Companies Commission of Malaysia issues Revised Practice Directive No. 1/2017 and Revised Practice Note No. 5/2019
26 August 2026
The Companies Commission of Malaysia (“
SSM”) issued a
revised Practice Directive No. 1/2017 (“
Revised PD No. 1/2017”) and a
revised Practice Note No. 5/2019 (“
Revised PN No. 5/2019”) on 14 July 2026.
The Revised PD No. 1/2017 supersedes the revised Practice Directive No. 1/2017 dated 1 October 2024 (“
Superseded PD”) whilst the Revised PN No. 5/2019 supersedes Practice Note No. 5/2019 dated 17 July 2019 (“
Superseded PN”).
This article provides a summary of the main requirements under Revised PD No 1/2017 and Revised PN No. 5/2019.
REVISED PD NO. 1/2017
Objectives
The Revised PD No. 1/2017 specifies the documents referred to in the Companies Act 2016 (“
CA 2016”) for purposes of lodgement with the Registrar of Companies (“
Registrar”) and to determine the general requirements for the lodgement of the documents and related matters.
General requirements relating to the lodgement of documents
As a general rule, regulation 3 of the Companies Regulations 2017 (“
Companies Regulations”) requires all documents that are to be lodged with the Registrar under the CA 2016 and all applications for matters specified in the Schedule to the Companies Regulations to be lodged or made, as the case may be, through the electronic filing system unless otherwise directed by the Registrar.
Lodgement of documents through the SSM electronic services
The SSM electronic services consist of the following:
- Corporate Registry System (“CRS”);
- Electronic Beneficial Ownership System (e-BOS);
- Malaysian Business Reporting System (MBRS); or
- Any other electronic services determined by the Registrar.
With effect from 14 July 2026, all corporate filings, statutory lodgements, incorporation application, notifications and other submissions to the Registrar shall be made through the CRS.
All persons responsible for corporate compliance shall ensure that documents are submitted in accordance with the requirements, procedures and timelines prescribed by the Registrar under the CA 2016 and any subsidiary legislation, practice notes, practice directives, guidelines or circulars issued under the CA 2016.
Existing Practice Notes, Practice Directives, Guidelines, Notifications, Circulars and related Forms shall remain applicable save that over the counter (“OTC”) lodgements or submissions shall be made online through the SSM’s electronic services.
Notwithstanding the foregoing, OTC lodgements and submissions shall only be permitted in the following circumstances:
- where the electronic services is wholly or partially unavailable or inaccessible;
- where the relevant statutory forms under the Companies Act 1965 (the predecessor to the CA 2016) are not supported by and cannot be lodged electronically through the electronic services; or
- upon notification by the Registrar.
Payment of fees
The fees payable on the lodgement of a document as specified in the Companies Regulations must be paid at the time of lodgement, unless otherwise directed by the Registrar. Where a fee is payable in respect of any matter involving the doing of any act or thing by the Minister or the Registrar, the Minister or Registrar is precluded from doing that act or thing until the fee has been paid.
Late lodgement penalty
Unless an application for an extension of time has been approved, documents to be lodged with the Registrar shall comply with the timeframe stipulated in the CA 2016. If a timeframe is not stipulated, a document must be lodged within 30 days from the time the requirement to lodge the document arises.
If a document is lodged later than the prescribed timeframe, late lodgement fees shall be payable as follows:
| Where the lodger is a public company or foreign company |
| Period of delay |
Penalty |
| More than 7 days but not more than 90 days |
RM150 |
| More than 90 days but not more than 180 days |
RM250 |
| More than 180 days but not more than 365 days |
RM300 |
| More than 365 days |
RM500 |
| Where the lodger is a private company |
| Period of delay |
Penalty |
| More than 7 days but not more than 90 days |
RM50 |
| More than 90 days but not more than 180 days |
RM100 |
| More than 180 days but not more than 365 days |
RM150 |
| More than 365 days |
RM200 |
The Registrar may remit in whole or part the late lodgement fee if he is satisfied that the omission to lodge the document within the time limit was accidental or due to inadvertence, or that it is just and equitable to do so.
Documents to be kept at the registered office
Unless otherwise directed, the completed or executed copies of the documents listed in
Schedule C on the SSM website (
www.ssm.com.my) are not required to be lodged with the Registrar but must be kept at the company’s registered office.
Amendments to documents under the Revised PD No 1/2017
The Registrar may, from time to time, amend or replace any documents or introduce new documents under the Revised PD No. 1/2017.
REVISED PN NO. 5/2019
Objectives
The Revised PN No. 5/2019 addresses matters relating to queries issued on documents and applications lodged or registered with the Registrar under the CA 2016 and sets out the procedures to be complied with where a company fails to respond to the Registrar’s queries.
Procedure on queries issued by the Registrar
The Registrar will issue a query on a document or application lodged by a company which is not in compliance with the requirements of the CA 2016.
Notification of the query will be sent via email to the lodger through the CRS. As such, it is critical for lodgers to ensure that their email addresses as notified to SSM are accurate and updated.
The procedures for query on all lodged documents and applications are as follows:
- a document or application which does not comply with the requirements set out under regulation 9 of the Companies Regulations and Revised Practice Directive No. 1/2017 will not be accepted for registration;
- a document or application which does not comply with section 610 of the CA 2016 will be queried;
- if the query is not answered within 30 days or the time frame specified in the notice, the document or application will be rejected. The lodger should contact the respective SSM’s officer if they require any further information and/ or clarification in respect of the query issued by the Registrar;
- a fresh document or application with a new submission date will have to be lodged together with the relevant fee, where applicable;
- where the initial date of submission of document is beyond the timeframe provided under the relevant provision of the CA 2016, late lodgement fee shall be payable.
The procedures for query set out above shall not apply to:
- applications or lodgements of documents relating to winding-up and management of assets of dissolved companies under Part IV of the CA 2016; and
- corporate rescue mechanism under Division 8 Part III of the CA 2016.
Comments
The most significant change under the Revised PD No. 1/2017 is to set out the procedures for electronic lodgements and submissions under the CRS which has replaced OTC submissions since 14 July 2026. Transitional provisions and requirements relating to the format and contents of hardcopy documents to be lodged OTC under the Superseded PD that are no longer applicable have been removed from the Revised PD No. 1/2017.
The Revised PN No. 5/2019 has been updated to remove transitional provisions in the Superseded PN that are no longer applicable. The list of exceptions to the procedures for queries has been reduced and the procedures have been extended to applications or documents relating to charges under Division 7 Subdivision 1 Part III and receivership under Division 7 Subdivision 3 Part III of the CA 2016 (see paragraph 11 of the Superseded PN).
Article by Siti Ayenaa Binti Mohd Anis (Associate) and Sarah Aida binti Mohammad Ali (Associate) of the Corporate Practice of Skrine.
This article/alert contains general information only. It does not constitute legal advice nor an expression of legal opinion and should not be relied upon as such. For further information, kindly contact skrine@skrine.com.