The Securities and Exchange Commission of Pakistan (SECP) has set 28 October 2026 as the deadline for companies whose financial year ended on 30 June to hold their annual general meeting (AGM) and complete the related statutory requirements. For companies that have not yet held their AGM, the deadline falls tomorrow, so boards, company secretaries and auditors need to act now rather than waiting for a reminder.
An annual general meeting is not a formality. It is the meeting at which shareholders receive the financial statements, ask questions, appoint or reappoint directors and auditors, and deal with the other business that the law requires to be placed before them. Missing the deadline can create filing and compliance problems that follow the company into the next year.
Who the 28 October deadline applies to
The deadline applies to companies whose financial year ended on 30 June 2026. For those companies, an AGM is mandatory within 120 days of the close of the financial year, which is what produces the 28 October date.
Companies with a different financial year end are not covered by this particular deadline, and they should follow the timetable that applies to their own year end. The key point for any company is to work back from its own year-end date, not from a headline deadline that belongs to another group.
Private and single-member companies are not automatically exempt from holding an AGM, but there is a specific filing exemption described below for smaller companies where nothing has changed. That exemption relates to the annual return filing, and it should not be read as a general exemption from all AGM requirements.
What must happen at the annual general meeting
At the AGM, shareholders consider the audited financial statements and the directors’ report, and they deal with appointments and other ordinary business. The meeting gives shareholders a formal opportunity to question the board and to vote on matters that affect the company.
Proper notice, quorum and minutes matter as much as the meeting itself. A meeting that is called incorrectly, or whose decisions are not properly recorded, can create disputes later, even if the date itself was met.
Companies should therefore check their articles of association, the notice period, and the resolutions to be passed, and should ensure that the meeting is documented in a way that can be produced if the regulator or a shareholder asks for it.
Annual return filing after the AGM
The annual return must be filed within 30 days of the AGM. For an AGM held on 28 October 2026, that filing would be due by 27 November 2026. The form depends on whether information has changed: Form A is used if information has changed, and Form 24, the no-change intimation, is used if it has not.
If no AGM is held or concluded, the relevant annual filing must be completed by 30 January 2027. That later date is not a reason to delay, because it applies to a different situation — a company that has not held its AGM — and it does not extend the AGM deadline itself.
Private and single-member companies with paid-up capital up to Rs3 million are exempt from filing the annual return if there is no change. Companies that rely on that exemption should still confirm that they meet all of its conditions, including the paid-up capital limit and the no-change condition.
Ultimate beneficial ownership duties
Ultimate beneficial ownership (UBO) duties also apply alongside the AGM and annual return. These include Form 16 notices, Forms 17 and 18 declarations, maintaining a UBO register, and filing Form 19 with the annual return within 30 days of the AGM.
UBO rules are aimed at identifying the real individuals who ultimately own or control a company, rather than only the names on the share register. For companies with layered ownership, that can require tracing through intermediate companies to the ultimate individuals.
Because UBO information must be consistent with the annual return, companies should prepare it at the same time as the AGM papers, rather than treating it as a separate task to be completed after the filing deadline has passed.
What to do if the deadline is about to be missed
If a company has not yet called its AGM, the first step is to check whether a meeting can still be validly called and held by 28 October, including notice requirements and director availability. If that is not possible, the company should take professional advice promptly on its position, rather than assuming an extension will be available.
Companies should also prepare the financial statements, directors’ report and draft resolutions in parallel with calling the meeting, so that the meeting itself is not delayed by paperwork that could have been prepared earlier.
Keeping a clear timetable — meeting date, filing date, and UBO filing date — helps boards avoid the common error of meeting the AGM date but missing the filing date that follows it.
Key dates at a glance
AGM deadline: 28 October 2026, for companies whose financial year ended 30 June 2026. Annual return after a 28 October AGM: by 27 November 2026. Annual filing if no AGM is held or concluded: by 30 January 2027.
Those three dates are the core timetable from the SECP deadline report. Companies should diarise all three, even if only the first applies to them today, because the second and third dates explain what happens next in each scenario.
This article is a compliance explainer based on the SECP deadline report available on 27 October 2026, and it is not legal advice. Companies with complex ownership, audit or filing issues should confirm their position with their company secretary, auditor or legal adviser.
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