The Registrar of the Companies Commission of Malaysia (“Registrar”) issued the revised Guidelines relating to Practising Certificate for Secretaries under Section 241 of the Companie Act 2016 (“Revised Guidelines”) on 22 October 2025.
 
The Revised Guidelines supersede the guidelines of the same name issued on 1 August 2022. The Revised Guidelines took effect on 22 October 2025, with the exception of paragraph 39 (see below) which takes effect from 1 January 2026.
 
A summary of the new requirements under the Revised Guidelines are set out below.
 
Additional renewal condition
 
Paragraph 13(d) of the Revised Guidelines introduces a new condition for the renewal of a practising certificate (“PC”) that requires the applicant to have been appointed and named as a secretary in at least one company during the validity period of his PC prior to the submission of his application for renewal of his PC.
 
Additional requirements under the duty to act honestly and use reasonable diligence
 
Additional duties are imposed under the new paragraphs 28(f) and 28(g) of the Revised Guidelines in relation to a secretary’s obligation to act honestly and use reasonable diligence on discharging his duty as a secretary.
 
New paragraph 28(f) requires a secretary to perform verification on company documents before submitting them to the Companies Commission of Malaysia (“CCM”) to ensure accuracy, authenticity and compliance with the prescribed legal requirements.
 
New paragraph 28(g) requires a secretary to demonstrate professional conduct and ethics that uphold the integrity of the company secretarial profession, including diligence, responsibility, competence in performing professional duties, propriety in professional conduct and behaviour befitting a secretary.
 
Non-fulfilment of Continuing Professional Education Requirements before Renewal
 
New paragraph 36 of the Revised Guidelines provides that where a secretary’s previous practising certificate has expired without the Continuing Professional Education (“CPE”) requirements being fulfilled, the secretary must complete all outstanding CPE points before submitting a new application for a PC. Non-compliance with this requirement may result in the application being rejected.
 
Additional qualifying courses
 
New paragraph 37 of the Revised Guidelines clarifies that the trainings or courses specified in paragraphs 39, 40, 41 and 42 of the Revised Guidelines (see below) qualify to be counted as part of the required minimum CPE hours to be achieved during the validity period of a PC.¹
 
Mandatory training in relation to duty as a Reporting Institution
 
New paragraphs 39 and 40 of the Revised Guidelines set out the following requirements:
 
New paragraph 39 requires a secretary with a PC to complete a relevant training programme or course focusing on Anti-Money Laundering, Countering Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions organised by any approved bodies or regulatory authorities. The programme or course must specifically address the duties and responsibilities of secretaries in their capacity as reporting institutions under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001. This requirement takes effect from 1 January 2026.
 
New paragraph 40 stipulates that: (a) the training or course referred to in paragraph 39 must be completed within three years from 1 January 2026 or from the issuance of the first PC, whichever is later; and (b) a secretary who has attended such training or course within the two years preceding 1 January 2026 is exempted from this requirement.
 
Mandatory training in relation to Companies Limited by Guarantee
 
The new paragraphs 41 and 42 of the Revised Guidelines set out the following requirements:
 
New paragraph 41 requires a secretary acting as a secretary for a company limited by guarantee (“CLBG”) to comply with the training requirement specified in the CCM’s Guidelines on Company Limited By Guarantee.
 
New paragraph 42 stipulates that a secretary of a CLBG appointed after 1 January 2026 must complete the training or course on CLBG organised by CCM within one year from the date of his appointment.
 
Duties relating to PC
 
Three new requirements are introduced in relation to PCs under paragraphs 44 to 46 of the Revised Guidelines.
 
New paragraph 44 prohibits a secretary from allowing any other person to use his PC number to carry out transactions including online submissions or dealings on behalf of the secretary.
 
New paragraph 45 prohibits the PC from being transferred, assigned or used by any person other than the PC holder, under any circumstances.
 
New paragraph 46 states that a secretary who contravenes paragraphs 43², 44 or 45 of the Revised Guidelines shall be regarded as having breached the duties prescribed under the PC.
 
Other amendments
 
Apart from the above, the Revised Guidelines have been amended to refine the drafting of some provisions.
 
New Part R of FAQs
 
On 23 October 2025, the Registrar issued a new Part R of the FAQs on the Companies Act 2016 and Transitional Issues (“Part R”). Part R assists to clarify some of the provisions in the Revised Guidelines, in particular, FAQ Nos. 58 to 73 which provide clarification on the amendments to the Revised Guidelines that are highlighted above. Part R can be accessed here.
 
 
Article by Sarah Aida binti Mohammad Ali (Associate) of the Corporate Practice of Skrine.
 
 

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