With MBRS 2.0 now fully phased in, all companies must transition to digital filing of financial statements and audit reports, shifting from manual submission to XBRL-driven e-lodgement. Recognizing the friction these changes might bring, SSM introduced limited windows for late lodgement fee waivers to support smooth adoption and avoid penalizing companies and company secretaries still fine-tuning their digital processes.​ 

The latest update isn’t a mere regulatory footnote-it is a lifeline. With the conclusion of MBRS 2.0 Phase 3, SSM’s 26 September 2025 announcement now extends the fee waiver for late submissions from 1 October 2025 until 30 November 2025, as detailed in its technical circulars and FAQs .   This represents both an extended grace period and a not-to-be-missed strategic window.​ 

Who qualifies? Core eligibility hinges on filings for audited financial statements and reports submitted via MBRS 2.0, particularly those falling under Sections 259 and 575 of the Companies Act 2016. The waiver is not an open-ended pass; it applies only if filings are:​ 

• Lodged more than seven days past the statutory deadline 
• Delayed up to three months from the original due date 
• Not already granted an Extension of Time (EOT). 

Filings for annual returns and other statutory documents are excluded; this waiver is focused strictly on audited FS and related documents required in Phase 3 of MBRS 2.0 implementation.​ 

Sample situations clarify eligibility: 

• If the three-month late period ends before 1 October 2025, waiver does not apply. 
• If the late period crosses into the new waiver window but is within November 2025, fees may be waived. 
• If an EOT is granted, the company is not eligible for this waiver. 

MBRS 2.0 Filing Waiver- The Additional Period in Focus

Updated Filing Deadlines and Waiver Windows 

Let’s break down the new compliance roadmap: 

Key point: Filing after the three-month window-even if within the extended waiver period-does not qualify unless the late period itself ends within the window. 

No EOT Applications Needed

Importantly, you do not need to apply for an EOT to use this waiver. If you apply for EOT, the fee waiver will not apply to your submission.​ 

The MBRS 2.0 Filing Waiver Isn’t Just About Fees- It’s About Readiness

For Malaysian company secretaries, this additional period is best leveraged as an operational reset. Here’s how: 

• Catalogue outstanding audits. Review your client register and identify which FS filings are now eligible within the October-November window. 
• Streamline XBRL mapping and validation. Address taxonomy, mapping, and error management well ahead of cutoff dates. 
• Document eligibility and filing activities. Maintain workpapers to validate date chains, pointing to original due date, delay calculation, and waiver eligibility. 
• Prioritize filings soon expiring. Give urgent attention to those close to completing the three-month past-due window.

Mandates for Company Secretaries: Digital and Regulatory Compliance

With MBRS 2.0, SSM has reinforced the importance of digital credentials and statutory compliance. Company secretaries must be registered under Section 241 of the CA 2016, have their Certificate of Company Secretary Practice valid, and be equipped for XBRL e-lodgement using the MBRS 2.0 portal.​ 

Avoiding Compounds and Penalties- Maximize the Waiver

SSM has confirmed that qualifying companies will not be compounded for late submission if they comply with the conditions outlined in Sections 259 and 575 of CA 2016 during the waiver window. This de-risks compliance and preserves your client’s regulatory standing.​ 

MBRS 2.0 Filing Waiver: Key Takeaways for CoSecs in Malaysia

1. Know your deadlines. The window closes 30 November 2025. Any filings submitted after this date or outside the three-month cut-off are subject to normal penalties.​ 
2. Only audited FS filings via MBRS 2.0 qualify for this waiver. Annual returns and other statutory submissions will still incur fees if late.​ 
3. No EOT required- but do not apply for one if you want the waiver. Once an EOT is processed, the waiver is void.​ 
4. Document everything. Keep records of due dates, grace periods, submission dates, and waiver eligibility for each client.​ 
5. Adopt digital-first. Use IRIS Instant to automate XBRL tagging, e-lodgement, audit preparation, and compliance dashboards, ensuring MBRS 2.0 filing readiness year-round.​​

Value-Adding Guidance for Company Secretaries

Company secretaries are the bridge between regulatory updates and internal compliance readiness. The MBRS 2.0 filing waiver period is not just about fee savings–it’s about futureproofing your practice. By automating digital filings and keeping up with evolving compliance windows, you become indispensable in your client’s compliance journey. 

Effortless MBRS 2.0 Filing Waiver Compliance with IRIS Instant

Keeping up with MBRS 2.0 filing’s shifting compliance windows is far more manageable when you equip your practice with the right digital tools. IRIS Instant stands out as the smart ally for Malaysian company secretaries, built by us, the same team of XBRL specialists behind the SSM Taxonomy and the MBRS platform itself.  

Here’s how IRIS Instant transforms the MBRS 2.0 filing waiver experience:​​ 

• AI-Powered Auto-Extraction and Tagging: Upload your PDF financials, and IRIS Instant’s AI auto-populates up to 90% of your data, translating it directly into SSM-compliant XBRL-no rekeying required.​​ 
• Guaranteed Accuracy, Every Filing: IRIS Instant leverages a validation engine certified by XBRL International. This is the very engine running on the official MBRS portal, guaranteeing that every file meets SSM’s strict standards before submission.​​ 
• Real-Time Validation and Error Alerts: Interactive validation checks run throughout the preparation process, flagging missing disclosures, tagging errors, or outdated taxonomy issues before they become filing roadblocks.​ 
• Cloud-Based Collaboration and Smart Memory: Your team can collaborate securely, access unlimited filing histories, and work from anywhere, with repeat filings streamlined by autofill of company profiles and framework settings.​ 
• Expert Review & Support: Top-tier review services-supported by our XBRL experts with a 100% accuracy track record- are available to audit your MBRS outputs and elevate confidence, especially during the critical waiver window.​​ 
• Always Up to Date: IRIS Instant syncs with every SSM Taxonomy update in the cloud, ensuring filings are always aligned with the latest compliance requirements, eliminating guesswork and manual software updates.​ 
• Guided Onboarding: New to MBRS? Free onboarding and training make your first filings smooth, and continual product updates keep you ahead of regulatory curveballs. 

Staying Informed: Where to Get Updates

For all the latest MBRS 2.0 filing waiver information: 

• Refer to SSM’s official FAQ page for situation-based guidance and eligibility checks.​ 
• Follow SSM’s announcements via social media for real-time deadline alerts.​ 
• Participate in IRIS and SSM webinars for hands-on digital training and compliance updates.​ 

The MBRS 2.0 filing waiver window from 1 October to 30 November 2025 is a strategic opportunity for Malaysian companies and company secretaries to close out compliance gaps and secure a smooth digital transition. Embrace this additional period to overhaul your filing processes, digitalize your compliance function, and leverage expert platforms like our AI powered XBRL tagging tool, IRIS Instant, for effortless MBRS 2.0 filings.