Every company must lodge its beneficial ownership information with the Registrar through e-BOS, SSM's Electronic Beneficial Ownership System, under s.60B(3) of the Companies Act 2016 and Practice Directive 9/2024. The lodgement is due within 14 days from the date the information is recorded in the company's own register of beneficial owners — not from the date the information was received. Lodgement is free; late lodgement is not.
- The 14-day lodgement clock runs from the register entry, not from receipt of the information
- Lodgement is made through e-BOS, accessed via the SSM4U portal, unless the Registrar allows otherwise
- No fee is charged for lodging or updating beneficial ownership information
- The transitional window closed on 30 September 2024; late lodgement fees now apply
- Filing through e-BOS is required even where the annual return already carried the information
- Errors in lodged information are corrected by rectification under s.602, not by refiling
- Lodging through e-BOS does not discharge the separate duty to keep the register
Who this applies to: Company secretaries and agents responsible for lodging beneficial ownership information with SSM.
On this page
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.
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. If you are still deciding whose particulars belong in it, work through who counts as a beneficial owner.
For the system itself, its legal basis and who can access what it holds, see e-BOS.
When exactly does the 14 days start?
From the date the change is recorded in the company's register of beneficial owners, under s.60B(4). This is a different date from the date the information was received from the shareholder, which starts the separate 14-day clock in s.60C(4) for making the register entry. In the worst case the two clocks together give you 28 days from receipt, but only if the register entry is genuinely made on day 14.
Do we still need to file through e-BOS if nothing has changed?
SSM has confirmed that all companies must submit beneficial ownership information through e-BOS even where there are no changes and even where the information was already lodged with the annual return, so that the information is captured in the system. The continuing statutory lodgement duty in s.60B(3) is triggered by changes to the register particulars.
How much does it cost to lodge?
Nothing. Practice Directive 9/2024 states that no fees are imposed for the lodgement of beneficial ownership information, including updates to particulars. Late lodgement fees and rectification fees are separate and do apply now that the transitional window has closed.
We lodged the wrong identity card number. How do we fix it?
Through a rectification application under s.602 of the Companies Act 2016, made in e-BOS with complete supporting documents, following Practice Note 6/2019. Rectification is not the same as an update: an update records a real-world change, while rectification corrects information that was wrong when lodged.
Where do we access e-BOS?
Through the SSM4U portal at ssm4u.com.my. The user must be a registered and verified SSM4U user, then apply to upgrade to a Verified Professional User through the e-BOS dashboard before submissions can be made.
The following are deliberately unstated or described only qualitatively until confirmed by a subject-matter expert:
- Confirm the current late lodgement fee scale applied to beneficial ownership lodgements after 30 September 2024 against SSM's published fee schedule
- Confirm the commencement date of paragraph 68(3)(ia) of the Companies Act 2016, which will require beneficial ownership information to be lodged with the annual return — SSM stated this would be enforced on a date to be determined by the Registrar
Sources
- Practice Directive No. 9/2024 — Lodgement of Beneficial Ownership Information under the Companies Act 2016 through e-BOS — SSM
- FAQ — Implementation of the Electronic Beneficial Ownership System (e-BOS) — SSM
- FAQ — Extension of Time Frame to Lodge Beneficial Ownership Information under Practice Directive No. 9/2024 — SSM
- Guidelines for the Reporting Framework for Beneficial Ownership of Companies (Revised 10 January 2025) — SSM
- Companies (Amendment) Act 2024 [Act A1701] — SSM
Change history
| Version | Date | Change | By |
|---|---|---|---|
| 01.00 | 20 Jul 2026 | Approved and published. | — |