LLP Compliance Update
Beneficial Ownership Filing Effective 30 May 2025
Beneficial Ownership (BO) is a crucial legal concept in Malaysia that identifies the natural person who ultimately owns or controls a company. Beneficial ownership is distinctly different from legal ownership. While legal ownership recognises the owner in the official records, BO goes beyond the legal shareholder and aims to increase corporate transparency by uncovering the true individual behind a corporate entity.
The official online platform launched by the Companies Commission of Malaysia (SSM) to facilitate this process is the e-BOS (Electronic Beneficial Ownership System) system. With this BO system, the government aims to enhance its powers to combat financial crimes like money laundering and terrorism financing.
If You Are Managing a LLP
If you are managing a Limited Liability Partnership (LLP) in Malaysia, this is a crucial update you cannot afford to miss. Starting from 30 May 2025, all LLPs are required to submit Beneficial Ownership (BO) information through the SSM’s (Companies Commission of Malaysia) e-BOS LLP system.
What is a BO under the LLP Act 2012?
A Beneficial Owner refers to any individual who:
- Ultimately owns or controls the LLP through direct or indirect ownership (e.g., holding more than 20% of shares or capital), or
- Exercises significant influence or control over the LLP’s management or decisions.
This includes partners, directors or other individuals who derive benefit from the LLP’s assets or profits, even if they are not formally registered as owners.
You may ask, what is the goal of doing so or what is the purpose for the declaration? The answer is that it is to enhance transparency, prevent money laundering and align Malaysia’s corporate governance with international anti-financial crime standards.
Key Highlights from Practice Note 5/2025
In the Practice Note 5/2025 issued by the SSM, a few requirements are imposed on LLPs, such as:
- Mandatory e-BOS Submission: All LLPs must file BO details via the e-BOS LLP portal on the SSM website.
- Effective Date: The requirement takes effect on 30 May 2025.
- Grace Period: A five (5)-month grace period is granted until 31 October 2025, during which LLPs may submit their BO information without incurring late fees or penalties.
- Ongoing Compliance: Any changes in BO details (e.g., new partners, ownership shifts) must be updated within fourteen (14) days of the change.
- Record Keeping: LLPs must maintain accurate internal BO records and make them available for inspection by authorities upon request.
What Happens If the LLP Does Not Comply?
After 31 October 2025, failure to submit or update BO information may result in serious penalties, including:
- A fine of up to RM50,000 and/or
- Daily compounding fines of RM1,000 for continued non-compliance.
These penalties apply to both the LLP and its responsible partners or officers.
Why This Matters for Your LLP
Ensuring LLP compliance in Malaysia is not just about avoiding fines, it is about building trust with stakeholders, financial institutions and regulators. With increasing scrutiny on corporate transparency, timely e-BOS LLP submission strengthens your business’s credibility and legal standing.
Take Action Now – Avoid Costly Penalties!
Don’t wait until the last minute. Use the grace period wisely and submit your beneficial ownership information via the e-BOS LLP system before 31 October 2025 to avoid fines and ensure full compliance.
Visit the SSM e-BOS LLP portal today and safeguard your LLP’s future: https://www.ssm.com.my
Need help understanding your BO obligations? Contact us or visit SSM’s official resources on Practice Note 5/2025 for detailed guidance.
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