What is a Joint Inspection in Pakistan?

A Joint Regulatory Inspection is a coordinated audit conducted by the Securities and Exchange Commission of Pakistan (SECP), Federal Board of Revenue (FBR), and provincial revenue bodies (PRA/SRB) to verify corporate records, statutory registers, UBO declarations, and tax withholding compliance.

What are the penalties for non-dematerialization of shares under SRO 328(I)/2026?

Under Section 72 of the Companies Act 2017 read with S.R.O. 328(I)/2026, failing to convert physical share certificates into Central Depository System (CDS) book-entry form attracts a Level 3 penalty up to PKR 100 million plus PKR 500,000 per day of continuing default.

Joint Inspection & Audit Readiness Scorecard • COMPLIFY.PK

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Core Corporate & Tax Audit Pillars (Click to Verify)

1. CDC Share Dematerialization (S.R.O. 328(I)/2026) Have 100% of physical shares been converted into CDS digital book-entry form? (Level 3 penalty: PKR 100M u/s 72).

2. SECP Form 19 Ultimate Beneficial Owner (UBO) Filing Is Form 19 active on eZfile identifying all natural persons holding ≥ 25% shares or voting control?

3. Statutory Physical Registers at Registered Office Are Member Registers (Sec 119), Director Registers (Sec 197), and Charges (Register R-5) available on premises?

4. FBR Weekly Withholding Tax Deposits (Rule 43(b)) Are income tax deductions (Salary u/s 149, Vendors u/s 153) remitted within 7 days of each week ending Sunday?

5. Quarterly Section 165 Statements on FBR IRIS Are payee-wise withholding tax statements filed on IRIS for all four quarters (or mandatory nil returns)?

6. Provincial Sales Tax Returns (PRA / SRB / KPRA / BRA) Are monthly provincial sales tax returns and Form PST-04 withholding declarations filed by the 18th?

7. EOBI PR-01 Contribution Slips (5+ Workers) Is the 5% employer + 1% employee contribution on minimum wage deposited by the 15th of each month?

8. Provincial Social Security (PESSI / SESSI / KPESSI / BESSI) Are 6% employer social security contributions on covered workers remitted by the 15th of each month?

9. Workplace Anti-Harassment (PAHWWA 2010/2022) Compliance Is a permanent 3-member Inquiry Committee constituted (≥ 1 female member) with Code of Conduct displayed?

10. Annual Professional Tax Paid (Excise Department) Has the annual provincial professional tax challan based on paid-up capital been cleared by 30 June?

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SECP & FBR Joint Inspection Legal Guidelines (FAQ)

What triggers a Joint Regulatory Inspection in Pakistan?

Joint inspections are commonly triggered by discrepancies between sales tax turnover and income tax declarations, non-filing of SECP Form 19 UBO registers, unregistered physical offices, failure to dematerialize physical shares into CDS, or failure to register employees under provincial social security (PESSI/SESSI).

What documents must be physically available on premises?

Under the Companies Act 2017, every company must maintain physical statutory registers at its registered office: Member Register (Sec 119), UBO Register (Sec 123A), Officers and Directors Register (Sec 197), and Mortgages & Charges Register. Additionally, the PAHWWA Harassment Code of Conduct must be visibly displayed on notice boards.