CDC Book-Entry Requirements for Unlisted Companies: Implications for Share Transactions and Annual Filings
In this alert, we examine the implications of SECP’s S.R.O. 328(I)/2026, which expands the circumstances in which unlisted companies are required to maintain their shares in book entry form through the Central Depository System operated by the Central Depository Company of Pakistan Limited (CDC). The regulatory changes are particularly relevant for unlisted companies intending to undertake share related transactions and complete statutory filings in view of the approaching annual Form A filing cycle.