Guide
SBCA Regularisation: Can Unapproved Floors Be Legalised in Karachi?
By Maham Imtiaz
Real Estate AnalystVerified author
9 min read
When a Karachi building turns out to be bigger than its approved plan, the first thing builders and buyers ask is whether it can be "regularised": made legal after the fact by paying a fee. Sometimes it can. Far more often, especially when the problem is extra floors, it cannot, and a buyer who paid on the promise of regularisation is left holding a unit the law does not recognise.
Regularisation is a building-layer question that decides the title layer. Our guide on how to verify property in Karachi explains that a unit cannot be registered without SBCA's completion plan, and regularisation is the only route by which a deviating building can still get one.
This guide explains what regularisation means under Sindh law, which deviations can be compounded and which cannot, how past amnesty schemes worked, what the courts and the July 2026 Federal Constitutional Court ruling have said, and what buyers should do when a builder promises that everything "will be regularised".
What regularisation means
Regularisation, called compounding in the Sindh Building Control Ordinance, lets SBCA accept certain deviations from an approved plan on payment of a fee, so that the building can receive a completion plan.
| Term | Meaning |
|---|---|
| Deviation | Any difference between the building and its approved plan |
| Compounding | Settling an offence by paying a fee instead of facing prosecution or demolition |
| Regularisation | Recognising a deviating building as approved after compounding |
| Amnesty scheme | A one-time, time-limited window to regularise past violations, set by special law or policy |
What the Ordinance allows
Section 19(1-C) of the Sindh Building Control Ordinance sets the main limit.
| Deviation | Can it be compounded? | Condition |
|---|---|---|
| Excess footprint | Yes | Up to 20% of permissible limits |
| Encroachment on compulsory open spaces | Yes | Up to 20% of permissible limits |
| Excess covered area | Yes | Up to 20% of permissible limits |
| Projections | Yes | Up to 20% of permissible limits |
| Deviations beyond 20% | No | Alteration or demolition |
| Violation of a master plan or site development scheme | No | Section 7-E bars compounding |
| Works violating regulations under section 21-A | No | Section 19(1-A) bars compounding |
Where compounding is allowed, the fee is the existing composition fee enhanced by 400%, plus other applicable fees. In effect, the owner pays five times the ordinary composition fee.
Extra floors: the hardest case
Extra floors are usually the deviation buyers care most about, and they are the least likely to be regularised.
| Situation | Typical outcome |
|---|---|
| Extra floor beyond the permitted number of storeys | Not regularisable; alteration or demolition |
| Extra floor that pushes covered area more than 20% over the limit | Not regularisable under section 19(1-C) |
| Building approved under the 1979 regulations | KBTPR 2002 Clause 3-2.20(d) generally bars further regularisation, additions or extra floors, with limited exceptions |
| Addition still within the permitted floor area ratio | Can be treated as an alteration and approved, not regularised |
In a 2023 case involving a residential building in a Karachi housing society, SBCA told the Sindh High Court that the second, third and fourth floors, built without approval, could not be regularised under the 2002 regulations. The court ordered them demolished and the occupants removed, with the cost on the builder.
The difference between regularisation and alteration matters. In C.P. No. D-1320 of 2023, decided in March 2024, the Sindh High Court held that an educational institution's request to add floor area that stayed within its permitted floor area ratio was an alteration, not a regularisation, and directed SBCA to decide it on that basis. The same order quoted the KBTPR clause barring regularisation and extra floors for buildings approved under the 1979 regulations.
Past amnesty schemes
Sindh has used one-time amnesties to regularise large numbers of violations.
| Scheme | What it did | Example |
|---|---|---|
| 2001-02 regularisation under the 2001 amendment ordinance | Allowed past violations to be regularised for a fee | Gul Plaza's approved count rose from 1,043 shops to 1,102, with a regularisation certificate issued in April 2003 |
| Later amnesty used in 2015 | Completion certificates issued for buildings exceeding their approved area | A Karachi institution's covered area recognised at 84,443.62 square feet against 70,371.585 approved |
| 2021 draft regularisation commission ordinance | Proposed a commission headed by a retired judge to regularise buildings where demolition would cause hardship | Drafted after the Nasla Tower demolition order; not reported as enacted |
Amnesties fix the past, not the future. Gul Plaza shows the risk: after regularisation in 2003, the building kept growing to 1,153 shops, with no further SBCA inspection before the fatal fire in January 2026.
What changed in 2025 and 2026
| Development | Effect on regularisation |
|---|---|
| Draft Sindh Building Control Authority Act 2025 | Proposed making offences non-compoundable, with up to five years' imprisonment and fines up to Rs5 million; not yet passed |
| February 2026 reform framework | Stricter enforcement, drone surveillance and a task force against illegal construction |
| July 2026 Federal Constitutional Court ruling | Recalled the Supreme Court's citywide demolition orders but stressed that any conversion, regularisation or legalisation must follow KBTPR 2002 and the SBCO 1979 |
The FCC ruling is sometimes described as relief for illegal buildings. It is not a regularisation scheme. It removed blanket court directions, but each building's status must still be decided under the existing law, which keeps the 20% limit and the bar on master plan violations.
What buyers should do when told "it will be regularised"
- Ask what exactly deviates. Get the approved plan and compare floors, covered area and open spaces.
- Ask SBCA whether the deviation is compoundable under section 19(1-C), and get the answer in writing.
- Check the percentage. A deviation over 20% of permissible limits, or extra storeys beyond the permitted number, generally cannot be regularised.
- Check the regulations the building was approved under. Buildings approved under the 1979 regulations face extra restrictions.
- Do not pay for an unregularised unit on the promise of a future amnesty. No amnesty is in force.
- Make the builder responsible in writing for regularisation costs and for refunds if regularisation fails.
- Wait for the completion plan before final payment or registration.
Our guide to the SBCA completion certificate explains why registration depends on it.
What the numbers show: Milkiyat.com findings
Compounding costs five times the normal fee. The base fee enhanced by 400% means paying 1 + 4 = 5 times the ordinary composition fee.
An amnesty recognised a 20% increase almost exactly. In the 2024 case, the approved covered area of 70,371.585 square feet became 84,443.62 square feet under the 2015 amnesty: 84,443.62 ÷ 70,371.585 = 1.19997, an increase of about 20.0%.
Gul Plaza's regularisation added 5.7%, and the building kept growing. From 1,043 to 1,102 shops is 59 more, about 5.7%. Another 51 shops followed after regularisation, for a total of 1,153.
The draft 2025 law would raise the maximum fine at least a hundredfold. The current minimum fine is Rs50,000; the draft proposes up to Rs5,000,000: 5,000,000 ÷ 50,000 = 100 times, and imprisonment of up to five years instead of three.
Three unapproved floors were held unregularisable in one 2023 case. The second, third and fourth floors of the housing society building were all ordered demolished.
Extra floors are also a safety issue, not just a legal one. Our review of Karachi building collapses and their approval records shows how often unapproved floors appear in the city's deadliest collapses.
Checklist before you pay
| Check | Where |
|---|---|
| Approved plan and the regulations it was approved under | SBCA |
| Exact deviations and their percentage | Plan compared with the building |
| Whether the deviation is compoundable | SBCA, in writing |
| Regularisation already completed, with certificate | SBCA |
| Completion plan issued | SBCA |
| Builder's written undertaking on costs and refunds | Your agreement |
Frequently asked questions
Q1. Can unapproved floors be regularised in Karachi?
A. Usually not. Section 19(1-C) allows compounding only for footprint, open space, covered area and projection deviations within 20% of permissible limits. Extra storeys beyond the permitted number generally require alteration or demolition.
Q2. How much does regularisation cost?
A. Where allowed, the existing composition fee enhanced by 400%, plus other fees, which is five times the ordinary composition fee.
Q3. Is there an amnesty scheme in Karachi now?
A. No general amnesty is in force. Past schemes ran in 2001-02 and later, and a 2021 draft regularisation commission ordinance was not reported as enacted.
Q4. Did the July 2026 FCC ruling legalise illegal buildings?
A. No. It recalled the Supreme Court's citywide orders but said conversion, regularisation or legalisation must follow KBTPR 2002 and the SBCO 1979.
Q5. What is the difference between regularisation and alteration?
A. Regularisation accepts a deviation already built. An alteration is a new approved change within the permitted limits. The Sindh High Court treated an addition within the permitted floor area ratio as an alteration in 2024.
Q6. Can master plan violations be regularised?
A. No. Section 7-E of the Ordinance bars compounding of violations of a master plan or sanctioned site development scheme.
Q7. Should I buy a flat the builder says will be regularised?
A. Not until SBCA confirms in writing that the deviation is compoundable and the regularisation and completion plan are actually issued.
This guide is for general information. Regularisation rules, amnesty policies and court interpretations change, and buyers should confirm the status of any building directly with SBCA and a qualified lawyer before paying.