Introduction
Changing a company’s registered office address is a common event in the lifecycle of a business. Whether you’re relocating to a more strategic location, expanding operations, or simply shifting administrative control, it is mandatory under Pakistani corporate law to update this change with the Securities and Exchange Commission of Pakistan (SECP) and other relevant authorities.
This comprehensive guide explains the legal requirements, forms, procedures, timelines, and consequences of not updating a company’s address. If you’re a director, company secretary, or business owner in Pakistan, this article outlines everything you need to ensure seamless compliance.
1. What Constitutes a Change of Company Address?
In Pakistan, a company can change its address in two ways:
| Type of Change | Regulatory Procedure |
|---|---|
| Change of address within the same city | Requires SECP notification via Form 21 |
| Change to a different city/province | Requires approval and special resolution |
2. Legal Framework
Governing Law:
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Companies Act, 2017
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Companies (General Provisions and Forms) Regulations, 2018
Relevant Sections:
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Section 21: Notice of situation of registered office
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Section 146: Maintenance of records at the registered office
3. Why Is It Mandatory to Update Your Address?
a. Legal Recognition
The SECP uses the registered address for:
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Official notices and legal correspondence
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Inspection or audit visits
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Delivery of legal summons or court orders
b. Regulatory Compliance
Updating the address helps maintain:
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Proper statutory records
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Valid communications with tax, labor, and banking authorities
c. Avoiding Penalties
Failure to notify SECP of an address change may result in penalties up to PKR 50,000 and inspection under Section 254.
4. Pre-Change Checklist
Before initiating the change of address, ensure:
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Board approval is obtained
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There are no ongoing SECP investigations or show-cause notices
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The new address is a physical, verifiable location
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Utility bills or lease agreement of the new office are available
5. Types of Address Change and Applicable Requirements
A. Change Within the Same City
Procedure:
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Hold a Board Meeting
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Pass a board resolution to change the registered address
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File Form 21 on the SECP eServices portal
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Attach a copy of:
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Utility bill of new address
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Lease deed or ownership proof
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Timeline: Within 15 days of the change
Fee: PKR 1,000 – 3,000 depending on company type
B. Change to Another City or Province
Additional Requirements:
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Pass a Special Resolution in a general meeting
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File Form 26 for special resolution within 15 days
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Submit Form 21 after special resolution
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Provide updated Memorandum & Articles of Association if address is mentioned therein
6. Step-by-Step Process to File Form 21 (Online)
Step 1: Log in to SECP eServices
Visit: https://eservices.secp.gov.pk
Step 2: Select Company and Filing Type
Choose:
“Statutory Returns” → “Form 21 – Notice of Change in Address”
Step 3: Fill Details
Enter:
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Old address
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New address
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Date of change
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Board or special resolution reference
Step 4: Upload Required Documents
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Copy of board resolution
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Utility bill (not older than 2 months)
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Lease or ownership agreement
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Form 26 (if change of city)
Step 5: Pay the Filing Fee
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Generate bank challan or use credit card
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Submit proof of payment online
Step 6: Submit and Track
Receive acknowledgment and tracking ID for your submission.
7. Additional Authorities to Notify
Once SECP updates the company address, notify the following:
| Authority | How to Update |
|---|---|
| FBR (NTN) | Update in IRIS portal under Business Profile |
| Provincial Revenue Authority | Submit application with utility bill & lease |
| EOBI & PESSI | Provide SECP approval and new address evidence |
| Banks | Submit certified Form 21 and resolution |
| Chamber of Commerce | Update profile to continue certifications |
8. Documents Required
| Document | Mandatory? |
|---|---|
| Board Resolution | ✅ |
| Form 21 | ✅ |
| Utility Bill of New Office | ✅ |
| Lease Deed / Ownership Proof | ✅ |
| Special Resolution (if new city) | ✅ |
| CNIC of Authorized Officer | ✅ |
| Updated MoA (if address included) | Optional |
9. Penalties for Non-Compliance
| Violation | Penalty |
|---|---|
| Not filing Form 21 within 15 days | Fine of up to PKR 50,000 |
| Continuing to operate under old address | Risk of legal notices not being served |
| Discrepancy in FBR vs SECP addresses | Tax scrutiny, compliance flags |
10. Real-Life Example
Case: IT Company Relocates to Bahria Town, Islamabad
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Filed board resolution and Form 21 within 10 days
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Updated address with FBR and PRA
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SECP approved within 3 working days
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Bank accounts updated without disruption
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Avoided late filing penalty
11. Frequently Asked Questions (FAQs)
Q1: Can we use a virtual office as a registered address?
No. SECP requires a physical, verifiable location. Virtual or PO Box addresses are not acceptable.
Q2: Is it necessary to file Form 21 if only the correspondence address changes?
Yes, if the registered office changes, Form 21 is mandatory—even if the new address is within the same premises.
Q3: Can we submit Form 21 manually?
No. All filings must be submitted via SECP’s eServices portal.
Q4: Do we need to notify SECP if we open a new branch office?
No. Only registered office address changes require SECP notification.
12. Role of Compliance Consultants Like Sterling.pk
At Sterling.pk, we provide:
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Drafting of board and special resolutions
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Preparing and submitting Form 21 and Form 26
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Coordinating with SECP and other authorities
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Updating your NTN and tax profile with FBR
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Providing notarized and certified copies for banks and stakeholders
Our goal is to ensure error-free, timely compliance—keeping your business operations smooth and uninterrupted.
Conclusion
Changing your company’s address in Pakistan is a routine yet legally sensitive task. Delays or errors in filing Form 21 can result in regulatory penalties, tax mismatches, and compliance disruptions. With a clear understanding of the SECP requirements, supporting documents, and update procedures, you can ensure a seamless transition to your new location.
Let Sterling.pk handle the paperwork while you focus on growing your business—compliantly and confidently.
