How to Prepare for an Audit in Pakistan

Introduction

Whether conducted by an external auditor, a regulatory body like SECP or FBR, or initiated internally, an audit is a critical review process that verifies a business’s financial and operational integrity. In Pakistan, audits are not only a matter of financial scrutiny—they are legally required for most registered companies under the Companies Act, 2017, Income Tax Ordinance, 2001, and other applicable laws.

Audit preparation, if handled correctly, can improve your company’s credibility, compliance standing, and investor confidence, while minimizing the risk of penalties and reputational damage.

This comprehensive guide walks you through everything you need to know about how to prepare for an audit in Pakistan—from understanding audit types to organizing documentation, internal controls, timelines, and audit readiness best practices.


1. What is an Audit?

An audit is an independent examination of a company’s financial statements, records, internal processes, or legal compliance to ensure that:

✅ Financial reports are accurate
✅ Internal controls are working effectively
✅ Tax and regulatory compliance is being met
✅ No fraud, misstatement, or procedural violations exist


2. Types of Audits in Pakistan

Type of Audit Conducted By Objective
Statutory Audit External auditor (CA firm) Required under Companies Act, 2017
Tax Audit FBR or authorized tax officer Verifies income and tax compliance
Sales Tax Audit FBR’s Sales Tax Wing Assesses GST compliance
Internal Audit Internal department or consultant Evaluates internal controls
SECP Inspection SECP’s Compliance Division Corporate filings and governance
Special Audit Ordered by SECP/FBR/Board Targeted audit of a specific area

3. Who Is Required to Undergo Audit in Pakistan?

Under the Companies Act, 2017:

Company Type Audit Required? Audit by QCR-Rated Firm?
Private Company (Turnover > Rs. 3 million) ✅ Yes ❌ No
Public Company ✅ Yes ✅ Yes (Listed)
Single Member Company ✅ Yes ❌ No
Section 42 Non-Profit ✅ Yes ✅ Often Required
Listed Company ✅ Yes ✅ Yes (Mandatory)

Under the Income Tax Ordinance, 2001:

  • FBR may select businesses randomly or based on risk profile for tax audit under Section 177 or 214C.


4. Benefits of Being Audit-Ready

Avoid penalties and legal action
✅ Faster audit process with minimal disruption
✅ Improved investor and lender confidence
✅ Enhanced internal financial discipline
✅ Stronger corporate governance image


5. Key Areas Reviewed During an Audit

Audit Focus Area What Is Checked
Financial Statements Balance sheet, P&L, cash flow, notes
Tax Compliance Income tax, sales tax, withholding tax returns
Supporting Documentation Vouchers, receipts, invoices, bank statements
Corporate Governance Board resolutions, Form A/B/29, MoA/AoA
Internal Controls Authorization policies, segregation of duties
Statutory Registers Shareholder, director, UBO registers
Inventory and Fixed Assets Stock counts, depreciation schedules, asset registers
Payroll & HR Records EOBI, gratuity, WHT, employment contracts

6. Step-by-Step Guide to Preparing for an Audit

Step 1: Review Applicable Laws and Requirements

✅ Determine whether your audit is under:

  • Companies Act (statutory)

  • FBR (tax audit)

  • SECP (corporate inspection)

Each audit type has different documentation and scope.


Step 2: Appoint a Qualified Auditor

  • Must be a CA or firm registered with ICAP

  • For public/listed companies, select a QCR-rated audit firm

  • Sign an engagement letter defining scope, deliverables, and timeline


Step 3: Organize and Update Financial Records

Ensure all records are:

  • Complete, updated, and error-free

  • Reconciled with bank statements and ledgers

  • Labeled and filed properly (digitally or physically)

Key documents to prepare:

Financial Documents
General Ledger (GL)
Trial Balance
Bank Reconciliation
Journal Vouchers
Cash Book
Chart of Accounts
Adjusting Journal Entries

Step 4: Reconcile Tax Compliance

Prepare and organize:

Tax Document Frequency
Income Tax Returns (IRIS) Annually
Sales Tax Returns (STR) Monthly
Withholding Tax Statements Quarterly/Monthly
Challans and Tax Payment Receipts All periods
FBR Notices and Replies As received

Check for tax understatements, delays, or discrepancies before the audit team does.


Step 5: Update Statutory Registers and SECP Records

Ensure your:

Form A, Form B, Form 29 are up to date
Board resolutions are documented
Shareholder and director registers are updated
✅ UBO declarations (Form 45) are filed and documented


Step 6: Prepare Inventory and Fixed Assets Records

✅ Perform a stock count if required
✅ Update your fixed asset register
✅ Reconcile with accounting system and invoices
✅ Ensure assets are tagged and depreciated as per IAS standards


Step 7: Review Payroll, HR, and Contribution Compliance

HR Record Requirement
Salary Sheets Monthly
EOBI and Social Security Compliance with SESSI/EOBI
Income Tax Deduction (Form 16) Monthly WHT compliance
Contracts and Attendance Supporting documentation

Step 8: Conduct Internal Pre-Audit Review

Assign your internal or external accountant to:

✅ Perform mock audit checks
✅ Identify any gaps or red flags
✅ Prepare management responses in advance
✅ Ensure consistency across financials and disclosures


7. How to Handle the Audit Process Professionally

Tip Benefit
Designate a single point of contact Smooth communication with auditors
Provide structured access to documents Saves time and builds confidence
Be honest and transparent Builds trust, reduces suspicion
Don’t delay responses or deny access Can trigger detailed investigation
Document everything you provide Ensures a record in case of dispute

8. Special Considerations for Different Audit Types

A. Tax Audit by FBR

  • Triggered under Section 177 or 214C

  • FBR issues notice via IRIS portal

  • Provide record within 15 days, including:

    • Ledger

    • Invoices

    • Vouchers

    • Salary sheets

    • Bank statements

    • Explanations for major expenses or loss

B. SECP Inspection or Compliance Audit

  • SECP may inspect:

    • Filings (Form A, Form 29, Form C)

    • Board minutes and governance procedures

    • UBO records and AML compliance

  • Provide access to the registered office and officers

C. External Statutory Audit

  • Conducted annually by auditor

  • Must issue auditor’s report within:

    • 120 days (for public companies)

    • 180 days (for private/SMCs)


9. Digital Audit Readiness

✅ Use cloud-based accounting systems
✅ Organize digital folders by fiscal year
✅ Maintain version control of financial statements
✅ Keep backups of:

  • Tax returns (PDF from IRIS)

  • EOBI/SESSI returns

  • SECP filings


10. Common Mistakes to Avoid

Mistake Consequence
Disorganized documentation Delays, penalties, auditor frustration
Inconsistent records Doubts over accuracy and reliability
Not filing required SECP forms Fines and possible legal action
Underreported tax liabilities Heavy penalties and interest from FBR
No evidence of board meetings Corporate governance failure
Unprepared audit staff Miscommunication and non-compliance

11. Frequently Asked Questions (FAQs)

Q1: How often should companies in Pakistan be audited?
All companies with turnover over Rs. 3 million must be audited annually.

Q2: Can SECP audit a private company?
Yes. SECP can inspect records of any registered company at its discretion.

Q3: What happens if I ignore an FBR audit notice?
It may result in:

  • Best judgment assessment

  • Heavy fines

  • Possible legal action

Q4: Is audit mandatory for startups and SMCs?
Yes, if their turnover exceeds Rs. 3 million or if they are registered under the Companies Act.

Q5: Do nonprofits (Section 42) require audit?
Yes. They are required to maintain audited accounts and submit them to SECP annually.


12. How Sterling.pk Can Help

At Sterling.pk, we provide:

Pre-audit review and mock audit testing
✅ Preparation of financial statements and schedules
✅ Tax and SECP compliance audit readiness
✅ Liaison with auditors and regulators
✅ Training your staff on audit support best practices
✅ Audit support for statutory, tax, or SECP inspections

We ensure that your business is fully prepared, legally compliant, and audit-confident.


Conclusion

Audits in Pakistan—whether regulatory, statutory, or tax-related—are a critical part of the compliance lifecycle for any company. Proactive preparation, good record-keeping, and clear internal communication can make the audit process smooth, fast, and beneficial.

By understanding the scope, requirements, and timelines involved in audits—and with expert support from Sterling.pk—your business can convert audits into an opportunity for improvement and credibility, rather than a source of stress or penalties.

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