# Financial Reporting Deadlines for a Malaysian Company

> Every statutory financial reporting deadline for a Malaysian company in one table, with the compound circulation-then-lodgement clock that most guides state only half of.

- Category: accounting
- Language: en
- Status: published
- Updated: 2026-07-20
- Canonical: https://negaraku.md/en/accounting/financial-reporting-deadlines

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Ask most Malaysian sources when financial statements are due and you will be
told one of two things: six months after year end, or seven months after year
end. Both are half-answers, and the half that gets omitted is the one that
causes the late filing.

The Companies Act 2016 sets **two clocks that run in sequence**. Section
258(1)(a) gives a private company six months from financial year end to
**circulate** the financial statements and reports to its members. Section
259(1)(a) then gives thirty days from **the date of that circulation** to
**lodge** them with the Registrar.

Thirty days from circulation. Not thirty days from the six-month mark.

The practical consequence runs the opposite way to intuition. Circulating in
month four does not buy you an extra two months to lodge — it starts your
lodgement clock two months early. The only way to reach the outer limit of
roughly seven months is to circulate on the last permitted day, which is
precisely the behaviour that leaves no margin if the auditor or the tagging
runs late.

## Every statutory reporting deadline

| Obligation | Clock | Runs from | Statute | Authority |
| --- | --- | --- | --- | --- |
| Prepare the first financial statements | 18 months | Date of incorporation | s.248(1)(a) CA 2016 | SSM |
| Prepare financial statements, every year after | 6 months | Financial year end | s.248(1)(b) CA 2016 | SSM |
| Enter a transaction in the accounting records | 60 days | Completion of the transaction | s.245(2) CA 2016 | SSM |
| Circulate financial statements — private company | 6 months | Financial year end | s.258(1)(a) CA 2016 | SSM |
| Circulate financial statements — public company | At least 21 days **before** | The date of the AGM | s.258(1)(b) CA 2016 | SSM |
| Hold the AGM — public company only | 6 months **and** 15 months | Financial year end, and the last AGM | s.340(1)(a) CA 2016 | SSM |
| Lodge financial statements — private company | 30 days | **Date of circulation** | s.259(1)(a) CA 2016 | SSM |
| Lodge financial statements — public company | 30 days | The AGM | s.259(1)(b) CA 2016 | SSM |
| Lodge an EPC certificate in lieu | 30 days | Date of circulation | s.260(1) CA 2016 | SSM |
| Lodge the annual return | 30 days | Anniversary of incorporation | s.68 CA 2016 | SSM |
| Retain accounting records | 7 years | Completion of the transaction | s.245(3) CA 2016 | SSM |
| File Form C | 7 months, plus one month e-Filing grace | Day following the close of the accounting period | s.77A(1) ITA 1967 | LHDN |
| Furnish CP204 | 30 days **before** | Start of the basis period | s.107C ITA 1967 | LHDN |

Two rows deserve a second look.

**The annual return does not move with your financial year end.** It runs from
the incorporation anniversary, and s.68(2) means none is due in the calendar
year the company was incorporated. Companies that redraw their compliance
calendar after a year end change routinely drag the annual return along with
it, which is wrong in both directions.

**Section 258(1)(b) is a backward-looking deadline.** For a public company the
circulation obligation is not a period after year end at all — it is at least
twenty-one days *before* the AGM. The six-month constraint sits in s.340, on
the meeting.

## The first financial year

Section 248(1)(a) requires the directors of every company to prepare financial
statements within **eighteen months from the date of incorporation**. This is a
preparation obligation, not a lodgement one — the s.258 and s.259 clocks then
run off whatever financial year end you selected inside that window.

A director who contravenes s.248 commits an offence carrying a fine up to
**RM500,000** or imprisonment up to **one year**, or both, under s.248(3). Note
where the liability sits: on the director personally, not on the company.

The eighteen-month allowance is not free. See
[your first financial year](/en/accounting/first-financial-year) for what a long
first period does to the audit exemption test.

## Extension of time, and the lead times that catch people

Section 259(2) lets the Registrar extend the period, but only **if the
application is made before the period expires**. Section 609(2) is the general
extension power for any lodgement, and s.340(4) covers the public company AGM.
Practice Note 3/2018 sets out how far in advance each application must arrive.

| Situation | Application must reach the Registrar | Source |
| --- | --- | --- |
| Private company, circulation cannot be made in time | At least **7 days** before the last day of the circulation period | PN 3/2018 para 13 |
| Private company, lodgement cannot be made in time | At least **7 days** before the last day of the lodgement period | PN 3/2018 para 14 |
| Any document where the prescribed lodgement period is 7 days or less | At least **3 days** before the end of the event | PN 3/2018 para 9 |
| A further extension of an already extended period | At least **7 days** before the last day of the extended period | PN 3/2018 para 8 |
| Public company, circulation or lodgement cannot be made in time | At least **30 days** before the last day to hold the AGM | PN 3/2018 paras 21–22 |

Each application costs **RM100**, and paragraph 16 makes clear that a second
application to extend an already extended period costs a further RM100. SSM
publishes no maximum extension length — paragraph 7 simply deems a document
lodged within the approved extended period to have been lodged in time.

The seven-day lead time is the trap. A company that discovers on the last day
of the six-month circulation period that the audit is not finished has already
missed the window to ask for more time.

## What lateness costs

Two separate consequences, and they are not alternatives.

**The administrative late lodgement penalty** sits in Practice Directive 1/2017
as revised on 1 October 2024, paragraph 17. It applies to any document lodged
after the prescribed timeframe, and the bands start only after seven days.

| How late | Private company | Public or foreign company |
| --- | --- | --- |
| More than 7 days, not more than 3 months | RM50 | RM150 |
| More than 3 months, not more than 6 months | RM100 | RM250 |
| More than 6 months, not more than 12 months | RM150 | RM300 |
| More than 12 months | RM200 | RM500 |

Paragraph 18 gives the Registrar a discretion to remit the penalty wholly or
partly where the omission was accidental or due to inadvertence, or where it is
just and equitable.

**The offence provisions** are a different order of magnitude.

| Section | Who is liable | Fine | Daily continuing fine |
| --- | --- | --- | --- |
| s.248(3) — failure to prepare | Any **director** | Up to RM500,000, or 1 year, or both | — |
| s.258(3) — failure to circulate | The company **and** every officer | Up to RM50,000 | Up to RM500 per day |
| s.259(3) — failure to lodge | **Every officer** | Up to RM50,000 | Up to RM1,000 per day |
| s.260(3) — EPC certificate | The company and every officer | Up to RM20,000 | Up to RM1,000 per day |

Two asymmetries worth noticing. Section 259(3) attaches to **every officer**
and does not name the company at all, while s.258(3) names both. And the daily
continuing fine under s.259 is **double** the one under s.258 — the Act treats
failing to file as worse than failing to circulate.

## Common mistakes

- **Reading the six months and the thirty days as one seven-month period.** They are sequential. Your lodgement deadline is a function of the date you actually circulated.
- **Circulating early to be safe.** It moves your lodgement deadline forward by exactly the same amount.
- **Applying for an extension on the deadline itself.** The application must arrive seven days before it, or thirty days before the AGM for a public company.
- **Assuming audit exemption removes the deadlines.** Paragraph 15 of PD 10/2024 keeps ss.258 and 259 in force for unaudited financial statements, with the certificate attached.
- **Rescheduling the annual return around the financial year end.** It runs off the incorporation anniversary under s.68.
- **Treating the PD 1/2017 penalty as the whole exposure.** RM200 is the administrative fee; s.259(3) is RM50,000 on every officer plus RM1,000 a day.
- **Forgetting that lodgement means an accepted MBRS filing.** A submission that is queried and returned has not been lodged, and the clock does not pause while you fix the tagging.

## What's next

Take last year's actual circulation date, not the deadline, and work forward
thirty days from it. That is the date your MBRS filing had to be accepted by.
If the gap between your typical audit sign-off and that date is under three
weeks, the extension application — seven days before the circulation deadline —
belongs in the calendar now rather than in the week it is needed.

## Sources

- Companies Act 2016 (Act 777), updated text as at 1 August 2022 — https://www.ssm.com.my/Pages/Legal_Framework/Document/Companies%20Act%202016_Akta%20777_BI%20(1.8.2022).pdf (SSM)
- Practice Directive No. 1/2017 (Revised 1 October 2024) — Documents under the Companies Act 2016, the Lodgement Requirements and Related Matters — https://www.ssm.com.my/Pages/Legal_Framework/Document/Practice%20Directive%201_2017%20(Revised)%201%20Oct%202024.pdf (SSM)
- Practice Note No. 3/2018 — Clarification on Application for Extension of Time under the Companies Act 2016 — https://www.ssm.com.my/Pages/Legal_Framework/PDF%20Tab%205/pn_ss_609_2592_3404_eot.pdf (SSM)
- Practice Directive No. 10/2024 — Qualifying Criteria for Audit Exemption for Certain Private Companies in Malaysia — https://www.ssm.com.my/Pages/Legal_Framework/Document/PD10-2024-Qualifying-Criteria-for-Audit-Exemption-for-Certain-Categories-of-Private-Companies.pdf (SSM)
- Income Tax Act 1967 (Act 53), reprint as at 21 May 2024 — https://www.hasil.gov.my/wp-content/uploads/20240521-akta-cukai-pendapatan-1967-akta-53.pdf (LHDN)

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