Electronic Beneficial Ownership System (e-Bos): Overview and FAQs

The Companies Commission of Malaysia (SSM) has launched the Electronic Beneficial Ownership System (e-BOS) to streamline the submission of beneficial ownership information by companies. This system, effective from April 1, 2024, aligns with the updated guidelines for reporting beneficial ownership, replacing the transitional framework introduced in 2020.

What is an Electronic Beneficial Ownership System (e-Bos)?

e-BOS is an online application facilitated by SSM for updating and rectifying beneficial ownership information under the Companies Act 2016. Typically, submissions for updating information are automatically approved upon submission. However, submissions requiring rectification of beneficial ownership information may undergo additional review or approval processes. e-BOS can be accessed of via SSM4U Portal.

The e-BOS system offers the following services:

(a) Notification of beneficial ownership information:

Addition of new beneficial owners or senior management
Update of existing beneficial owners or senior management
Ceasing of beneficial owners or senior management

(b) Rectification of beneficial ownership information

For further details on Guidelines for Beneficial Ownership (BO), please click here.

Preparing to Update Beneficial Ownership Information

Consider Exemption Status
- Assess whether your entity qualifies for exemption from identifying beneficial owner(s). If exempted, declare the exempted status. Note that this exemption applies only to the entity itself and does not exempt its subsidiaries from identifying their beneficial owner(s).
Identify Beneficial Owner(s)
- Continuously identify the beneficial owner(s) of the entity by evaluating all criteria outlined in the Beneficial Ownership Guideline. Include every intermediary shareholder within the group in this assessment. Review this identification at least annually or whenever there is a change in shareholders.
Submit Beneficial Ownership Information
- Maintain up-to-date and accurately recorded beneficial ownership information in the beneficial ownership register at the entity’s level. This information should be prepared for submission to the SSM after the transitional period.

FAQs about e-Bos

1. When will the Electronic Beneficial Ownership System (e-BOS) begin operation?

e-BOS was launched and began operation on 1 April 2024.

2. What browser suitable for using this e-BOS?

e-BOS is best viewed by using Chrome or Mozilla Firefox with a resolution of 1024 x 768.

3. How could new users access e-BOS?

e-BOS users need to follow the following steps:

Step 1: Ensure that the user has registered with the SSM4U Portal (https://ssm4u.com.my) and has been verified as a Verified User.

Step 2: Visit the SSM4U portal at https://ssm4u.com.my.

Step 3: Log in to the SSM4U portal using the registered email address and password.

Step 4: In the main services section, click on the e-BOS icon.

Step 5: Apply as a Verified Professional User:

On the e-Bos Dashboard page, click User Management and click Upgrade/Update Verified Professional. Complete all the required information, click Submit and wait until the application is approved.

A notification email will be sent to the registered email after application processed.

Step 6: Proceed to submit Beneficial Ownership information via e-BOS after the account has been activated.

4. What is meant by the e-BOS transition period?

The transition period is the duration provided to companies to update Beneficial Ownership Information through e-BOS. Companies must update Beneficial Ownership information via e-BOS within three (3) months (1 April 2024 - 30 June 2024).

5. Beginning 1 April 2024, should all companies need to submit update Beneficial Ownership information via e-BOS even if they have updated it through the submission of Annual Return (AR)?

Yes, all companies need to submit Beneficial Ownership via e-BOS even though latest Beneficial Ownership information has been lodged through Annual Return. This is to ensure that the beneficial ownership information is recorded in e-BO

6. What actions must be taken by local companies to obtain and submit Beneficial Ownership information after its incorporation?

Actions that should be taken as below:

(a) Obtain and record BO information into register of BO within sixty (60) days from the date of appointment of the company.

(b) Notify the Registrar within fourteen (14) days from the date of BO information is recorded in the register of BO.

7. When is the submission period for beneficial ownership updates for newly registered foreign companies?

Within fourteen (14) days after the companies have been registered as foreign companies.

8. Will a late filing fee for submissions that are submitted after fourteen (14) days be imposed?

(a) Submission made during the three (3) months transition period are not subject to a late lodgement penalty; and

(b) SSM will update any changes from time to time.

9. Is the notification of beneficial ownership information that has been registered amended?

(a) Yes, the company can apply for rectification under provision Section 602(1);

(b) Amendments are only applicable to submissions made through e-BOS only;

(d) Registration is based on Practice Note No. 6/2019 (Revised): Procedures for Rectification of Documents Lodged and

Registered with the Companies Commission of Malaysia.

10. What types of amendments could be made through e-BOS?

(a) Rectification:

Amendments to the beneficial owner/senior management information that has been submitted. Example - Date of appointment of beneficial owner and number of identification card.

(b) Remove/Cancellation:

Amendment to cancel the appointment/placement of beneficial owner/senior management. Example - Appointment of Mr. A as senior management.

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