Corporate Account Opening Requirements in Zambia: PACRA Printout, Beneficial Owners at 5% and TPIN

Short answer: For a Zambian company account, a bank checks a certified copy of the certificate of incorporation, reviews the TPIN against the PACRA Register of Companies, and verifies everyone who controls the company (SI 54 of 2022, reg 7(1)(b)). Since 30 December 2025, company law counts anyone holding at least 5% of shares as a beneficial owner, and banks must report register discrepancies to PACRA within 15 days.

This guide is for corporate onboarding, compliance and relationship teams at Zambian banks and microfinance institutions, and for savings and credit co-operatives (SACCOs) that admit companies and institutions as members. This is a practical guide, not legal advice; confirm requirements with your supervisor (the Bank of Zambia or the Financial Intelligence Centre) or adviser. Checked against primary sources on 9 October 2026.

Creodata makes BAOS, the account opening workflow for Zambian banks that sits beside your verification provider and core banking system. Near the end we say what it records and what stays with PACRA, ZRA and your other systems.

What does the law require for a company account?

The particulars come from the Financial Intelligence Centre Act, 2010 (Act No. 46 of 2010), s.16(4)(b): "the corporate name, head office address, identities of directors, proof of incorporation or similar evidence of legal status and legal form, provisions governing the authority to bind the legal person, and information that is necessary to understand the ownership and control".

SI 54 reg 7(1)(b) says how to verify them:

1. compare the details with "a certified true copy of its certificate of incorporation issued by the Registrar of Companies or another relevant authority";
2. review "the tax payer identification number issued by the Zambia Revenue Authority and other information contained in the Register of companies or other relevant register";
3. except for statutory bodies, verify the particulars of "every person exercising direct or indirect control", to identify the beneficial owner.

The Bank of Zambia's AML Directives 2017 add no CDD list. Update the file when signatories, shareholding or the board change (reg 7(7)).

Which PACRA documents should you ask for?

PACRA keeps the Register of Companies and the Register of Beneficial Owners (Companies Act 2017 s.21(1) and (2)). Three of its documents matter at onboarding:

PACRA's printout fees are K111.20 for a business name, K120.00 for a local company and K266.67 for a foreign company. Record the date you obtained it.

The registers are open to public inspection on payment of the prescribed fees (s.326(1)). Since 2025, access to BO information is open "where a legitimate interest exists as may be prescribed" (s.326(3)); we found no regulation prescribing it yet, and no PACRA BO search service built for banks. The 2025 National Risk Assessment says banks had access to BO information at PACRA, but many companies registered under the repealed Act had not disclosed their beneficial owners. Expect gaps.

Banks commonly ask for more: one Zambian bank's published checklist adds articles, PACRA forms, a share capital certificate, references, a board resolution with the signing mandate, a tax clearance certificate and a visitation report. That is bank practice, not law. For the general flow, see the corporate account opening process and KYB explained.

Who is a beneficial owner in Zambia?

Two laws give two definitions:

• FIC Act s.2: a natural person who "ultimately owns or controls the rights to or benefits from property", or "a person who exercises ultimate effective control over a legal person or legal arrangement". No percentage.
• Companies Act, as amended by Act No. 23 of 2025 (from 30 December 2025): a natural person who "(a) directly, or indirectly, holds at least five percent of a legal person's shares; (b) exercises ultimate effective control over a legal person; or" (c) has a substantial interest in, or receives substantial economic benefits from, the legal person.

SI 54 does not cross-refer to the Companies Act, and no rule says which definition a bank must apply. Applying both (anyone at 5% or more, plus anyone with ultimate effective control) matches the PACRA data and the FIC Act; confirm your choice with your supervisor.

The old 25% test is gone. It was in SI 9 of 2016, revoked in 2022, and in the Companies Act's "control" definition, replaced in 2025. If your forms or policy still say 25%, update them. (For Kenya, see our beneficial ownership guide.)

Nominees and bearer shares. Since 2025 the register of members must show a nominee's nominator (s.30(1)(b)), and new bearer shares are prohibited (s.142B). SI 54 treats "a company that has nominee shareholders or shares in bearer form" as a high-risk factor (Second Schedule Part II para 1(h)).

Must companies give you their beneficial-ownership information?

Yes. Section 124A(1)(c), inserted in 2025, requires a company to "provide adequate, accurate and up-to-date beneficial ownership information when establishing a business relationship or executing an occasional transaction with a reporting entity". If that information changes, it must "notify a reporting entity within fourteen days" (s.124A(2)). Failing to comply is an offence (s.124A(3)).

So cite s.124A on your BO declaration, and remind the customer of the 14-day duty to report changes.

Reporting a discrepancy to PACRA within 15 days

Section 329B(2): where a reporting entity "reasonably believes that there is a discrepancy" between the Register of Beneficial Owners and its own BO information, it "shall, within fifteen days of identifying the discrepancy, report the discrepancy to the Agency, in writing". "Reporting entity" has its FIC Act meaning, so banks are covered. PACRA then asks the company to clarify and may approach the person believed to be the beneficial owner (s.329B(3) to (5)).

So the PACRA comparison is a timed task. Record what the customer declared, what the printout showed, when you found the difference and when you wrote to PACRA.

Business names, partnerships, trusts, NGOs and co-operatives

For business names, bank checklists commonly add the BN Form III (sole trader) or BN Form II (firm), owners' IDs and a TPIN certificate.

TPIN for the business

Income Tax Act s.45B requires a TPIN for "Account opening and holding" at a "bank or financial institution". A TPIN is issued to "a corporate person or unincorporate body of persons" as well as to individuals aged 16 or over (s.2), and a partnership obtains its own (s.45(2)). The Bank of Zambia's CB Circular 05/2020 says new accounts without a TPIN "should not be opened", and corporate account holders must fully comply.

ZRA says a business registered with PACRA after 2020 gets its TPIN on PACRA registration. SI 54 asks you to "review" the TPIN with the Register of Companies information; no ZRA verification channel is prescribed. Our NRC and TPIN guide covers the rule in full.

Directors, signatories and people acting for the company

The law asks for the identities of directors (s.16(4)(b)) and proof of authority for anyone acting for the company: "a power-of-attorney, a service level agreement or other proof of that individual's authority to act" (reg 7(5)). Each such person, and every signatory, gets the individual checks (reg 7(2)). Banks commonly use a board resolution naming the signatories and the mandate. See authorised signatories and signing mandates, and our KYC requirements guide for Zambia for the individual checks.

Higher-risk companies and records

The SI 54 Second Schedule high-risk factors include non-resident customers, personal asset-holding vehicles, cash-intensive businesses and unusually complex ownership. So is a "prominent influential person", Zambia's term since 2020 in place of "politically exposed person". For high-risk customers, s.19(4) requires senior-management approval, reasonable measures to verify the source of wealth and funds, and closer monitoring. BoZ CB Circular 05/2026 adds due diligence at account opening for customers who appear to provide virtual-asset or stablecoin services.

Keep account files and identity documents for at least ten years after the relationship ends (FIC Act s.22(2)(a)).

Where BAOS fits

Whatever system you use, check that it gives you:

• one record for the entity, its directors, shareholders, beneficial owners and signatories, each with their own ID and documents;
• a BO declaration that captures holdings and control, so reviewers can apply both tests;
• the PACRA printout stored with the date it was obtained;
• a place to record a PACRA discrepancy, the date found and the date reported;
• document lists by entity type; and
• hosting that fits Zambia's data protection law.

BAOS is the account-opening workflow that sits beside your identity-verification provider and your core banking system. Its business form is published by default and covers fifteen entity types, from sole proprietorships, partnerships and limited companies to trusts, NGOs, societies and SACCOs. It records directors, shareholders and beneficial owners with their ID and shareholding, signatories and eight operating mandates, and a document checklist per person that staff verify. No Zambia template ships, so your team adds the Zambian documents (certificate of incorporation, Legal Entity Printout, BO declaration) in the no-code builder, and can add a staff-only section for the PACRA comparison. BAOS lists every person who needs screening once each; screening runs in your screening tool, such as Creodata's AML software for Zambia. See also corporate accounts in BAOS.

What BAOS does not do: it does not calculate ownership or apply the 5% test, query PACRA or ZRA, report discrepancies, rate risk or book the account. Reviewers approve or reject, then record the account number once the core banking system opens the account, and every workflow action is recorded with who, what role, when and from which address.

Hosting. The Data Protection Act 2021 requires a data controller to "process and store personal data on a server or data centre located in the Republic" (s.70(1)); sensitive personal data, including sex, marital status and biometric data, "shall be processed and stored" there too (s.70(3)), and s.71 sets the conditions for any transfer abroad (s.71(4)(b) allows sensitive data to move with explicit consent, which sits uneasily with s.70(3)). The Bank of Zambia requires prior approval for material outsourcing and for offshoring. BAOS has two deployment options: from Azure Marketplace into your own Azure subscription, in the Azure region you choose, or on-premises in your own data centre, installed and supported by Creodata. Azure has no region in East Africa (the nearest are South Africa North and South Africa West), so where your data must stay in Zambia, choose the on-premises deployment. The Enterprise AI features run on Azure AI services outside Zambia. See BAOS for Zambia or the BAOS product page for plans.

Frequently asked questions

What documents does a company need to open a bank account in Zambia?

By law: a certified certificate of incorporation, the TPIN, directors' identities, who can bind the company, and its ownership and control, including every person exercising direct or indirect control (FIC Act s.16(4)(b); SI 54 reg 7(1)(b)). Banks commonly add a board resolution and articles.

What is a PACRA Legal Entity Printout?

A PACRA document, from its website or the Government Service Bus, showing a company's registration details, directors, secretaries, shareholders and beneficial owners. It is valid only for the day it is obtained.

What is the beneficial-ownership threshold in Zambia?

Company law says at least 5% of shares, or ultimate effective control, or substantial interest or benefit (Companies Act, as amended from 30 December 2025). The FIC Act sets no percentage. No rule says which a bank must apply, so confirm your policy with your supervisor.

What if a company's BO information doesn't match PACRA's register?

Report the discrepancy to PACRA in writing within fifteen days of identifying it (Companies Act s.329B(2)). PACRA then follows up with the company.

Does BAOS check PACRA or ZRA?

No. BAOS records the entity, its owners, signatories and documents. PACRA and ZRA checks happen outside BAOS; staff record the review on the application.