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Special Cases

Audit Exemption & EA1 / EA2 / EA3

MBRS has a formal process for requesting relief from parts of the standard filing requirement, called an Exemption Application. There are three types, and they are not interchangeable.

Last reviewed: July 2026

Not a substitute for advice

Exemption eligibility criteria are defined by SSM and can change. Confirm your company's eligibility for any exemption directly with SSM or a company secretary before relying on it — this page explains what each exemption is for, not whether your company qualifies.

Exemption Applications (EA) are their own filing type

Within MBRS, an Exemption Application is a formal request for relief from a specific part of the standard filing requirement — not a blanket "opt out" of MBRS altogether. There are three defined exemption types, each addressing a different situation:

Exemption Application EA1 Foreign subsidiary FYE alignment EA2 File KFI instead of full XBRL EA3 Foreign co. waiver of FS lodgement
Three exemption types, three different situations
TypeWhat it's for
EA1Exemption from requiring a foreign subsidiary's financial year end to coincide with its Malaysian holding company's financial year end.
EA2Exemption from filing financial statements in the full XBRL format — if approved, the company may instead file only Key Financial Indicators (KFI) in XBRL, a substantially reduced dataset. See our Simplified vs Full XBRL guide for more.
EA3Waiver, for an eligible foreign company, of the requirement to lodge financial statements with SSM at all. See our guide for foreign companies.

EA2 is the one most companies ask about

Of the three, EA2 comes up most often in practice, because it is what people usually mean when they loosely refer to "Simplified XBRL" — filing a reduced set of Key Financial Indicators instead of a full, fully-tagged financial statement. This can meaningfully reduce preparation effort for smaller or lower-activity companies, but it is not automatic: SSM's approval is required before the KFI-only route can actually be used.

The sequencing that matters

An exemption application generally needs to be submitted and approved before the filing it affects. Applying for EA2 as a last-minute alternative when a full XBRL deadline is already close is unlikely to work — treat exemption applications as an early-stage decision, not a deadline-day fallback.

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Weighing whether to apply for an exemption?

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Audit exemption is a related, separate concept

Malaysia's audit exemption framework — generally available to dormant, zero-revenue, or small-threshold companies under SSM's published criteria — determines whether a company's financial statements need to be signed off by a licensed auditor before lodgement. A company can be exempt from audit and still need to lodge unaudited financial statements through MBRS in the standard XBRL format, unless it has also separately obtained an EA2 exemption for the reduced KFI format. Audit exemption and filing-format exemption are two different approvals, addressing two different questions, and one does not automatically grant the other.

How the pieces fit together

  1. Is the company required to file at all? In almost every case, yes — see our SMEs and dormant companies guide.
  2. Does the company qualify for audit exemption? This determines whether a licensed auditor needs to sign off the accounts before lodgement.
  3. Does the company want to apply for EA2? This determines whether the lodged financial statement can be a reduced Key Financial Indicators set instead of the full XBRL statement — and requires prior SSM approval.
  4. Does EA1 or EA3 apply? Relevant mainly to foreign-owned or foreign-registered structures with specific financial year or lodgement circumstances.