Primary reference: Section 10, Lawyers Welfare and Protection Act, 2023; SECP compliance reminder of 22 October 2026 · Detailed research review: 25 October 2026. Consult the original instrument and any later amendments; draft measures are not operative until approved and commenced.
SECP's October compliance reminder concerns section 10 of the Lawyers Welfare and Protection Act, 2023: companies with paid-up capital over Rs20 million must retain a practising advocate, who may advise no more than three covered entities, and report appointment details on Form-9.
Exactly who must appoint a legal adviser
Section 10 of the Lawyers Welfare and Protection Act, 2023 requires every incorporated company with more than Rs20 million paid-up capital to engage at least one practising advocate as its legal adviser on a retainership basis. Autonomous bodies, corporations and statutory authorities are separately included by the section.
The trigger refers to paid-up capital—not authorised capital—and requires the amount to exceed Rs20 million (Rs2 crore). Companies should test actual paid-up capital rather than their permitted share capital.
The adviser limit and the filing specified by SECP
The same section prevents one advocate from serving simultaneously as legal adviser to more than three entities within its scope. An adviser should check this cap before accepting another statutory retainership.
The 22 October 2026 SECP communication calls upon qualifying companies to furnish the particulars of appointed legal advisers on Form-9 to the Registrar under section 197 of the Companies Act, 2017. It warns of enforcement against noncompliant companies.
This is a reminder of the 2023 statutory appointment requirement, with a specific compliance and filing direction; the communication did not create section 10.
What affected companies should verify
Boards and company secretaries should examine the company's paid-up capital, verify a practising advocate's status, execute and retain appropriate retainership records, and make any outstanding Form-9 reporting under the applicable Companies Regulations and Companies Act provisions.
The Rs20 million amount is confirmed by the statutory text. Reports using an Rs200 million threshold should not be relied upon for this obligation. Any other duties under the 1974 legal-adviser legislation and regulations should also be checked independently.
What do the exact changes mean for affected organisations?
Companies above Rs20 million paid-up capital should confirm their statutory legal adviser is a practising advocate, falls within the three-entity limit and is correctly recorded through Form-9.
Specific compliance and response checklist
- Confirm paid-up capital exceeds Rs20 million and check the separately covered public-sector categories.
- Verify practising status and no more than three concurrent covered retainership appointments.
- Document the statutory retainer and company approval.
- File or reconcile the legal-adviser particulars with the Registrar using Form-9 under section 197.
Timing and legal status
Section 10 has applied since 2023; SECP compliance reminder issued 22 October 2026. No new threshold was introduced this week.
The statutory wording must control: Rs20m, not Rs200m. Verify current SECP Form-9 filing procedure and any applicable timelines under the governing rules.
Pakistan Code — Lawyers Welfare and Protection Act, 2023, section 10 (read with SECP's 22 October 2026 filing reminder)