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In brief

We refer to our previous client alert on the implementation of the beneficial ownership reporting obligations, administered by the Companies Commission of Malaysia (“CCM“), which came into effect on 1 April 2024. These statutory and reporting requirements imposed the obligation on companies to notify the CCM of their beneficial owners via the dedicated e-BOS portal. The CCM provided a transition period of three months (from 1 April 2024 to 30 June 2024) for companies to complete this reporting obligation.

The CCM has recently announced the extension of the transition period by a further three months ending 30 September 2024 (“Extended Transition Period“). This is to provide companies additional time to comply with the beneficial ownership reporting obligation.

Key takeaways

Please refer to the revised Practice Directive 9/2024 issued by the CCM here.

Once the Extended Transition Period ends, companies have a continuous obligation to properly maintain the register of beneficial owners (“RBO“) and ensure that the RBO is up-to-date. This would entail companies sending out yearly notices to seek confirmation of the beneficial owners and record any changes to the particulars of the beneficial owners. Looking ahead, we anticipate that the format of the annual return will be revised to include the particulars of the beneficial owners, enabling the annual return to be lodged with the CCM together with the beneficial ownership information at the same time.

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Andre heads the Corporate, Commercial & Securities and Competition Practice Group of Wong & Partners, and the regional mergers & acquisitions (M&A) practice of Baker McKenzie's Asian offices. His practice covers mergers and acquisitions, corporate securities, venture capital and private equity, and competition.
Andre is recognised in the leading legal directories including Chambers and Legal 500, and has published numerous articles in leading business publications in relation to corporate and competition law. He has also worked in the Singapore and London offices of Baker & McKenzie International.


Poh Seng Lim is the General Manager in B&M Consultancy Services, Kuala Lumpur office.

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