Sdn Bhd Annual Compliance in Malaysia: SSM, Audit and Tax Deadlines for 2026

SSM filings: annual return, financial statements and audit exemption

Under section 68 of the Companies Act 2016, a company lodges its annual return within 30 days of each anniversary of its incorporation date, not its year end. SSM’s fee for a private company is RM150. For anniversary dates from 1 December 2024, the return also carries beneficial ownership information. It is lodged on MBRS 2.0, not the new Corporate Registry System.

According to SSM’s Practice Note 3/2018, a private company circulates its financial statements within six months of year end and lodges them with SSM within 30 days of circulation. The fee is RM50 for audited and RM20 for unaudited statements.

SSM’s Practice Directive 10/2024 replaced the 2017 audit-exemption criteria for financial periods starting on or after 1 January 2025. A private company qualifies if it meets two of three limits in the current and previous two financial years. The limits step up: RM1 million revenue, RM1 million assets and 10 employees for 2025; RM2 million, RM2 million and 20 for 2026; and RM3 million, RM3 million and 30 from 2027. SSM’s guidance shows no later revision. Public companies, their subsidiaries and foreign companies are excluded, dormant companies stay exempt, and exempt companies still lodge unaudited statements.

Tax deadlines: Form e-C, CP204 and MITRS documents

According to the Inland Revenue Board (LHDN), a company files Form e-C electronically within seven months of the end of its accounting period, and LHDN’s 2026 filing programme gives e-filed returns one extra month. The return for a 31 December 2025 year end was due on 31 July 2026, or 31 August 2026 within the grace period. The balance of tax is due by the same date, or the end of any extension, with 10% added to any balance unpaid.

An existing company submits its CP204 estimate at least 30 days before its basis period begins; a new company does so within three months of starting operations, unless it qualifies for the two-year exemption for new companies with paid-up capital of RM2.5 million or less, no related company above that level and, from YA 2024, foreign ownership of 20% or less. The estimate cannot be below 85% of the previous year’s revised estimate, or of its original estimate if it was not revised. Instalments are due by the 15th of each month from the second month of the basis period (the sixth for a new company), with 10% added to a late one. Revisions go in on CP204A in the 6th, 9th or 11th month. If the tax finally assessed exceeds the estimate by more than 30% of that tax, LHDN charges 10% on the excess beyond the margin.

From year of assessment 2025, section 82B of the Income Tax Act 1967 requires companies to upload financial statements, the tax computation and capital allowance and incentive schedules through LHDN’s Malaysian Income Tax Reporting System (MITRS). LHDN’s FAQ, as PwC reports it, counts the 30-day window from the return’s due date including any grace period, so a 31 December 2025 year end had until 30 September 2026.

Employer returns, beneficial ownership, SST and e-Invoicing

LHDN requires employers to give each employee a Form EA by the last day of February and to file Form E, with C.P.8D, by 31 March. Sources differ on the length of the e-Filing extension, so treat 31 March as the deadline. Monthly tax deductions (PCB) are due by the 15th of the following month.

Division 8A of the Companies Act 2016, in force since 1 April 2024, requires a register of beneficial owners: individuals holding at least 20% of the shares or voting shares, or exercising ultimate effective control. The company lodges any change with SSM within 14 days of recording it. The fine is up to RM20,000, plus RM500 for each day the offence continues.

A company registered for Sales and Service Tax files SST-02 for each two-month taxable period and pays by the last day of the following month, according to the Royal Malaysian Customs Department. LHDN’s e-Invoicing exemption threshold rose from RM1 million to RM3 million of annual turnover on 1 September 2026, subject to group conditions; see our e-Invoicing article. Reconcile MyInvois data with the ledger before each SST-02.

Penalties for missing a deadline

SSM’s late lodgement fee under Practice Directive 1/2017 is RM50 for a private company for a document more than seven days to three months late, RM100 up to six months, RM150 up to 12 months and RM200 beyond that. Failing to circulate financial statements to members on time is also an offence, with a fine of up to RM50,000 (section 257(4)), and failing to lodge them is an offence under section 259. SSM has repeatedly waived the first tier for MBRS 2.0 filings, most recently for 1 to 30 September 2026; no later MBRS 2.0 waiver had been announced as at 8 October 2026, and SSM’s extension to 31 December 2026 covers CRS lodgements only.

LHDN also applies a penalty under section 112(3) to late returns: 15% of the tax for a delay of up to 12 months, 30% up to 24 months and 45% beyond. Failing to file Form E, upload MITRS documents or submit a CP204 estimate is an offence under section 120, with a fine of RM200 to RM20,000, up to six months’ imprisonment, or both. Late SST payment costs 10% in the first 30 days and up to 40% after 90 days.

Month-by-month checklist for a 31 December year end

• Monthly, by the 15th: PCB, EPF, SOCSO and EIS for the previous month, and the CP204 instalment.
• Every two months, if SST-registered: SST-02 and payment by the last day of the following month.
• End of February: Form EA to every employee.
• 31 March: Form e-E with C.P.8D.
• 30 June: circulate financial statements, then lodge them within 30 days of circulation.
• June, September and November: CP204A revision months.
• 31 July: Form e-C and the tax balance (e-Filing grace to 31 August); MITRS documents by 30 September.
• By 1 December: next year’s CP204 (YA 2027 is paid in 11 instalments, February to December).
• Within 30 days of each incorporation anniversary: annual return.
• Within 14 days of any change: beneficial ownership update to SSM.

Worked example: the 2026 calendar for a 31 December 2025 year end

A Sdn Bhd incorporated on 15 March, with a 31 December 2025 year end, staff and SST registration, had these deadlines from January 2026 to January 2027. Its 2025 year began on 1 January 2025, so Phase 1 audit limits applied (RM1 million, RM1 million, 10 employees).

Date	What is due	Cost if missed
15th of every month	PCB, EPF, SOCSO and EIS for the previous month; CP204 instalment	10% of a late instalment; EPF charge (minimum RM10); PERKESO interest at 6% a year
15 January and 15 February 2026	Final YA 2025 instalment; first YA 2026 instalment	10% of the amount unpaid
28 February and 31 March 2026	Form EA to employees; Form E with C.P.8D	Form E: section 120 offence, fine of RM200–RM20,000
31 March 2026	SST-02 for January–February	10% of the tax, rising to 40% after 90 days
14 April 2026	Annual return (RM150), 30 days after the anniversary	Late fee of RM50–RM200
30 June 2026	Circulate FY2025 financial statements; CP204A window	Fine of up to RM50,000; extension requests were due by 23 June
30 July 2026	Lodge financial statements (RM50 audited, RM20 unaudited)	Late fee of RM50–RM200
31 July 2026	Form e-C for YA 2025 and balance of tax; transfer pricing file ready	e-Filing grace to 31 August, then a section 112(3) penalty and 10% on unpaid tax
30 September 2026	MITRS documents; CP204A window	Section 120 offence, fine of RM200–RM20,000
30 November 2026	Final CP204A revision	10% of any shortfall above 30% of actual tax
1 December 2026	CP204 estimate for YA 2027	Section 120 offence, fine of RM200–RM20,000

The final YA 2026 instalment is due on 15 January 2027, and SST-02 also falls on 31 May, 31 July, 30 September and 30 November 2026.

What does missing a deadline cost? A worked penalty example

Four missed deadlines cost the same company RM16,350, almost all of it charged by LHDN. Its YA 2025 tax was RM96,000 and its CP204 estimate RM84,000, paid as 12 instalments of RM7,000.

1. Instalment due 15 January 2026, paid 20 January: 10% × RM7,000 = RM700.
2. Underestimate test: RM96,000 less RM84,000 = RM12,000, within the 30% margin of RM28,800, so no penalty.
3. Balance of RM12,000, due 31 August 2026 with the e-Filing grace, paid 30 September: 10% × RM12,000 = RM1,200.
4. Form e-C also filed on 30 September: LHDN’s Operational Guideline 5/2019 sets the section 112(3) penalty for a delay of up to 12 months at 15%: 15% × RM96,000 = RM14,400.
5. Annual return due 14 April, lodged 20 May, 36 days late: a RM50 late fee on top of the RM150 fee, assuming no SSM waiver.
6. Total: RM700 + RM1,200 + RM14,400 + RM50 = RM16,350.

The section 112(3) rate rises to 30% after 12 months and 45% after 24 months. Filing Form e-C on time would have saved RM14,400.

What changed in Sdn Bhd compliance in 2025–2026?

Audit-exemption limits are rising in three steps, MITRS added an upload after Form e-C, SSM changed systems and the Finance Act 2025 (gazetted 31 December 2025) moved CP204 instalments. As at October 2026:

Date	Change
1 January 2025	Phase 1 audit limits: RM1 million revenue, RM1 million assets, 10 employees
YA 2025	MITRS upload due 30 days after the Form e-C deadline
1 January 2026	Phase 2 audit limits: RM2 million, RM2 million, 20 employees
14 July 2026	SSM’s Corporate Registry System (CRS) replaces MyCoID; annual returns and financial statements stay on MBRS 2.0
1 September 2026	e-Invoicing exemption threshold rises from RM1 million to RM3 million of turnover
30 September 2026	MBRS 2.0 late-fee waiver ends; a separate CRS waiver runs to 31 December 2026
1 January 2027	Phase 3 audit limits: RM3 million, RM3 million, 30 employees
YA 2027	Transitional year: 11 CP204 instalments from the second month of the basis period
YA 2028	Instalments start in the first month of the basis period

Budget 2027 is due to be tabled on 9 October 2026; its proposals apply only once legislated.

How to build your company’s compliance calendar: a checklist

Two dates drive the calendar, the incorporation date and the financial year end; the rest recurs monthly or follows an event.

1. Diarise the annual return for 30 days after each incorporation anniversary.
2. From the year end, diarise circulation (6 months), lodgement (30 days after actual circulation), Form e-C (7 months) and MITRS (30 days later).
3. Test audit exemption at each year end on three years’ figures, using the limits for the phase in which the year began.
4. Diarise the CP204 estimate 30 days before each basis period and the 6th, 9th and 11th month revisions; budget 11 instalments for YA 2027.
5. Set the 15th for PCB, EPF, SOCSO, EIS and CP204, plus SST-02 dates if registered.
6. Finish transfer pricing documentation before Form e-C is due, and lodge officer and beneficial ownership changes within 14 days.
7. If financial statements will be late, apply to SSM for an extension at least 7 days before the deadline (RM100).

Common Sdn Bhd compliance calendar mistakes

Most missed deadlines come from counting from the wrong date or relying on an outdated rule.

• Using the 2026 audit limits for a year that began in 2025: a year from 1 July 2025 to 30 June 2026 is tested at Phase 1.
• Assuming a new company is audit-exempt: SSM’s FAQ says a non-dormant company without two preceding years of figures does not qualify.
• Counting lodgement from the circulation deadline: the 30 days run from the actual circulation date.
• Relying on the CRS waiver for an annual return or financial statements, which are lodged on MBRS 2.0.
• Filing Form E without C.P.8D: LHDN treats Form E as incomplete unless C.P.8D is in by the due date.

Malaysian compliance calendar terms explained

These terms appear in SSM and LHDN notices and in the dates above.

• Incorporation anniversary: the yearly date matching the incorporation date; it fixes the annual return deadline.
• Extension of time (EOT): SSM’s approval under section 259(2) to circulate or lodge financial statements later.
• Exempt private company (EPC): a company lodging a section 260 certificate (RM200) instead of financial statements; it cannot also use audit exemption.
• e-Filing grace period: LHDN’s extra time for e-filed returns, which for Form e-C also covers the balance of tax.
• Late payment charge: EPF’s charge on late contributions, at the lower of its two dividend rates plus 1%, minimum RM10.