substitute for completing submission of the required document.
7. A Paper Supporting Document Is Not the Same as Paper Filing
A corporate transaction may require an originally signed resolution, consent, affidavit or other supporting document, while the statutory submission itself must be made electronically. The requirement to execute a document does not determine the channel through which the company must submit the resulting filing. See the Companies Regulations.
For example, an electronically filed return may require an uploaded resolution or death certificate. Conversely, a company may be required to maintain an original record without filing that record separately every year.
This distinction helps prevent two opposite mistakes: omitting necessary corporate records because the process is online, or submitting documents physically because their underlying originals were signed on paper.
8. The 2026 Certificate of Statutory Compliance Is Not an Annual Renewal
In 2026, SECP introduced a Certificate of Statutory Compliance framework through S.R.O. 875(I)/2026. It enables an eligible company to apply for a certificate concerning its status and statutory compliance record. It should not be described as a new compulsory annual renewal of every private company’s incorporation.
The framework contemplates manual or electronic issuance. However, the method by which a certificate is issued does not independently give an online-mandated company an unrestricted right to submit its application on paper.
The certificate should also be distinguished from the annual certificate obtained from a company’s statutory legal adviser under the 1975 Rules. They arise under different instruments and serve different purposes.
Conclusion: Determine the Obligation Before Choosing the Filing Method
Reliable SECP compliance requires three separate decisions: what the company must do, when it must do it, and how it must submit the required information.
A private company may be exempt from submitting financial statements but still require an audit. An SMC may be exempt from an AGM and a no-change annual return but still have to file beneficial-ownership information. A small company may have no general paper option because it was incorporated online, while a particular director-related filing may require eZfile regardless of the company’s older filing history. These distinctions arise from the Companies Act, Companies Regulations and electronic-filing requirements.
For businesses seeking a corporate lawyer in Karachi or assistance with company compliance in Pakistan, the starting point should be a review of the company’s constitution, paid-up capital, filing history, ownership structure and actual transactions—not a generic annual filing package.
Legum Law Firm advises companies on corporate governance, statutory compliance, beneficial-ownership disclosures, shareholder and director matters, and applications before the relevant regulatory authorities.
This article provides general information and does not constitute legal advice for a particular company. Tax, employment, social-security, licensing and sector-specific obligations require separate review. Applicable amendments, notifications, company classifications and registrar directions should be checked before a filing or exemption is relied upon.
