The First Counsel

The Advisory Hub

The Corporate Compliance Calendar

The recurring obligations of an established Pakistani company as one interlocking timetable — the audit, AGM, accounts, and Form A chain under the Companies Act, 2017, the tax year under the Income Tax Ordinance, 2001, the sales tax cycle, and the employer funds — and how a board keeps the machine from drifting.

An established company rarely falls out of compliance through ignorance. It falls through drift: the accountant who kept the dates in his head retires, the AGM slips a month, the slipped AGM delays the annual return, and eighteen months later the company discovers its filing history the way outsiders do — by reading it. This page lays out the recurring obligations of a Pakistani company as what they really are: not a list but a machine, with dependencies, and with a board that owns it. It states the position as of July 2026; deadlines, forms, and rates move by statute and notification, which is why every precise date below is bracketed rather than asserted. The startup hub carries a version for early-stage companies crossing thresholds for the first time; this page assumes the registrations exist and the question is keeping the machine running.

Four regimes, one year

The obligations arrive from four directions at once. The SECP administers the Companies Act, 2017 layer — the corporate record, meetings, accounts, and returns — through the eZfile portal. The FBR administers income tax under the Income Tax Ordinance, 2001 and federal sales tax under the Sales Tax Act, 1990, through IRIS. The provincial revenue authorities tax services under their own statutes, each with its own portal and its own monthly return. And the employer institutions — EOBI, the provincial social security bodies, and the workers' funds regimes — run cycles of their own. Each regime has its own logic of punishment: escalating fees at the SECP, default surcharge and Active Taxpayers List consequences at the FBR, arrears with penalties at the employer funds. A calendar that lists obligations without naming each one's regime and portal will fail the moment its author leaves.

The Companies Act chain: audit, AGM, accounts, Form A

The corporate year is a dependency chain, and this is the fact most calendars miss. The financial year closes. The audit must then be completed, because the audited financial statements are laid before the annual general meeting. The AGM, held within the statutory window after year end [PERIOD — TO BE VERIFIED BY REVIEWING LAWYER] on notice issued within the statutory notice period, receives the accounts and appoints the auditor for the coming year. The annual return on Form A is then filed within the prescribed period keyed to the AGM [PERIOD — TO BE VERIFIED BY REVIEWING LAWYER], and companies of the relevant classes file the financial statements themselves [CLASSES — TO BE VERIFIED BY REVIEWING LAWYER].

Read as a chain, every deadline in it is really an audit deadline: an audit that starts late compresses everything downstream until the company is choosing between a rushed audit and a late AGM. Boards that book the auditor's fieldwork at year end, rather than after it, rarely meet the rest of the chain in a hurry.

Around the chain sit the standing items. The election of directors runs on a three-year term under the Act, and an expired board discovered mid-transaction is a genuinely awkward finding [ELECTION PROVISIONS — TO BE VERIFIED BY REVIEWING LAWYER]. Board meetings must be held and minuted on the cadence the law and the articles require. Companies above the relevant thresholds must have a company secretary and, in higher classes, other named officers [THRESHOLDS — TO BE VERIFIED BY REVIEWING LAWYER]. And the registers — members, directors and officers, ultimate beneficial ownership under section 123A — are written up as events occur, because a register reconstructed at diligence reads exactly like what it is.

Event filings that cut across the calendar

The calendar's recurring lines are punctured by event-driven ones: a director resigns, shares are allotted or transferred, the registered office moves, the company grants security over assets. Each triggers its own return inside its own statutory window, and one of them — registration of charges — carries a consequence beyond fees, because an unregistered charge can leave the lender unsecured against a liquidator and the company in breach of its facility [WINDOWS — TO BE VERIFIED BY REVIEWING LAWYER]. The discipline that works is procedural, not heroic: no corporate event is complete until its filing is made and its register entry written, in the same week, by a named person.

The tax year: return, advance tax, withholding

The company's tax life runs on a different axis. Its tax year is defined under the Income Tax Ordinance, 2001 — the normal year ends 30 June, with special years available to certain classes [TO BE VERIFIED] — and the annual return is due on a statutory date keyed to that year end [DUE DATES — TO BE VERIFIED BY REVIEWING LAWYER]. Filing keeps the company on the Active Taxpayers List; lapsing off it raises the withholding rates counterparties apply to the company's own receipts, a same-month cash cost that makes this the least forgiving line on the calendar.

Two obligations recur inside the year. Advance tax under section 147 is paid quarterly against an estimate of the current year's liability — an estimate that must be revisited when the year improves or deteriorates, because a stale estimate produces either default surcharge or a needless loan to the exchequer. And withholding: from every salary run and most vendor payments, the company deducts tax as an agent, deposits it within the prescribed time, and reports it in the statements filed under section 165 on the current cycle [CYCLE AND DATES — TO BE VERIFIED BY REVIEWING LAWYER]. Withholding is where established companies quietly accumulate their largest tax exposure, because a failure costs the company someone else's tax plus surcharge, discovered years later.

Sales tax, month in month out

Sales tax is the calendar's metronome. A company selling goods files monthly with the FBR under the Sales Tax Act, 1990; a company rendering services files monthly with each provincial authority where it is registered — each province and the federal capital runs its own statute and portal — and a business doing both does both [DUE DATES — TO BE VERIFIED BY REVIEWING LAWYER]. Nil months are filed, not skipped. Because the return is relentless, it is the first obligation to fail when the finance team is stretched — a run of missed sales tax returns is usually the earliest symptom that the compliance machine has stopped. Treat it as the canary.

The employer cycle: EOBI, social security, and the profit-linked funds

The people side of the calendar runs monthly and annually at once. Monthly: contributions to EOBI under the Employees' Old-Age Benefits Act, 1976 and to the provincial social security institution under the Provincial Employees' Social Security Ordinance, 1965 framework, each by its prescribed date, each reconciled to actual headcount rather than last year's [DATES, THRESHOLDS AND RATES — TO BE VERIFIED BY REVIEWING LAWYER]. Annually, and tied to the accounts rather than the payroll: the workers' profit-linked regimes. The Companies Profits (Workers' Participation) Act, 1968 requires qualifying companies to allocate a share of profits to the workers' fund, and the workers' welfare fund legislation adds its own levy — both complicated, post-devolution, by provincial enactments whose reach remains contested [APPLICABILITY, RATES AND PROVINCIAL POSITION — TO BE VERIFIED BY REVIEWING LAWYER]. Because these compute from the audited accounts, they belong on the calendar as a closing step of the accounts cycle, owned jointly by finance and whoever signs the tax return.

Making it a board instrument

What separates companies that stay compliant from companies that used to be is not knowledge but design. Four features do the work. The calendar is one document, and every line carries four fields: the obligation, its statutory source, its date, and a named owner with a named backup. It is built backwards from the financial year end, so the dependency chain is visible rather than discovered. It is reconciled quarterly against eZfile and IRIS, because the portals are the regulators' version of the truth and the company's should never differ from it by surprise. And twice a year the whole calendar, with status against every line, goes to the board — under the directors' duty provisions of the Companies Act, 2017 the state of this machine is the board's business, and obligations with board visibility get done. A legal health check, covered elsewhere in this hub, photographs the company's position once; the calendar is what keeps the photograph true between sittings.

The Checklist

Corporate compliance calendar checklist

The lines an established company's compliance calendar must carry, sequenced around the financial year end.

  • Anchor the calendar on the company's financial year end and derive every Companies Act deadline backwards and forwards from that date.
  • Book the audit early enough that signed financial statements exist before the AGM notice has to be issued.
  • Issue the AGM notice within the statutory notice period and hold the meeting inside the statutory window after year end [PERIODS — TO BE VERIFIED].
  • Appoint or reappoint the auditor at the AGM, record the remuneration decision, and file whatever notice the appointment requires.
  • File the audited financial statements with the registrar where the company's class is required to file them [CLASSES AND PERIOD — TO BE VERIFIED].
  • File the annual return on Form A within the prescribed period after the AGM, every year, whether or not anything changed [PERIOD — TO BE VERIFIED].
  • Diarise the election of directors so the three-year term is never allowed to lapse unnoticed.
  • Hold and minute board meetings on the cadence the law and the articles require, and keep the minute book current, not reconstructed.
  • Refresh the ultimate beneficial ownership record under section 123A on every change in ownership or control, and verify it annually regardless.
  • File every event-driven return — director and officer changes, allotments, transfers, registered office, charges — inside its own statutory window.
  • File the company's income tax return by its statutory due date and confirm the company remains on the Active Taxpayers List [DUE DATES — TO BE VERIFIED].
  • Pay quarterly advance tax under section 147 against a live estimate of the current year, and revise the estimate when the year changes shape.
  • Deposit withheld tax within the prescribed time after each deduction and file the withholding statements on the current statutory cycle [CYCLE — TO BE VERIFIED].
  • File the sales tax return every month with each authority where the company is registered — federal for goods, provincial for services — including nil months [DUE DATES — TO BE VERIFIED].
  • Pay EOBI and provincial social security contributions monthly, and reconcile headcount against the contribution schedules each quarter [DUE DATES AND RATES — TO BE VERIFIED].
  • Compute the workers' participation fund allocation with the annual accounts and make the payments the regime requires [APPLICABILITY AND RATES — TO BE VERIFIED].
  • Renew every licence, registration, and sectoral permission ahead of expiry, with a named owner against each line.
  • Reconcile the calendar against the eZfile and IRIS portals every quarter, and table the full calendar with status at the board twice a year.

Questions, Answered

What clients ask most.

The Companies Act, 2017 requires the annual general meeting within a fixed period after the financial year end, with a longer allowance for the first AGM after incorporation, and exempts certain small private and single-member companies from holding one at all [PERIODS AND EXEMPTIONS UNDER SECTION 132 — TO BE VERIFIED BY REVIEWING LAWYER]. The date matters beyond the meeting itself: the audit must finish before it and the annual return is keyed to it, so a slipped AGM drags two other deadlines with it.

Form A is the annual return prescribed under the Companies Act, 2017 for companies with share capital — a snapshot of the registered office, directors, officers, and shareholding as at the return date, filed through the SECP's eZfile portal. Yes, it is filed every year regardless of change [FILING TRIGGER AND WINDOW — TO BE VERIFIED BY REVIEWING LAWYER]. Skipped years surface later as additional fees, a degraded compliance history, and awkward questions in any diligence or bank review.

The first auditor is appointed by the board within the statutory period after incorporation; thereafter shareholders appoint or reappoint at each AGM on the board's recommendation, and a casual vacancy is filled by the board within the prescribed time [PERIODS UNDER THE AUDITOR PROVISIONS — TO BE VERIFIED BY REVIEWING LAWYER]. The trap is treating reappointment as automatic: it is a resolution that must actually be passed and recorded each year, and a company that lets it lapse is in default even if the same firm keeps doing the work.

The due date under the Income Tax Ordinance, 2001 is keyed to the company's tax year end, with different statutory dates depending on where in the calendar the year closes, and the FBR periodically extends dates by notification [CURRENT DUE DATES — TO BE VERIFIED BY REVIEWING LAWYER]. Build the calendar on the statutory date, not the hoped-for extension. Filing late does not just risk penalty — it can cost the company its Active Taxpayers List status, which raises the withholding rates suffered on its own receipts immediately.

Three things, in rising order. First, additional filing fees that escalate with the length of the delay. Second, adjudication and penalties that can be imposed on the company and on its officers personally — the Act's default provisions frequently name officers in default alongside the company. Third, and most expensive, the record itself: the filing history is public, permanent, and read by every bank, investor, and regulator that later looks at the company. The fee is the cheapest part of the failure.

The skeleton is the same — audit, AGM, accounts, annual return, tax — but each step up in class adds mass: public companies face more filings and governance requirements, and listed companies add the SECP's listed-company governance regulations, PSX notifications, and quarterly reporting on top. Group structures multiply rather than differ: each subsidiary runs the full calendar in its own right, a recurring cost worth remembering when the next entity is proposed.

The full FAQ Center

Prepared by The First Counsel · As of 2026-07-12 · Pending professional review — statements flagged in the text are being verified

This publication is provided for general information only. It is not legal advice, and neither reading it nor corresponding with the firm about it creates a lawyer–client relationship. The position stated must be verified against current law before it is relied upon.

Every matter begins with a first conversation.

Contact the Firm