Accountant vs Auditor vs Tax Agent vs Company Secretary: Who Does What in Malaysia

Who does what in a Malaysian company's accounts?

Five roles usually touch a Sdn Bhd's numbers each year: the bookkeeper, the accountant, the auditor, the tax agent and the company secretary. Three of them come with specific approval or licensing requirements: the auditor must be an approved company auditor, a tax agent must be an approved tax agent, and the company secretary must be licensed by SSM or be a member of a prescribed body.

Role	Licence or approval	When you need them	Typical deliverables
Bookkeeper	Not a statutory appointment; choose on skills and reliability	Every month	Recorded transactions, bank reconciliations, receivables and payables lists, monthly reports
Accountant	Not a statutory appointment; works to approved standards (MPERS or MFRS)	Year end, plus adjustments during the year	Year-end adjustments and financial statements
Auditor	Must be an approved company auditor	Every financial year, unless the company is audit-exempt	Independent auditor's report on the financial statements
Tax agent	Must be an approved tax agent	Each year for Form C, before each year for CP204, and for LHDN queries	Tax computation, Form C, CP204 estimate and revisions
Company secretary	Licensed by SSM or a member of a prescribed body	Within 30 days of incorporation, then at all times	Annual return, resolutions, statutory registers, SSM lodgements

In a small company, one firm often covers both bookkeeping and accounting, and some firms also offer tax or secretarial services. The audit, however, is meant to be an independent check. The sections below explain each role and how they fit together.

What does a bookkeeper do?

A bookkeeper records the company's day-to-day transactions and keeps the accounts reconciled, month by month. The typical scope:

• recording sales invoices, receipts, supplier bills and expenses;
• reconciling every bank account against the books;
• tracking receivables (who owes you) and payables (whom you owe);
• recording payroll journals and statutory payments;
• preparing monthly management reports: profit and loss, balance sheet and cash position.

This is the layer the law looks at first. The Companies Act 2016 (section 245) requires entries to be made within 60 days of a transaction and records kept for 7 years. Every other professional in this article relies on this work. If you are deciding who should do it, compare outsourcing bookkeeping with hiring in-house and see what drives bookkeeping fees.

What does an accountant do that a bookkeeper doesn't?

An accountant turns the year's records into financial statements, making the judgement calls that go beyond recording transactions. Typical year-end work includes depreciation of equipment and vehicles, accruals and prepayments, closing stock, provisions for doubtful debts, and a review of the director's account.

The financial statements must follow approved accounting standards; most private SMEs use MPERS, and MFRS is the alternative. The directors approve them and circulate them to members within 6 months of the financial year end, and they are lodged with SSM within 30 days after circulation.

In a small company, the same person or firm often does both the bookkeeping and the accounting. That works well when the monthly records are reconciled before the year-end work starts; if they are not, the accountant spends the first weeks rebuilding them instead of finishing the accounts.

When do you need an auditor?

You need an auditor every financial year unless your private company qualifies for audit exemption and chooses to use it. The auditor's job is to give an independent opinion on whether the financial statements are properly prepared, set out in the auditor's report. Only an approved company auditor can carry out the audit.

Under SSM's Practice Directive 10/2024, a private company can elect not to be audited if it meets at least two of three thresholds (revenue, total assets and employees) for the current and the immediate past two financial years. For financial years starting in 2026, the limits are RM2 million revenue, RM2 million total assets and 20 employees, and the 2024 and 2025 years are tested against the same RM2 million limits. Companies that have been dormant (since incorporation, or in the current and immediate past financial year) also qualify. See audit exemption for Sdn Bhd for the full rules.

An exempt company may still face an audit: members holding, together, at least 5% of the voting shares can require one by written notice, and banks, licensing bodies or grant agencies may ask for audited accounts. Because the audit is an independent check, keep the people who prepare your accounts separate from the auditor who reviews them.

What does a tax agent do for a Sdn Bhd?

A tax agent works out how much tax the company owes and deals with LHDN on its behalf; anyone acting as your tax agent must be an approved tax agent. The main tasks:

• Tax computation. Adjusting accounting profit into chargeable income: adding back items that are not deductible, such as fines, private expenses and half of most business entertainment, and claiming capital allowances in place of depreciation. See which expenses are tax deductible.
• Form C. Due within 7 months after the financial year end, with a 1-month e-filing grace normally allowed; filed electronically as e-C through MyTax.
• CP204. The estimate of tax payable, submitted at least 30 days before each financial year starts, paid in monthly instalments by the 15th and revised with CP204A in the 6th, 9th and 11th months if needed.
• LHDN correspondence, queries and reviews.

The tax agent also checks whether the company qualifies for SME tax rates (15% on the first RM150,000 of chargeable income and 17% up to RM600,000) or pays 24% from the first ringgit. That test depends on conditions such as paid-up capital and ownership, so give your tax agent accurate share-capital and shareholder details, not just the accounts.

Why does every Sdn Bhd need a company secretary?

Because the Companies Act 2016 requires it: every company must have at least one company secretary, and the board must appoint the first one within 30 days of incorporation. The secretary must be licensed by SSM or be a member of a prescribed body.

The company secretary's job is statutory compliance with SSM, not accounting. Typical duties:

• lodging the annual return within 30 days from each anniversary of incorporation;
• preparing directors' and members' resolutions, for example to approve the financial statements or change directors;
• keeping the company's statutory registers up to date;
• lodging the financial statements with SSM within 30 days after they are circulated.

Your company secretary does not prepare your accounts or your tax return, but the SSM lodgements depend on both being ready on time.

How do they work together over a financial year?

They work in sequence, and each one depends on the person before them. For a company with a 31 December 2025 year end:

1. January to December 2025: the bookkeeper records and reconciles every month.
2. Early 2026: the accountant closes the year and prepares the financial statements.
3. Before circulation: the approved company auditor audits them, or the directors confirm that the company is audit-exempt.
4. By 30 June 2026: the financial statements are circulated to members.
5. Within 30 days after circulation: the company secretary lodges them with SSM.
6. By the end of July 2026 (e-filing grace to 31 August 2026): the tax agent submits Form C.
7. At least 30 days before each new financial year: the tax agent submits the CP204 estimate.

The annual return runs on its own clock: within 30 days from each anniversary of incorporation. The Sdn Bhd annual compliance calendar sets out every date.

Example: one profit figure, four professionals

Example with illustrative figures: a Klang Valley café Sdn Bhd ends 2025 with RM96,000 profit before tax in its financial statements.

Step	Who	Amount
Profit before tax in the financial statements	Accountant	RM96,000
Add back depreciation (not deductible)	Tax agent	+ RM18,000
Deduct capital allowances instead	Tax agent	− RM20,000
Add back half of RM3,000 business entertainment	Tax agent	+ RM1,500
Chargeable income	Tax agent	RM95,500
Tax at 15%, if SME rates apply	Tax agent	RM14,325

Now suppose the bookkeeper had missed a RM6,000 supplier bill dated December. Profit would be overstated by RM6,000, so the financial statements lodged with SSM, the Form C and the tax (RM900 too much at 15%) would all be wrong, and fixing them later means reopening work for every party. That is the practical case for reconciled monthly books.

How WeCount helps

WeCount is the bookkeeping and reporting layer in this picture. We record your transactions, reconcile your bank accounts, track receivables and payables, support LHDN e-Invoice, prepare monthly management reports and hand clean, evidenced records to your year-end professionals. WeCount is not a tax agent, an audit firm or a company secretary: regulated audit, tax-agent and professional accountancy services are delivered through appropriately authorised partners where required. See our services and packages.