# Keeping the Register of Beneficial Owners (s.60B)

> The internal register every Malaysian company must keep at its registered office — what goes in it, when entries are due, how long records are kept, and who may inspect it.

- Category: company-secretary
- Language: en
- Status: published
- Updated: 2026-07-20
- Canonical: https://negaraku.md/en/company-secretary/bo-register

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Ask a Malaysian company secretary to produce the register of beneficial owners
and a good number will produce an e-BOS submission receipt. That is not the
register. It is evidence that a different obligation was performed.

Section 60B creates a record the company keeps itself, at its own premises,
with its own supporting file, on its own clock. SSM never sees most of it.
Competent authorities and law enforcement agencies do — and they see it on
demand.

## Where the register lives

Section 60B(2) requires the register of beneficial owners to be kept at the
registered office of the company, or at any other place in Malaysia notified to
the Registrar. Where the company keeps it elsewhere, the notification is made
under s.47(2).

The Companies (Amendment) Act 2024 also inserted paragraph 68(3)(ib), which
will require the annual return to state the address at which the register is
kept where that is not the registered office.

The register may be kept in physical or electronic form, in Malay or English.
Whatever form is chosen, the test SSM applies is functional: competent
authorities and law enforcement agencies must be able to access it **in a timely
manner** when required, and the company must be able to supply copies on
request.

## What goes into it

Section 60B(1) sets the statutory minimum. For each beneficial owner:

- Full name, addresses, nationality, identification and usual place of residence
- The date the person became a beneficial owner
- The date the person ceased to be a beneficial owner
- Such other information as the Registrar may require

“Identification” is defined in s.60B(10): for a person holding an identity card
issued under the National Registration Act 1959, the identity card number;
otherwise passport particulars or similar available evidence.

The Registrar has required considerably more. The Guidelines list thirteen
particulars to be obtained:

| | Particular |
| --- | --- |
| 1 | Full name |
| 2 | Address of usual place of residence |
| 3 | Business address, if any |
| 4 | Email address, if any |
| 5 | Nationality |
| 6 | Date of birth |
| 7 | Race |
| 8 | Gender |
| 9 | NRIC or passport number |
| 10 | Position in the company, if applicable |
| 11 | Type and criteria of beneficial owner |
| 12 | Date of becoming a beneficial owner |
| 13 | Date of cessation as beneficial owner |

Where an individual meets more than one of the six criteria, each criterion is
recorded against them.

Section 60C(4) adds a requirement that is easy to overlook: when information is
received in response to a notice, the company records **both** the date on
which the notice requiring the information was issued **and** the particulars
received. A register showing only the answer, with no trace of the question, is
incomplete.

Where the company names senior management in place of a beneficial owner, a
parallel set of particulars applies, including the position held, the date of
appointment to it, and the reason for naming senior management.

## The 14-day entry clock

Section 60C(4) requires the entry to be made **within 14 days from the date on
which the information is received**.

This is the first of the two clocks in the framework, and it is the one that
gets missed, because nothing external prompts it. The second clock — lodgement
with the Registrar within 14 days of the entry under s.60B(3) and (4) — is
covered in [filing BO information through e-BOS](/en/company-secretary/ebos-filing).

| | Register duty | Lodgement duty |
| --- | --- | --- |
| Section | s.60C(4), s.60B(1) | s.60B(3) and (4) |
| Where | Company's registered office | SSM, through e-BOS |
| Clock starts | Date information is received | Date the entry is recorded |
| Deadline | 14 days | 14 days |
| Fee | None | None; late lodgement fees apply |

Doing the second without the first is the most common compliance failure in
the whole framework, and it is invisible until someone asks to see the register.

## The supporting file

The register does not stand alone. The Guidelines require supporting documents
to be kept **together with** it — the material on which identification and
verification were based. That may include certified copies of national identity
cards or passports, founding documents, and agreements regulating the power to
bind the company.

Every notice issued under s.60C and every reply received forms part of that
file, with the date each was sent and each was received recorded. SSM's
position is direct: these documents are the proof that reasonable steps were
taken to identify the beneficial owner. If a shareholder never answered, the
file is the only thing standing between the company and an allegation that it
never tried.

Verification is a distinct duty. The company must verify the identity of the
natural person recorded, and verify that the person is in fact a beneficial
owner, when an obligation arises to record a name or to record a change of
particulars — and as and when the Registrar instructs. The company secretary
carries the same verification duty at the point of recording, unless the
company has already performed it.

## Retention: seven years past cessation

Section 60B(5) requires the company to retain the information of a person who
has been recorded in the register as a beneficial owner but subsequently ceases
to be one, for **seven years from the date the person ceases**.

The correct handling of an exit is therefore to record the cessation date, not
to remove the entry. The supporting documents stay with it.

This aligns the beneficial ownership file with the seven-year retention period
for accounting records under s.245 — a useful anchor when setting a records
policy, since both clocks run for the same length from different trigger events.

## Who may inspect it

The register kept by the company is not open to the public and not open to
members. Access belongs to:

- Competent authorities — Bank Negara Malaysia, by virtue of s.3 of the
  Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful
  Activities Act 2001
- Law enforcement agencies as defined in s.3 of that Act
- The beneficial owner whose name is recorded, limited to their own information
- Persons authorised by that beneficial owner

Section 60B(9) allows the Minister to prescribe further persons, the manner and
conditions of access, and fees for the supply of information. The Registrar's
central registry, fed by e-BOS, has a slightly wider access list that includes
public bodies carrying out government procurement.

Auditors are outside all of this. SSM has confirmed that auditors are not
required to report on any deficiency in the register of beneficial owners and
do not need access to it for audit purposes.

One consequence of getting the register right: s.60B(8) makes it **prima facie
evidence** of the matters entered in it. Kept properly, it is a defensive asset
in an ownership dispute. Kept badly, it is evidence against the company.

## Common mistakes

- **No register at all**, because the e-BOS submission was treated as the
  record.
- **Recording the answer but not the notice date**, contrary to s.60C(4)(a).
- **Deleting a former beneficial owner** instead of recording the cessation and
  retaining for seven years.
- **Keeping the register at the secretary's office** without filing the s.47(2)
  notification.
- **Filing the notices and replies separately** from the register, so the
  evidence of reasonable steps cannot be produced with it.
- **Recording one criterion** where the individual meets several.
- **Granting the auditor or a member access** on request, when neither has a
  right of access.

## What's next

With the register in place, the lodgement clock becomes mechanical — see
[filing BO information through e-BOS](/en/company-secretary/ebos-filing). If
the identification analysis is still open, work the six criteria through
[who counts as a beneficial owner](/en/company-secretary/who-is-a-beneficial-owner).

Where a shareholder will not reply and the register cannot be completed, the
evidence you must build is set out in
[when the beneficial owner will not respond](/en/company-secretary/bo-non-cooperation).

## Sources

- Companies (Amendment) Act 2024 [Act A1701] — https://www.ssm.com.my/Pages/Legal_Framework/Document/A1701%20BI.pdf (SSM)
- Guidelines for the Reporting Framework for Beneficial Ownership of Companies (Revised 10 January 2025) — https://www.ssm.com.my/Pages/Legal_Framework/Document/Guideline%20BO%20(Revised)%202025%20fair.pdf (SSM)
- FAQ — Beneficial Ownership Reporting Framework of Companies — https://www.ssm.com.my/Pages/Legal_Framework/FAQs%20on%20BO%20(English).pdf (SSM)
- Companies Act 2016 [Act 777] — https://www.ssm.com.my/Pages/Legal_Framework/Document/Companies%20Act%202016_Akta%20777_BI%20(1.8.2022).pdf (SSM)

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