Introduction: What is Form 20?
Form 20 is a statutory form issued by the Securities and Exchange Commission of Pakistan (SECP). It relates to the Pattern of Shareholding in a company. This form is used to declare and update the list of shareholders, how many shares each person holds, and what percentage of ownership they represent in the company. It is primarily required for public companies to promote transparency and ensure compliance with corporate governance regulations.
Who is Required to File Form 20?
Form 20 must be filed by:
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Every public company incorporated under the Companies Act, 2017
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Private companies only if they convert to public status or are instructed by SECP under special circumstances
For public companies, Form 20 is filed annually along with the company’s annual return.
Purpose of Form 20: Why It Matters
The key objective of Form 20 is to give SECP a transparent view of the company’s shareholding structure. This includes:
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Ensuring legal and financial transparency
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Detecting any hidden or indirect shareholding
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Complying with investor protection laws
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Supporting corporate accountability in public interest companies
It plays a vital role in corporate reporting and maintaining public trust.
Details Required in Form 20
When filling Form 20, companies must provide the following information:
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Full name of each shareholder
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CNIC number (for Pakistani nationals) or passport number (for foreign shareholders)
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Number of shares held by each shareholder
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Class of shares (such as ordinary shares, preference shares, etc.)
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Percentage of total shareholding each shareholder holds
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Details of any changes in the shareholding pattern during the year
This information gives SECP a complete picture of the ownership distribution.
When to File Form 20
Form 20 must be submitted annually. The deadline is within 30 days of holding the company’s Annual General Meeting (AGM) in which the financial statements are approved. The form is filed together with:
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Form A – for companies that held an AGM
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Form B – for companies that did not hold an AGM
Timely submission helps maintain compliance and avoid penalties.
How to File Form 20 with SECP
There are two methods of submitting Form 20:
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Online Filing via SECP e-Services Portal
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Log in to your company account on SECP’s portal
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Fill in the form with accurate shareholder details
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Attach supporting documents (such as CNIC/passport copy, if needed)
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Pay the prescribed fee using a challan form
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Submit the form online and receive acknowledgment
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Manual Submission at Company Registration Office (CRO)
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Download and print the filled form
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Attach required documents and payment receipt
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Submit at the concerned CRO office
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Most companies prefer the online method due to its speed and convenience.
Why Filing Form 20 is So Important
Staying compliant with SECP requirements by filing Form 20 has several advantages:
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Keeps the company’s public records accurate
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Avoids legal complications or disputes over shareholding
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Builds trust with investors, regulatory bodies, and financial institutions
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Helps during audits, funding rounds, or when applying for licenses
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Reflects good corporate governance practices
What Are the Risks of Not Filing Form 20?
Failing to file Form 20 on time can result in:
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Monetary penalties or fines from SECP
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Reputation damage in the eyes of investors and regulators
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Delays in business approvals, licensing, or fundraising
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Non-compliance notices and warnings from the regulatory authorities
It’s always better to file on time than to face regulatory consequences later.
Conclusion: Stay Compliant and Transparent
Form 20 may seem like a routine form, but it plays a crucial role in ensuring your company remains transparent and compliant in the eyes of the law. If you run a public company in Pakistan, make sure you file this form annually after your AGM. It’s a small task with big importance. If you’re not sure how to prepare it, consult your company secretary or a corporate compliance expert for help.
