Ask ten people how to register an NGO in Pakistan and you will get ten answers, most of them half right. The confusion is understandable. There is no single "NGO law" here. NGO is a description, not a legal form, and the law you register under decides who regulates you for years to come.
This note sets out the main routes, the regulator behind each one, and the extra layers that apply once you collect donations or receive money from abroad. We checked each point against the statute or the regulator's own material as of 11 October 2026.
Is there one law for NGOs in Pakistan?
No. You first choose a legal form, then you deal with the regulators that come with it. The four common forms are a society, a trust, a voluntary social welfare agency and a not-for-profit company. On top of that sit the provincial charity laws, the income tax rules and, if the money comes from abroad, federal approvals.
Route 1: a society under the Societies Registration Act, 1860
A group of people sign a memorandum of association and rules, and register the society with the provincial Registrar of Societies. It is the oldest route, cheap and familiar to banks and donors. The catch is that the 1860 Act gives the Registrar very few powers over what a society does after registration, which is exactly why the newer charity laws now sit on top of it.
You need at least seven people to sign the memorandum. In Punjab the Registrar also asks for attested CNIC copies of the members and office bearers, an affidavit that no dispute or case is pending against the proposed society and that it is not registered anywhere else, and three copies of the memorandum and rules. A mosque or madrasa needs proof that it owns the land.
Route 2: a trust under the Trusts Acts of 2020
A trust is created by a trust deed, where a settlor hands property to trustees to hold for a stated purpose. In 2020 Islamabad and each of the four provinces passed their own Trusts Act, with a stricter registration and monitoring regime than the old Trusts Act, 1882 ever had. A trust suits a founder or a family who want control to stay with a small group of trustees, since there is no general body of members to answer to.
Take Punjab. Section 15 of the Punjab Trusts Act, 2020 says no trust can function unless it is registered with the Director of Land Records. The trustee applies through the Assistant Commissioner with details of the author, the trustees, the beneficiaries and anyone else who exercises ultimate control, and the Director has the application verified by investigating agencies before issuing a certificate. Trusts registered under the old 1882 Act had to register again under the new law within six months.
Route 3: a voluntary social welfare agency
Organisations doing social welfare work can register with the provincial Social Welfare Department under the Voluntary Social Welfare Agencies (Registration and Control) Ordinance, 1961. This route is common for community and welfare work at the local level.
In Punjab the whole process now runs online through the Department's portal under its revised procedures of 2022. You file the model constitution, lists of the executive and general body members with their CNIC numbers, a plan of action, minutes of the founders' meeting signed by three quarters of them, and affidavits that the NGO has no link with any proscribed person or sectarian group and will open a joint bank account within a month of registration. An area officer and the Deputy Director visit and report on the NGO, and the Home Department issues a no objection certificate only after checks by the Special Branch and the Counter Terrorism Department. Once registered, the Department itself tells the NGO to register with the Punjab Charity Commission as well.
Route 4: a not-for-profit company under section 42
This is the most formal option. Under section 42 of the Companies Act, 2017, the SECP may license an association to register as a public company without the word "Limited" in its name if:
- its objects are useful ones, such as commerce, art, science, religion, health, education, research, sports, the environment, social welfare or charity;
- it applies its profits and income only to those objects and prohibits paying dividends to members; and
- its objects and activities are not against the law, public order, security or national interest of Pakistan.
The licence is granted "for a period to be specified" and can carry conditions, which become part of the memorandum and articles. The memorandum and articles follow Table F of the First Schedule. The detailed rules are in Chapter VII of the Companies Regulations, 2024, from regulation 97 onwards. You apply on form App-3 through an authorised promoter, with at least three promoters and at least one of them experienced in each object you list. Each promoter undertakes a start-up donation of at least Rs 200,000, and the directors and chief executive must meet the SECP's fit and proper criteria. Once the licence is granted, you have 60 days to apply for incorporation. The company must then show the words "A company set up under section 42 of the Companies Act, 2017" on its letterheads and signboards, and close its accounts on 30 June each year. If the company is large enough to count as a public interest company, regulation 53 also requires at least one woman director with at least a bachelor's degree.
Keep an eye on the revocation grounds in section 42(5). The SECP can revoke the licence if, among other things, the company fails to file its financial statements or annual returns for two years in a row, its members fall below three, or it is run by people involved in terrorist financing or money laundering. A section 42 company carries the most paperwork, but banks, donors and foreign partners tend to trust it the most.
Do you also need to register as a charity?
In most places, yes, and this is the step people forget. Registering a society or a trust gives you a legal form. It does not give you permission to collect public donations.
In Punjab, the Punjab Charities Act, 2018 defines "charity" widely enough to cover societies, social welfare agencies, companies and public or private trusts set up for a charitable purpose. Under section 12, every charity must register with the Punjab Charity Commission, and it cannot collect or seek charitable funds until it does. The registering authority depends on how far the work reaches: the Commission for the whole province or two or more districts, the Deputy Commissioner for one district, and the Assistant Commissioner for one tehsil. Applications are made online, and the Act replaced the old Charitable Funds (Regulation of Collections) Act, 1953.
Some other points worth knowing:
- If a charity receives more than Rs 50,000 in a calendar month, the money must go into a dedicated bank account (section 28(6)).
- Funds cannot be used for any purpose other than the one they were collected for without the Commission's prior permission (section 31).
- The Commission can suspend or cancel registration and impose a fine of up to Rs 1 million (section 24).
- Breaking the Act is an offence punishable with imprisonment of 15 days to six months and a fine of Rs 25,000 to Rs 100,000, and the offence is cognizable and non-bailable (sections 32 and 33).
Islamabad has its own regime under the Islamabad Capital Territory Charities Registration, Regulation and Facilitation Act, 2021, which also makes registration compulsory, and the other provinces have charity laws of their own. Check the one where you will actually operate.
What if the money comes from abroad?
Foreign money brings a federal layer. A local NGO that receives foreign contributions comes under the Economic Affairs Division's policy for local NGOs and NPOs receiving foreign contributions, approved in 2022. The NGO applies through EAD's online portal for a memorandum of understanding at least 60 days before the foreign-funded project starts, and the MoU is signed after security clearance. International NGOs are a separate track altogether: they register with the Ministry of Interior under the INGO policy and sign their own MoU.
In short, if a foreign donor is in the picture, build these approvals into your timeline from day one. Projects stall more often on this step than on any other.
How does tax work for an NGO?
Registration does not make an organisation tax exempt by itself. Under section 2(36) of the Income Tax Ordinance, 2001, a "non-profit organization" must be set up for religious, educational, charitable or welfare purposes for the general public, or to promote an amateur sport, must be formed and registered under a law as a non-profit organisation, and must be approved by the Commissioner for a specified period on an application. None of its assets may confer a private benefit on anyone.
That approval matters on both sides of a donation. An approved organisation can claim the tax credit for charitable organisations under section 100C, and donors can claim a tax credit for donations under section 61. Donors increasingly ask for this before they write a cheque.
Which route should you choose?
- A small local welfare effort: a society or a social welfare agency, plus charity registration.
- A family or founder-led foundation: a trust, plus charity registration if you will collect from the public.
- Larger programmes, corporate donors or foreign partners: a section 42 company, with EAD approval for any foreign funding.
Whatever you pick, plan for three layers rather than one: the legal form, the charity registration and the tax approval. Get the order right and the rest falls into place. If you would like help choosing a route or preparing the papers, book a consultation with our corporate team.
Sources
- Companies Act, 2017, section 42 (MGS Juris law library)
- SECP: Licence under section 42 of the Companies Act, 2017
- The Punjab Charities Act, 2018 (Government of the Punjab)
- SECP: Companies Regulations, 2024 (Chapter VII, regulations 97 to 101)
- The Punjab Trusts Act, 2020 (text)
- Social Welfare and Bait-ul-Maal Department, Punjab: revised SOPs for NGO registration, 2022
- ICT Charities Registration, Regulation and Facilitation Act, 2021 (National Assembly)
- EAD policy for local NGOs/NPOs receiving foreign contributions, 2022 (ICNL copy)
- Income Tax Ordinance, 2001, sections 2(36), 61 and 100C (FBR)
Information as of 11 October 2026, checked against the statutes and regulator material listed above. Charity and trust laws differ by province and are amended from time to time, the Punjab figures are as enacted in 2018, and references to the Companies Regulations, 2024 are to the text notified in February 2024, which the SECP has amended since. This note is general information and is not legal advice.
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