Forming a Malaysia Labuan company is just the start. Here's a comprehensive guide to annual compliance obligations for your Labuan entity in 2025.
1. Labuan FSA Annual Licence Renewal
Your Labuan company licence must be renewed annually with Labuan FSA. The renewal involves submitting a renewal application, paying the annual licence fee, and confirming your business activities remain within the licence scope. Deadline: 31 January each year.
2. Annual Return Filing
Every Labuan company must file an annual return with Labuan FSA confirming its registered office, directors, shareholders, and share capital. Deadline: Within 3 months of financial year end.
3. Financial Statements
Labuan trading companies must prepare and submit audited financial statements to Labuan FSA. Labuan non-trading (holding) companies may submit unaudited accounts. Deadline: Within 6 months of financial year end.
4. Economic Substance Requirements
Labuan companies engaged in certain ‘relevant activities’ (banking, insurance, fund management, financing, leasing, headquarters, shipping, holding, intellectual property, distribution) must demonstrate economic substance in Labuan:
- Adequate qualified employees in Labuan
- Adequate operating expenditure in Labuan
- Core income-generating activities conducted in Labuan
Blueberry's Labuan trust company partners provide substance solutions including resident directors, office space, and local staff.
5. UBO Register Maintenance
All Labuan companies must maintain an up-to-date Ultimate Beneficial Owner (UBO) register. Changes must be reported within 14 days.
6. India-Side FEMA/RBI Compliance
For Indian residents with outbound investments through their Labuan company:
- APR (Annual Performance Report): Filed by 31 July each year
- ODI reporting: For new investments or shareholding changes
Compliance Calendar
| Obligation | Deadline | Authority |
|---|---|---|
| FSA Licence Renewal | 31 January | Labuan FSA |
| Annual Return | 3 months post-year-end | Labuan FSA |
| Financial Statements | 6 months post-year-end | Labuan FSA |
| UBO Register Update | Within 14 days of change | Labuan FSA |
| APR (India) | 31 July | RBI / AD Bank |
Let Blueberry Handle Your Compliance
Blueberry offers annual compliance retainer packages for Malaysia Labuan companies. Enquire about our compliance retainer →
Also read: Complete Guide to Malaysia Company Formation | What is a Labuan Company? | Opening a Bank Account for Your Malaysia Company | Why NRIs Should Form a Labuan Company