# Filing Beneficial Ownership Information Through e-BOS

> The lodgement duty under s.60B(3) and Practice Directive 9/2024 — what to file through e-BOS, when the 14-day clock starts, and how to fix a mistake.

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

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The lodgement is the part everyone remembers, because it produces an
acknowledgement. That is exactly why it is the part that hides the breach: a
clean e-BOS history looks like compliance even when the company has no register
at all.

Keep the two apart. This page is about the duty owed to the **Registrar**. The
duty to keep the company's own register is
[a separate obligation on a separate clock](/en/company-secretary/bo-register).

## What the lodgement duty actually is

Section 60B(3) requires the company to lodge with the Registrar a notice of any
change to the particulars in its register of beneficial owners. Section 60B(4)
sets the deadline: **within 14 days from the date on which the change is
recorded in the register**.

Practice Directive 9/2024, issued on 13 May 2024 under s.20C of the Companies
Commission of Malaysia Act 2001 and s.60B(7) of the Companies Act 2016,
supplies the mechanism: unless the Registrar allows otherwise, lodgement must
be made through the **Electronic Beneficial Ownership System (e-BOS)**.

That is the legal basis competitor walkthroughs omit. They describe the screens;
the screens are not the obligation.

## The clock starts later than you think

Read s.60B(4) against s.60C(4) and the sequence is:

| Step | Deadline | Runs from |
| --- | --- | --- |
| Record in the register of beneficial owners | 14 days | Date the information is received from the person given notice — s.60C(4) |
| Lodge the change with the Registrar | 14 days | Date the change is **recorded in the register** — s.60B(4) |

So the lodgement window is not 14 days from the shareholder's reply. It is 14
days from your register entry. A company that records the entry the same day it
receives the reply has 14 days to lodge; a company that records on day 14 has
until day 28.

The revised Guidelines of 10 January 2025 spell this out in paragraph 20, which
was rewritten precisely to separate the recording step from the lodgement step.
The 1 April 2024 version compressed both into one instruction, which is why so
much published guidance states a single 14-day deadline.

Do not treat the later deadline as a licence to delay. The 14-day recording
period is itself a duty under s.60C(4), and s.60B(6) reaches the company and
every officer.

## The entry points, in order

**A newly incorporated company** has 60 days from the appointment of its
company secretary to obtain the beneficial ownership information. That 60-day
window is inclusive of both the 14-day recording period and the 14-day
lodgement period — so the notices must go out early in the window, not at the
end of it.

**An existing company** lodges within 14 days of each register entry recording
a change, and continues to do so for as long as it exists.

**A newly registered foreign company** lodges beneficial ownership information
at the registration stage under s.562(1)(fa), then records that information in
its register within 14 days after registration — the reverse of the local
sequence.

The Guidelines also contemplate beneficial ownership information travelling
with the annual return, under paragraph 68(3)(ia) inserted by the Companies
(Amendment) Act 2024. SSM has stated that paragraph came into force on a date
to be determined by the Registrar and that, in the meantime, beneficial
ownership information accompanies the annual return under the existing MBRS
requirements. Confirm the current position before relying on the annual return
as your lodgement route — it is listed in `verificationNeeded` on this page.

## Filing mechanics

e-BOS is reached through the SSM4U portal at ssm4u.com.my. The submitting user
must first be a registered and verified SSM4U user, then apply through the
e-BOS dashboard to upgrade to a **Verified Professional User**, and wait for
approval before any submission can be made. Firms that leave this to the day of
the deadline discover the approval is not instant.

The services available in e-BOS are narrow and specific:

- **Notification of beneficial ownership information** — add a new beneficial
  owner or senior management, update an existing one, or record a cessation
- **Rectification of beneficial ownership information** — correction of
  information already lodged

Two operational details worth knowing. Where beneficial owners are recorded as
a joint arrangement, SSM applies a minimum of 50.001% for each group. And where
the register of beneficial owners is kept somewhere other than the registered
office, the company notifies SSM under s.47(2) — the location notification is
not made inside e-BOS.

## Fees, late fees and the closed window

Lodgement is free. Practice Directive 9/2024 states that no fees are imposed
for the lodgement of beneficial ownership information, including for updating
changes to any particulars.

Late lodgement is not free, and the grace period is long gone:

| Date | Position |
| --- | --- |
| 1 April 2024 | Division 8A in force; transitional window opens, originally ending 30 June 2024 under PD 9/2024 |
| 27 May 2024 | PD 9/2024 revised, extending the window by three months |
| 30 September 2024 | Extended window closes |
| From 1 October 2024 | 14-day clocks apply in full; late lodgement and rectification fees imposed |

During the window, companies could lodge and update at any time without
adhering to the 14-day period, and no late lodgement or rectification fee was
charged. SSM confirmed no further extension would be granted, citing Malaysia's
FATF mutual evaluation.

If you are reading a guide that says the deadline was 30 June 2024, or that
enforcement began on 1 July 2024, it predates the 27 May 2024 revision.

## Fixing a mistake: update versus rectification

These are different operations and choosing wrongly creates a record that
contradicts your register.

An **update** records something that changed in the real world — a beneficial
owner's new address, a new criterion met, a cessation. It follows the ordinary
14-day cycle and attracts no fee.

A **rectification** corrects information that was wrong when it was lodged — a
mistyped identity card number, an incorrect date of appointment. It is made
under s.602 of the Companies Act 2016, submitted through e-BOS with complete
supporting documents, and processed in line with Practice Note 6/2019 (issued
5 November 2019, revised 31 December 2020 and 24 January 2022). e-BOS also
supports removal or cancellation of a beneficial owner or senior management
entry that should not have been made.

Rectification fees were waived during the transitional window. They are not
waived now.

## The discrepancy duty

Separately from lodging changes, companies must notify the Registrar of any
**discrepancy** between the information in their own register and the
information lodged with the Registrar. The revised Guidelines direct
discrepancy reports to SSM by email.

The 2025 revision also added an obligation running the other way: a person who
has been supplied with beneficial ownership information from the Registrar's
registry and subsequently discovers a discrepancy must report it within 30 days
from the date the information was supplied.

## Common mistakes

- **Running the clock from the shareholder's reply.** It runs from the register
  entry under s.60B(4).
- **Treating the e-BOS acknowledgement as the register.** The register is a
  separate statutory record under s.60B(1) kept at the registered office.
- **Skipping e-BOS because the annual return carried the information.** SSM has
  confirmed the e-BOS submission is still required.
- **Using an update to fix an error.** Errors go through s.602 rectification
  with supporting documents.
- **Leaving the Verified Professional User upgrade until deadline day.**
- **Assuming a fee applies and delaying to arrange payment.** Lodgement is free.
- **Relying on the transitional relief.** It ended on 30 September 2024.

## What's next

Build the register first and the lodgement becomes bookkeeping — see
[keeping the BO register](/en/company-secretary/bo-register). If you are still
deciding whose particulars belong in it, work through
[who counts as a beneficial owner](/en/company-secretary/who-is-a-beneficial-owner).

For the system itself, its legal basis and who can access what it holds, see
[e-BOS](/en/company-secretary/ebos).

## Sources

- Practice Directive No. 9/2024 — Lodgement of Beneficial Ownership Information under the Companies Act 2016 through e-BOS — https://www.ssm.com.my/Pages/Legal_Framework/Document/Practice%20Directive%209%202024%20(Final)%20Uploaded%20version.pdf (SSM)
- FAQ — Implementation of the Electronic Beneficial Ownership System (e-BOS) — https://www.ssm.com.my/Pages/Legal_Framework/FAQ%20BO%20(OPERATION%20BI).pdf (SSM)
- FAQ — Extension of Time Frame to Lodge Beneficial Ownership Information under Practice Directive No. 9/2024 — https://www.ssm.com.my/Pages/Legal_Framework/Document/EXTENTION%20OF%20TIME%20FRAME%20TO%20LODGE%20BENEFICIAL%20OWNERSHIP%20INFORMATION%20UNDER%20PRACTICE%20DIRECTIVE%20NO.%209.2024.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)
- Companies (Amendment) Act 2024 [Act A1701] — https://www.ssm.com.my/Pages/Legal_Framework/Document/A1701%20BI.pdf (SSM)

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