Quick answer
Since the Companies (Amendment) Act 2024, every Malaysian company must identify its beneficial owners — the natural persons who ultimately own or control it — keep a register of beneficial owners and report the particulars and any changes to SSM (Companies Act 2016, ss.60A–60E). Nominee or trust arrangements do not remove this duty.
Last reviewed： · Reviewed by：ONEKEY BIZ compliance team
01
Overview
A beneficial owner is the natural person who ultimately owns or controls a company — which may not be the person whose name is on the share register. Companies held through a holding company, a nominee, or a trust all have a real person at the end of the chain.
The Companies (Amendment) Act 2024 added Division 8A (Sections 60A to 60E) to the Companies Act 2016. Section 60A defines a beneficial owner, Section 60B requires the company to keep a register of beneficial owners and report the particulars and changes to SSM, Section 60C lets the company require disclosure, and Section 60D puts a duty on the beneficial owner to tell the company.
In practice the difficult cases are layered structures: a foreign parent company, several shareholders each below any obvious threshold, or someone who controls the board without owning shares. We trace the chain, document how each beneficial owner was identified, and keep the register ready for SSM, banks and auditors.
Who needs this
- Every company incorporated in Malaysia
- Companies owned through a foreign holding company
- Companies with nominee shareholders or trust arrangements
- Companies that have just had a share transfer or new investor
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Documents you need to prepare
Ownership chain
- Current register of members
- Group structure chart for corporate shareholders
- Constitution and shareholder agreements affecting control
Each beneficial owner
- Full name, IC or passport, nationality and date of birth
- Residential address
- Date they became a beneficial owner and how (ownership, voting, control)
- A nominee arrangement does not remove the duty to identify and report the real beneficial owner.
- Every later change — a transfer, an allotment, a change of control — must be reported again.
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How to get it done with ONEKEY BIZ
- 1Structure review Day 1–3
We map shareholders and any holding companies, nominees or trusts.
- 2Identify BOs Day 3–5
We identify each beneficial owner and record the basis.
- 3Build the register Day 5
We prepare the register of beneficial owners.
- 4Report to SSM Day 5–7
We lodge the particulars with SSM.
- 5Keep it current Ongoing
Any future change is reported as part of our secretarial service.
You do
- Share the ownership and control structure
- Provide each beneficial owner's particulars
We do
- Trace ownership through every layer
- Prepare the register of beneficial owners
- Report to SSM
- Update it after every change
04
What you receive
Kept with your statutory records, ready for SSM, banks and auditors.
Proof the beneficial ownership particulars were reported.
How each beneficial owner was identified, for your compliance file.
A note in our system to report any future change.
Official sources
Frequently asked questions
Is the shareholder always the beneficial owner?
Not always. If a shareholder holds shares for someone else, or a company is the shareholder, the beneficial owner is the natural person behind it.
Do nominee shareholders change this?
No. The real beneficial owner must still be identified and reported.
What happens after a share transfer?
The register and the SSM report must be updated for the new beneficial owner.