Declaring senior management in place of beneficial owner for a Public Company

Companies are allowed to declare its senior management in place of beneficial owner in the following circumstances:

1. the company has no beneficial owner; 
2. the beneficial owner of the company cannot be identified; or
3. the company is still in the process of obtaining its beneficial ownership information.

More information :

1. Guidelines for the Reporting Framework for Beneficial Ownership of Companies
2. Case Studies and Illustrations of the Guidelines for the Reporting Framework for Beneficial Ownership of Companies
3. Electronic Beneficial Ownership System ​(e-BOS)​​
4. Companies (Amendment) Act 2024
5. ​Practice Directive No. 9/2024: Lodgement of Beneficial Ownership Information under the Companies Act 2016 Through e-BOS
6. FAQ Beneficial Ownership​​
7. FAQ Companies (Amendment) Act 2024

Note: A company can name more than 1 individual in their senior management for the purpose of beneficial ownership reporting framework.​