SSM revised Practice Directive No. 11/2026 on 6 November 2026. The directive asks certain companies to lodge their shareholder and share capital information with the Registrar so that the Corporate Registry System (CRS) holds an accurate record. SSM’s announcement says the revision took effect on 6 November and fully exempts local public listed companies.
Compared with the original 14 July text, the list of companies in scope has been rewritten. SSM’s FAQ now says there is no restriction from 6 November 2026 on companies that have not updated their share information. The window to lodge still closes on 14 January 2027.
If you read our July or August posts on this directive, the scope and the consequence described there reflect the original 14 July text.
Who is in scope now
Paragraph 7 of the revised directive applies to:
- A company with one class of share, multiple shareholders, and shares issued for multiple considerations (cash and otherwise than cash).
- A company with multiple classes of shares and multiple shareholders.
- Foreign companies.
Paragraph 2 states that the directive does not apply to local public listed companies.
A company with one type of share, one type of consideration and more than one shareholder does not need to lodge (Q115). All foreign companies must lodge their current share and shareholder information (Q114).
Both local limbs in paragraph 7 require multiple shareholders, and every scenario in the FAQ’s table has multiple shareholders. On that wording, a local company with a single shareholder is not in scope, even if it has more than one class of share. That is our reading of the text; the directive does not address single-shareholder companies expressly.
For a company with one class of share and several shareholders, consideration decides the question. It is in scope if some of its shares were issued for cash and some otherwise than cash. The forms ask for both figures separately, so the answer comes from your own records of each share issue.
How this compares with the July version
SSM issued the directive on 14 July 2026, issued a further version on 5 August 2026, and revised it on 6 November 2026. The 6 November text states that it supersedes the version issued on 5 August. The comparison below is with the original 14 July text.
| 14 July 2026 text | Text revised 6 November 2026 | |
|---|---|---|
| Local companies in scope | “Local companies with members holding more than one type of shares” | One class with multiple shareholders and multiple considerations; or multiple classes with multiple shareholders |
| Foreign companies | All | All |
| Local public listed companies | Not mentioned | Excluded |
| Consequence of not lodging | “The companies will not be able to access any of the services as listed in Annexure A unless and until the information ... is duly lodged” (paragraph 10) | Companies are “advised to lodge” before any update listed in Annexure A (paragraph 9). FAQ Q116: no restriction from 6 November 2026. FAQ Q129: the company can still access the related share services |
| Forms | Annexure B for all | Annexure B for local companies, Annexure C for foreign companies |
| Window | 14 July 2026 to 14 January 2027, extendable | Unchanged |
| Fee | None | None |
Annexure A, the list of nine CRS services, is the same in both versions. It covers changes to the register of members, redemption of preference shares, allotments and return of allotment, alteration of share capital, variation of class rights, reduction of share capital, and an increase in a foreign company’s share capital.
What happens if you do not lodge
SSM’s FAQ states that no fine applies if the information is not lodged (Q130), there is no fee to lodge (Q127), and there is no late lodgement fee (Q128).
SSM still advises in-scope companies to lodge, and to check that their share and shareholder details are correct and consistent with SSM’s records before they do (the 6 November announcement and FAQ Q116). The FAQ explains why the exercise exists: the old system did not hold information the Companies Act 2016 requires, including the voting rights attached to shares, the features of preference shares, whether shares were issued for cash or otherwise, and each shareholder’s holding (Q113).
Both forms carry a declaration. Making or authorising a statement that a person knows is false or misleading is an offence under section 591 of the Companies Act 2016, punishable by imprisonment of up to ten years, a fine of up to RM3 million, or both (FAQ Q131 and the forms).
How to lodge
Lodgement is in person, over the counter at SSM’s Head Office or any SSM State Office (paragraph 10 and FAQ Q121).
- Local companies use Annexure B: a notice to update shares and shareholders information, Table A on capital structure, and Table B on the shareholder breakdown. The company secretary signs the notice and gives a practising certificate number.
- Foreign companies use Annexure C, with the same three parts, signed by the company’s agent. Authorised capital need not be completed if the home country has no requirement for it (FAQ Q120).
Table A and Table B ask for the share types, the number and amount of shares issued for cash and otherwise than cash, paid and unpaid amounts, voting rights, the features of any preference shares, and each shareholder’s holding (FAQ Q117). Where a company has Class A and Class B ordinary shares, both are declared under “Ordinary”, and Class A and Class B preference shares under “Preference” (FAQ Q119). A passport’s expiry date is mandatory where a shareholder is identified by passport number.
The company does not key the information into CRS itself. An SSM officer updates CRS from the forms submitted (Q122). Processing time follows SSM’s internal procedures (Q123). The status appears on the CRS dashboard, and SSM emails the company secretary (Q124).
What to do now
Check whether you are in scope. Count your share classes and shareholders, and check how each issue of shares was paid for. A one-class company with several shareholders is in scope if its shares were issued for both cash and otherwise than cash.
If you are a foreign company registered in Malaysia: you are in scope. Your agent completes Annexure C.
If you had been holding back a share filing because of the July block: SSM’s FAQ says the restriction no longer applies from 6 November 2026. Check your records against SSM’s before you file either way.
If you are in scope: lodge before 14 January 2027. There is no fee, but the declaration must be accurate.
If you would like us to check whether your company is in scope, or to prepare and lodge Annexure B or C, we can help.
Sources: Companies Commission of Malaysia (SSM), Practice Directive No. 11/2026, 14 July 2026, revised 6 November 2026, with Annexures A, B and C; the original 14 July 2026 text; SSM announcement “Pindaan Arahan Amalan No. 11/2026”, 6 November 2026; SSM, Soalan-Soalan Lazim Corporate Registry System (CRS), edition reflecting the 6 November 2026 revision, questions 112 to 131. This article is general information current as at 10 November 2026 and is not legal advice. SSM has revised this directive twice since July; check the current version before you lodge.