Once a company is registered, the next task is managing the annual accounts, filings, and record updates. This work can be handed to a company secretary, accountant, and tax agent, but founders still need to know what has been done and which documents are waiting for their review.
For a typical Sdn. Bhd., the annual schedule can be built around two dates: the incorporation anniversary, used to schedule the annual return, and the financial year end (FYE), used to schedule financial statements and the corporate tax filing. Employer filings, tax installments, and SST each have their own timetable.
Setting the dates, the people responsible, and the required documents in the first year usually makes ongoing maintenance much easier to manage. This article lays out the basic annual schedule that foreign founders need to know for an existing company.
Three Questions This Article Answers First
- What do the two key dates each affect: when are the annual return, financial statements, and tax filing each due?
- What needs to be maintained year-round: how should the company secretary, employer filings, and transaction-related taxes be divided up?
- What happens with no business activity: what is the difference between dormancy, audit exemption, and closing the company?
Who Needs This Calendar?
The first group is foreign founders who have just set up a company and have not yet been through their first anniversary or year end. The second is directors who have engaged a secretarial firm and accountant to handle routine filings and want a clear picture of what is covered and how things are progressing. The third is shareholders of a company that currently has little or no business, or holds only a small amount of assets, and need to assess the annual maintenance work and cost.
Outsourcing can reduce the administrative burden, but a director still has to fulfill the corresponding oversight, approval, and compliance duties. At the same time, the company, the company secretary, and other professionals each carry their own statutory or professional responsibilities; it is not accurate to say all responsibility falls on the director alone.
When actually engaging service providers, first confirm whether the scope includes bookkeeping, preparing statements, audit, tax computation, and the various filings, rather than assuming a single secretarial contract covers everything.
Anchor One: The Incorporation Anniversary — The Annual Return Timetable
The annual return must generally be lodged with SSM within 30 days of the company’s incorporation anniversary, confirming the company’s registered address, directors, shareholders, and other statutory information. In practice, this is usually prepared and lodged by the company secretary, then checked and signed by the relevant people.
It is a different document from the financial statements and the corporate tax filing. Lodging the annual return does not mean the statements and tax filing are also done.
A more convenient approach is to have the company secretary send an information-confirmation checklist ahead of the anniversary. If there is any change to directors, address, shares, or beneficial ownership during the year, notify the secretary promptly and update within the relevant deadline, rather than waiting for the next annual return.
Anchor Two: The Financial Year End — The Timetable for Statements and Tax Filing
The main schedule for a private company is set out below. In the first year, also pay attention separately to the deadline for preparing the first set of financial statements.
| Timing | Main Task | Common Division of Work |
|---|---|---|
| Within 18 months of incorporation | Prepare the first financial statements | Prepared by the accountant, with the director responsible for ensuring completion; an auditor is arranged if an audit is required |
| Within 6 months of the FYE | Circulate financial statements and related reports to shareholders and other statutory recipients | Approved by the director, coordinated between the accountant and company secretary |
| Within 30 days of circulating the financial statements | Lodge the financial statements and related documents with SSM | Usually handled by the company secretary or an appointed lodger |
| Within 7 months of the end of the accounting period | Submit Form C and settle any balance of tax as required | Prepared by the tax agent, confirmed and paid by the company |
| Within 30 days of the relevant tax filing deadline | Applicable companies submit designated documents through MITRS | Coordinated between the tax agent, accountant, and company |
The 18 months in the first year and the 6 months after the year end are different requirements. The first is the deadline for preparing the first set of statements; the second is the circulation deadline for a private company. Do not let the fact that the first statements can be prepared within 18 months of incorporation cause you to overlook the circulation timeline that an earlier year end brings.
Accounts should also be kept in order continuously. Leaving bank records, invoices, and contracts to be reconciled only just before the statutory deadline leaves too little time for the director to review, for the audit, and for tax adjustments. SSM and LHDN deadlines must each be met separately; a delay on one side does not automatically extend the deadline on the other.
On audit, a private company is in principle required to have an audit, though those that qualify can apply an audit exemption under applicable rules such as Practice Directive 10/2024. The new framework is phased in based on the start date of the financial period, and requires checking conditions relating to revenue, assets, and employee numbers, along with the necessary annual records; it is not simply a matter of looking at this year’s turnover.
Qualifying for the SSM audit exemption does not mean a bank, investor, or other authority will necessarily accept unaudited statements. If the company has financing or transaction plans, confirm the other party’s requirements first.
In addition, CP204 tax estimates and installment payments are a within-year task, not something to schedule only after the year end. The timetable differs between an ongoing company and a newly operating one, and should be set out on the calendar by the tax agent based on the actual situation.
A private company generally has no statutory requirement under the Companies Act for a mandatory annual general meeting (AGM), but should still check the constitution and any other agreements, and complete the required director or shareholder resolutions.
Standing Obligations: Three Things to Track Year-Round
First, the company secretary and maintaining statutory records. Within 30 days of incorporation, a qualified company secretary must be appointed, and the registered office and related registers must be maintained. Any change to directors, shares, address, or beneficial ownership should be promptly confirmed with the secretary against the applicable update requirements.
A company secretary must be a natural person who meets the statutory qualifications and holds a valid practising certificate; engaging a secretarial firm means the statutory role is held through its qualified individuals, not by the firm itself.
Second, employer and payroll filings. Once employees are hired, confirm the applicable PCB, EPF, and SOCSO arrangements based on their status and the nature of their pay. A director who is actually employed and draws a salary may also be subject to these obligations, though treatment can differ by type of payment.
Common tax dates include: PCB generally due by the 15th of the following month; EA/EC forms generally given to employees by the last day of February the following year; Form E and C.P.8D generally due by 31 March the following year. Any e-filing grace period or special arrangement should be checked against that year’s announcements.
Foreign employees should not be assumed exempt from contributions either. For example, from wages paid from October 2025, qualifying non-Malaysian employees have been brought into mandatory EPF contribution arrangements.
Third, SST and transaction-related tax. Regularly check whether the goods or services the company provides fall within the taxable scope and whether the relevant registration threshold has been reached. Importing goods, buying taxable services from overseas, or paying certain overseas amounts may also carry separate tax or withholding obligations.
E-invoicing follows a separate set of rules and cannot be determined simply by SST registration status. These matters are best tracked by whoever handles invoicing and payments at the time of the transaction, rather than leaving everything until year end.
A Company With No Business: Confirm Its Status Before Arranging Maintenance
Having no income for now does not mean a company can stop all filings. Generally, the annual return, financial statements, and related tax filing must still be handled; LHDN also explicitly requires a dormant company to submit the relevant tax returns, including Form E.
That said, a dormant or not-yet-operating company may not need to submit CP204. So existing arrangements should not simply be cancelled altogether, nor should every arrangement for an operating company be applied unchanged; the company’s actual status should be confirmed first.
A company holding property, shares, fixed deposits, or similar investments cannot be treated as dormant just because it has few transactions. A property-holding company earning rental income should keep normal records of income, expenses, and asset information. The SSM audit exemption and LHDN’s tax treatment of dormancy also need to be assessed separately.
If a company is no longer going to be used long-term, compare the cost of keeping it going against closing it down in accordance with the law. Dormancy does not make a company disappear; applying to strike it off or wind it up has different conditions, and assets, debts, taxes, and any outstanding filings need to be dealt with first.
Common Misconceptions and Risks in Annual Compliance
Misconception One: “Once It’s Outsourced to a Secretarial Firm, I Don’t Need to Ask About It Again”
The company secretary, accountant, and tax agent may have different scopes of work. A director should at least know who is responsible for what, when information needs to be provided, and which documents require their own review and approval.
Misconception Two: “No Income Means I Just Fill Everything in as Zero”
A company may still have secretarial fees, bank charges, shareholder loans, or assets. No business income does not mean there are no transactions in the accounts, nor does it mean every figure in every filing is zero.
Misconception Three: “Audit Exemption Means I Don’t Need to Keep Books”
The exemption applies to the audit requirement where conditions are met, not to the accounts, financial statements, lodgment, or tax filing. Eligibility must also be reconfirmed for the relevant year and conditions.
Misconception Four: “Submitting a Few Days Late Shouldn’t Make a Difference”
Being late may involve additional fees, penalties, increased tax, or other consequences depending on the item. If you expect not to meet a deadline, check in advance whether an extension process is available, rather than assuming an extension has already been granted just because one can be applied for.
Misconception Five: “The First Year Can Be Sorted Out After the Year End, at Leisure”
The first set of statements, the first anniversary, and the first CP204 may not fall close together. Confirming the year end and actual start date at incorporation is what allows the first year’s schedule to be set accurately.
Three Typical Scenarios: Putting the Calendar Into Practice
Scenario One: A Newly Incorporated Founder Running the Business Themselves
After incorporating, Mr. A confirms the year end, the deadline for the first set of statements, and the first-year tax estimate arrangement with his accountant and company secretary, then builds a habit of monthly bookkeeping and quarterly review.
When he starts hiring staff or paying himself a salary as an employee-director, he arranges employer registration, contributions, and filings at the same time. After each important milestone is complete, he keeps the submission receipts and confirmed versions, making the following year easier to pick up.
Scenario Two: A Shareholder Whose Company Holds Property With Few Daily Transactions
Ms. B’s company only owns one property. She still needs to record the property, rent, loans, maintenance, and management fees, and complete the annual return and tax filing.
The audit exemption is assessed separately based on applicable conditions. When choosing a service package, she confirms separately whether bookkeeping, statements, audit, and tax filing are included, and factors the annual maintenance cost into her property-holding budget.
Scenario Three: An Overseas Shareholder Relying on a Local Team
Mr. C asks the company secretary and accountant to share an annual calendar and provide accounts and pending items regularly. The director reviews and approves the statements following the applicable process, and the company keeps records of submissions and payments to SSM and LHDN.
If he is only a shareholder, not a director, he should obtain information through proper corporate governance arrangements, rather than treating shareholder confirmation as a substitute for director approval. The key to managing remotely is a clear division of work, complete information, and status that can be checked.
FAQ: Malaysia Company Annual Compliance
Q1: What are the most important deadlines each year?
The annual return is generally due within 30 days of the incorporation anniversary; a private company’s financial statements are generally circulated within 6 months of the year end, then lodged with SSM within 30 days of circulation; Form C is generally due within 7 months of the end of the accounting period.
In the first year, also check the requirement to prepare the first set of statements within 18 months of incorporation. CP204, applicable MITRS filings, and employer filings each have their own separate dates.
Q2: Do I have to have a company secretary? Can I do it myself?
A typical Sdn. Bhd. must appoint a company secretary. A founder who meets all the statutory qualifications, status, and practising requirements may consider taking on the role themselves; it is not banned outright.
But when the same person holds both the director and secretary roles, they cannot substitute one person for the two roles where the law requires each to act separately. Most foreign founders choose to engage a qualified company secretary.
Q3: Does my company need an audit?
In principle, yes, though some private companies can qualify for an exemption under the current directive. This depends on the start date of the financial period, the applicable thresholds, the required annual records for the relevant year, and any exclusion conditions.
Even where the statutory exemption applies, a bank or investor may still require an audit. Confirm the company’s actual needs for that year first.
Q4: My company has no business at all. Do I still need to go through all of this?
Generally, the annual return, financial statements, and tax filing obligations still apply, though items such as CP204 may be treated differently for a dormant or not-yet-operating company.
Have the company secretary and tax agent confirm the status first; do not stop filing on your own initiative, and do not treat “no income” as automatically the same as “dormant.”
Q5: What happens if I miss a deadline?
Depending on what is overdue, there may be additional fees, penalties, increased tax, or other legal consequences. Confirm which documents or payments are outstanding, then lodge, pay, or apply for relief through the relevant authority’s process.
An individual delay does not necessarily block banking services or transactions, but incomplete filings can add to the work needed for future checks and transaction preparation.
Q6: If everything is outsourced, what do I still need to do myself?
Provide information on time, review documents that need your approval, set aside funds for fees and tax, and confirm that important filings have been completed. When there is a change to directors, shareholders, address, beneficial ownership, or business during the year, notify the relevant service providers promptly.
If you are a director, this is part of fulfilling your oversight role; if you are only a shareholder, you should keep track through the board and agreed reporting arrangements.
Disclaimer
This article is based on publicly available information verified as of September 2026. It mainly applies to a general Malaysian private limited company and does not constitute individual legal, tax, or accounting advice. First-year arrangements, audit exemption, filing grace periods, and transaction obligations can vary by company; the actual calendar should be confirmed jointly with a qualified company secretary, accountant, and tax professional.
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Sources
- SSM — Companies Act 2016
- SSM — FAQ: Annual Return
- SSM — FAQ: Accounts, Audit and Annual General Meetings
- SSM — FAQ: Annual Returns and Financial Reporting
- SSM — Audit Exemption Framework and Practice Directive 10/2024
- SSM — Audit Exemption FAQ, Updated 19 May 2026
- SSM — Practising Certificate Requirements for Company Secretaries
- LHDN — Corporate Tax
- LHDN — Tax Estimates
- LHDN — Dormant Companies and Other Situations
- LHDN — MITRS Filing Programme for Year of Assessment 2026
- LHDN — Employer Responsibilities
- EPF — Contributions for Non-Malaysian Citizen Employees
- Royal Malaysian Customs — SST Industry Guides
