The First Counsel

Client Alert

Company incorporation: changes to the SECP regime

Incorporation now runs end-to-end through SECP's eZfile portal, with tax registration attached — the speed is real, and the compliance questions have moved downstream.


25 March 2026 · 3 min read · The First Counsel

Draft — for lawyer review before publication

Incorporating a company in Pakistan is governed by the Companies Act 2017 and the Companies (Incorporation) Regulations 2017, as amended. The statute has not been rewritten. The process around it has. This alert states the position as of late March 2026.

What changed

The SECP has replaced its old eServices system with the eZfile portal, and incorporation is now a digital process from name reservation to certificate [transition dates — TO BE VERIFIED BY REVIEWING LAWYER]. Name reservation and incorporation can be combined in a single application. Fees for online filing are lower than the offline schedule, and for routine cases the offline route has effectively disappeared [current fee schedule — TO BE VERIFIED BY REVIEWING LAWYER].

Registration has also been bundled. Through the SECP's integration with the FBR, a company receives its National Tax Number as part of incorporation, and the registration data flows onward to certain other authorities — including provincial and social-security registrations through the integrated business registration arrangements [current scope of the integrations — TO BE VERIFIED BY REVIEWING LAWYER].

The memorandum itself is simpler than it used to be. Following the substitution of section 26 of the Act, a company states its principal line of business and may, subject to stated restrictions, engage in any lawful business — the old practice of drafting exhaustive object clauses is gone [amendment reference — TO BE VERIFIED BY REVIEWING LAWYER].

Two obligations run the other way. Companies must obtain, maintain, and report ultimate beneficial ownership information under section 123A and the related regulations, and declarations on beneficial ownership now form part of the incorporation and post-incorporation filings [form numbers — TO BE VERIFIED BY REVIEWING LAWYER]. And where a subscriber or director is a foreign national, security clearance requirements apply, with the application processed against an undertaking while clearance from the Ministry of Interior is obtained [current procedure — TO BE VERIFIED BY REVIEWING LAWYER].

What it means

For a straightforward company with resident sponsors, incorporation is now fast — often a matter of days, and the SECP has advertised same-day processing for simple cases [service standards — TO BE VERIFIED BY REVIEWING LAWYER]. The friction has not vanished. It has moved.

It has moved, first, into the inputs. The portal rejects nothing so reliably as inconsistent data: a subscriber's name that does not match the CNIC, a principal line of business that collides with a licensing regime, a proposed name too close to an existing one. Second, into the foreign-shareholder track, where security clearance and attestation of foreign corporate documents set the real timeline, not the portal. Third, into post-incorporation compliance: the beneficial ownership register, the first auditor, the statutory registers, and the filings that fall due in the first weeks of the company's life are now where new companies most often default.

One more point deserves attention. Because the incorporation data feeds the FBR and other authorities automatically, an error made on day one — a wrong address, a mis-stated principal activity — replicates across registrations and takes longer to correct than it took to make.

What this means for you

Prepare the inputs before touching the portal: exact names against CNICs or passports, a registered office address that will survive the first year, and a principal line of business checked against any sectoral licensing it may trigger. If any subscriber or director is a foreign national or a foreign company, start the clearance and document-attestation work first — it is the critical path, and nothing else on the timeline matters until it moves. Identify the ultimate beneficial owners before incorporation and keep the supporting documents; the declaration is not a formality and the register must be maintained from the start. Calendar the post-incorporation obligations on the day the certificate arrives — auditor appointment, statutory registers, and the first filings — rather than at the first year-end. And treat the incorporation data as permanent: verify every field before submission, because the same data now sits with the tax authorities from day one.

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.

The position stated is as of 25 March 2026 and must be verified against current law.

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