Filing Multiple Statutory Returns A Detailed Guide

Introduction
In Pakistan, companies are required to file multiple statutory returns with various government authorities, including the Securities and Exchange Commission of Pakistan (SECP), the Federal Board of Revenue (FBR), and provincial revenue boards. These returns serve to ensure regulatory compliance, tax transparency, and accurate public records.

Failure to timely file these returns can result in penalties, reputational risk, and even legal action. This guide covers the major statutory returns, their due dates, filing procedures, and best practices for companies of all sizes—especially private limited companies, public companies, and SMEs.


1. Annual and Periodic Returns with SECP

SECP requires companies to maintain updated corporate records through routine filings.

Return Type Form No. Frequency Deadline
Annual Return Form A / B Annually Within 30 days of AGM or 365 days after incorporation
Director/Officer Changes Form 29 As needed Within 15 days of change
Change in Registered Office Form 21 As needed Within 15 days of change
Allotment of Shares Form 3 As needed Within 45 days of allotment
Increase in Capital Form 7 As needed Within 15 days of resolution
Change in Business Activity Form 4 As needed Within 30 days of resolution
Amendment in MOA Form 5 As needed Within 15 days of change

Where to File: SECP eServices Portal
Penalty for Delay: Ranges from Rs. 5,000 to Rs. 100,000 depending on company type and delay duration


2. Federal Tax Returns and Reports (FBR)

All companies must register with FBR and comply with income and sales tax obligations.

Return Type Form / System Frequency Deadline
Income Tax Return IRIS Annually Sept 30 (Individuals/AOPs) / Dec 31 (Companies)
Statement of Final Tax Deduction Form 45 Monthly 15th of next month
Statement of Salary Deductions Form 46 Quarterly Within 45 days
Sales Tax Return (if applicable) STR-7 Monthly 15th of every month
Advance Tax Payments IRIS Quarterly As per Sec. 147 ITO

Where to File: FBR IRIS Portal
Penalty for Non-Compliance:

  • U/S 182: Rs. 2,500/day or minimum Rs. 10,000 for late filing

  • Penalty for non-filing or misreporting can reach Rs. 50,000+


3. Provincial Sales Tax on Services (PRA, SRB, KPRA, BRA)

If your business provides taxable services, you must file monthly returns with the respective provincial revenue authority.

Province Return Form Frequency Deadline
Punjab (PRA) Form PST-03 Monthly 15th of each month
Sindh (SRB) SRB Annex-C Monthly 18th of each month
KPRA Online Portal Monthly 15th of each month
Balochistan (BRA) BRA Web Form Monthly 15th of each month

Penalty: Late filing can attract penalties between Rs. 10,000 and Rs. 100,000 plus default surcharge.


4. Employees’ Contribution and Payroll Statutory Returns

Employers must submit returns for contributions under social security and EOBI laws.

Contribution Type Authority Return Frequency Deadline
Social Security PESSI / SESSI Monthly Before 15th of each month
EOBI Contributions EOBI Monthly Before 15th of each month
Employee Income Tax Deduction FBR Monthly/Quarterly See Form 45 / 46 above

5. Annual Audited Financial Statements

Companies must file their audited financial statements with SECP and FBR.

Requirement Entity Type Due Date
Audited Accounts (SECP) All Companies Within 30 days of AGM (public)
Tax Computation + Audit All Taxpayers With Income Tax Return filing

6. Other Common Returns and Declarations

Purpose Form/Platform Authority Frequency
BO (Beneficial Ownership) Declaration Form 45 SECP Annually/Update
Declaration under AML Act STR/CTR filing FMU/SECP As needed
Foreign Shareholding Report SECP Reporting SECP Annual / Update
Data Security / IT Compliance (if listed) PSX/SECP Circulars SECP/PSX Quarterly / Annually

Best Practices for Managing Statutory Compliance

✅ Maintain a compliance calendar integrating FBR, SECP, and provincial deadlines
✅ Use cloud accounting & payroll systems for accurate reporting
✅ Assign a compliance officer or consultant for filing responsibilities
✅ Regularly audit internal records before filing statutory data
✅ Keep digital and physical records for 6–10 years per legal requirement


Consequences of Non-Compliance

Authority Consequence
SECP Penalties, suspension of company status, disqualification of directors
FBR Tax audits, heavy fines, blacklisting, disallowance of expenses
PRA/SRB Penalties, notices, and possible license cancellation
EOBI/PESSI Legal prosecution, fines, employee disputes

Conclusion

Filing multiple statutory returns is an ongoing responsibility that businesses in Pakistan cannot afford to ignore. Whether you’re managing SECP changes, FBR filings, or provincial sales tax returns, a systematic approach and professional support can help your business stay compliant, avoid penalties, and build credibility with regulators and stakeholders.


Need help managing your statutory filings?
At Sterling Consultancy, we specialize in:

  • SECP and FBR return filing

  • Sales tax compliance across all provinces

  • EOBI, PESSI, and payroll tax compliance

  • Corporate recordkeeping and regulatory audits

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