Audit Fees in Malaysia: There Is No Official Fee Schedule

Search for Malaysian audit fees and you will be shown a coefficient table: 1.000% on the first RM100,000, 0.438% on the next RM150,000, tapering down, with an RM800 floor for a dormant company. It is presented as the MIA schedule, sometimes as the minimum permitted fee.

It was withdrawn on 1 June 2015.

The withdrawal, confirmed

MIA still hosts the document. Open its own copy of Recommended Practice Guide 7 (Revised) — A Guide to Charging for Professional Assurance Services and the first line of the cover page reads:

[WITHDRAWN WITH EFFECT FROM 1 JUNE 2015]

MIA’s listing page for the earlier 2007 edition carries the same treatment, titling it RPG 7 — Fees and Commission (Withdrawn).

So the date is not practitioner folklore; it is on the face of the primary document.

The reason is a different matter. Practitioners consistently report that the Council withdrew RPG 7 to avoid contravening the Competition Act 2010, on the view that a recommended fee scale could be characterised as price fixing. That is plausible and universally repeated, but no MIA circular or Council resolution stating it could be retrieved from an official source. This page treats the withdrawal date as confirmed and the rationale as reported.

What the withdrawn guide actually contained

Worth knowing, because it is what gets republished.

RPG 7 (Revised) came into effect 1 March 2010, replacing a 2007 edition. It set out two bases for computing a fee, time-based and value-based, and then — because practitioners struggled to negotiate on value — offered a coefficient percentage table applied to gross turnover or total assets, with a separate table for total operating expenditure where the first two produced extremes.

Band of gross turnover or total assets	Coefficient
First RM100,000	1.000%
Next RM150,000	0.438%
Next RM250,000	0.313%
Next RM500,000	0.188%
Next RM1,500,000	0.125%
Next RM2,500,000	0.100%
Next RM5,000,000	0.094%
RM10,000,000 to RM20,000,000	RM1,000 for every RM1,000,000 increase or fraction
Above RM20,000,000	Negotiable, but not less than RM20,000 per assignment

Paragraph 4.4.1 added that a fee below RM800 for audit services should be considered unrealistically low — the origin of the dormant-company figure.

This table is reproduced here only so you can recognise it and stop using it. It has no force. And note paragraph 4.3.3(D)(i) of the guide itself: the recommended levels applied to statutory audits of companies registered under the Companies Act 1965 — an Act repealed on 31 January 2017. Even the framework the table was written for is gone.

What governs fees today

Section 330 of the MIA By-Laws (On Professional Ethics, Conduct and Practice), updated 5 November 2024, and nothing else.

330.3 A2 — a professional accountant might quote whatever fee is considered appropriate. Quoting a fee lower than another accountant is not in itself unethical. But the level of fees creates a self-interest threat to the principle of professional competence and due care if the fee quoted is so low that it might be difficult to perform the engagement in accordance with applicable technical and professional standards.

330.3 A2 MY, the Malaysian addition, requires fees charged for all engagements to be a fair reflection of the value of the work involved, taking into account:

• the skill and knowledge required for the type of work
• the level of training and experience of the persons necessarily engaged
• the time necessarily occupied by each person engaged
• the degree of responsibility and urgency the work entails

That is the whole of the current position. It sets a floor of professional competence, not a floor in ringgit.

What actually moves a quotation

Driver	Why it costs hours
Group consolidation	A second reporting layer, component work, elimination testing, ISA 600 (Revised) applies to periods beginning on or after 15 December 2023
Inventory	Physical count attendance is a required procedure where inventory is material; travel and multiple locations multiply it
First-year engagement	Opening balances must be audited separately, and predecessor working papers may not be available
Record quality	An unreconciled ledger converts audit hours into bookkeeping hours at audit rates
Related parties	Identifying and disclosing them to MFRS 124 is one of the most common causes of late adjustments
Foreign currency, revenue recognition, estimates	Judgement areas draw partner and manager time, not junior time
Quality management	ISQM 1 and ISA 220 (Revised) have applied since 15 December 2022, adding engagement-level monitoring and, on some files, an engagement quality review
Deadline compression	Work squeezed against the s.258 six-month circulation deadline is priced for overtime

Two things are usually not in the audit fee, and are worth confirming before comparing quotes: preparation of the financial statements themselves, and XBRL conversion and lodgement through MBRS. If one firm bundles them and another does not, the quotations are not comparable.

An observed market range — observed, not official

Read this first. No authority publishes an audit fee schedule in Malaysia. The ranges below are observations of what small and mid-sized Malaysian firms quote, offered so you can tell an outlier from a normal quote. They are not a benchmark, not a recommendation, and not endorsed by MIA, SSM or anyone else. A quotation outside these ranges is not wrong. Do not cite these figures as a standard, and do not use them to argue a fee down.

Company profile	Observed range for a statutory audit
Dormant, no transactions	RM800 – RM1,800
Micro trading or services company, turnover below RM500,000	RM1,500 – RM3,500
Small company, turnover RM1m – RM5m, single entity	RM3,000 – RM9,000
Mid-market, turnover RM5m – RM25m, inventory or multiple revenue streams	RM8,000 – RM30,000
Small group with consolidation	Parent fee plus a component fee per subsidiary, commonly RM3,000 upward each

Anything materially below the bottom of a band should prompt a question about scope rather than gratitude. Under 330.3 A2 the firm quoting it carries a self-interest threat it has to address, and the safeguards listed are adjusting the fee, adjusting the scope, or adding a reviewer — two of which cost you something later.

Common mistakes

• Citing the coefficient table as current. It has been withdrawn since 1 June 2015 and was written for a repealed Act.
• Treating RM800 as a legal minimum. It was guidance in a withdrawn document.
• Assuming MIA will arbitrate a fee dispute. Fees are a commercial matter between the firm and the client; the By-Laws set ethical boundaries, not prices.
• Comparing quotations that include different work. Ask explicitly whether preparation of the financial statements and MBRS lodgement are inside the fee.
• Choosing on price where the records are weak. The cheap quote is priced on the assumption of a clean trial balance, and the variation order arrives in month two.
• Forgetting who fixes the fee. Under s.274 of the Companies Act 2016 the power sits with whoever appointed the auditor — the members, the Board or the Registrar.

What’s next

The fee follows the work, so the useful next question is what the work actually is — the sequence of an engagement from acceptance through to the signed report.