Strata & Building Management
Who is legally allowed to manage your building — and how to check yours is registered
A registered property manager is one registered under the Valuers, Appraisers, Estate Agents and Property Managers Act 1981. An unregistered person may still be engaged, but only against a bond in Form 12 of twelve months' fees or RM50,000, whichever is higher — and acting without it is an offence carrying up to RM50,000 or three years.
Quick summary
Quick answer
Best for
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Buyer action
| Best for | Owners assessing whether their building is competently run, and buyers using management quality as a filter. |
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| Risk level | Medium |
| Buyer action | Send Lewis your building name, the charge you pay and what you are trying to decide, and he will tell you what to check first. |
Who is spending your money
This post works through property management is a registered profession in Malaysia. An unregistered manager is committing an offence with your money. Property management is a registered profession in Malaysia, and the registration requirement is enforceable.
The registered route
Section 2 of Act 757 defines a registered property manager as a property manager registered under the Valuers, Appraisers and Estate Agents Act 1981 — now the Valuers, Appraisers, Estate Agents and Property Managers Act 1981, Act 242. That registration is the cleanest answer to the question of who may manage a strata scheme, because it brings with it a professional body, a code of conduct and a disciplinary route that exists independently of your building's committee.
The unregistered route, and the bond that makes it lawful
The Act does not require every manager to be registered. Under regulation 21(1) and (2) of the 2015 Regulations for a joint management body, and regulation 32(1) and (2) for a management corporation or subsidiary management corporation, a person or agent who is not a registered property manager may be employed under a management agreement provided they lodge a security bond. Regulations 21(2) to (3) and 32(2) to (3) set the terms: a bond in Form 12, given by a bank, finance company or insurer, in an amount equivalent to twelve months' remuneration or fees, or RM50,000, whichever is higher. That bond is the protection standing between the collection and a manager who is not answerable to a professional board.
The Commissioner's managing agent is a third category
Where the Commissioner of Buildings appoints a managing agent under s.86(1), different rules apply. Section 87(1) requires that person to have no professional or pecuniary interest in the scheme. Section 88, with regulations 44(1) and (2), requires a bond in Form 24 from a bank, finance company or insurer, in an amount determined by the Commissioner, lodged before the agent acts. Failure to lodge it is an offence under regulation 44(3), carrying a fine not exceeding RM50,000, imprisonment not exceeding three years, or both.
The penalty for skipping the bond
Regulations 21(5) and 32(5) make it an offence for an unregistered manager or agent to act without complying with the bond requirements. On conviction: a fine not exceeding fifty thousand ringgit, or imprisonment for a term not exceeding three years, or both. That is why the request is worth making in writing. A managing agent who cannot produce either registration under Act 242 or a Form 12 bond is not merely under-qualified — they are exposed personally, and so is the committee that engaged them.
Verify this against your own building
Verify the managing agent's registration and ask for the appointment terms and the last two years of audited accounts. Those three documents answer most questions about competence.
Buyer checklist
Three lawful categories. A registered property manager under Act 242, as defined in s.2 of Act 757. An unregistered person or agent engaged under a management agreement who lodges a bond in Form 12 — regulation 21 for a JMB, regulation 32 for an MC or subsidiary MC — set at twelve months' remuneration or RM50,000, whichever is higher. And a managing agent appointed by the Commissioner under s.86(1), who must have no professional or pecuniary interest in the scheme under s.87(1) and lodges a bond in Form 24 under s.88.
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| 1 | Ask whether your manager is a registered property manager under Act 242 and request the registration details. |
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| 2 | If not registered, ask for the Form 12 bond and check the amount is twelve months' fees or RM50,000, whichever is higher. |
| 3 | For a COB-appointed managing agent, ask for the Form 24 bond under s.88 and regulation 44. |
| 4 | Confirm a COB-appointed agent has no professional or pecuniary interest in the scheme, as s.87(1) requires. |
| 5 | If neither registration nor bond can be produced, put it in writing to the committee and note regulations 21(5) and 32(5). |
Common questions
Must our building's manager be registered?
Not necessarily. A registered property manager under Act 242 is one lawful category, but an unregistered person or agent may be engaged under a management agreement if they lodge a bond in Form 12 under regulation 21 or 32 of the 2015 Regulations.
How big must the bond be?
Equivalent to twelve months' remuneration or fees, or RM50,000, whichever is higher — regulations 21(2) to (3) and 32(2) to (3).
What happens if a manager acts without the bond?
It is an offence under regulations 21(5) and 32(5), carrying a fine not exceeding RM50,000, imprisonment not exceeding three years, or both.
Does a COB-appointed managing agent lodge the same bond?
No. A managing agent appointed under s.86(1) lodges a bond in Form 24 under s.88 and regulation 44, in an amount determined by the Commissioner, and must have no professional or pecuniary interest in the scheme under s.87(1).
Lewis Chong
REN 69566 · IQI GlobalProperty advisor helping KL, JB, and Penang buyers make data-backed property decisions.
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Lewis Conclusion
If you only remember one thing: ask for your share unit figure, not your square footage. It is the number that sets your bill and your vote for as long as you own the unit, and it is printed on documents you are entitled to see.
The sinking fund explained
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Lewis Conclusion
Ask two questions before you buy into any high-rise: what is the sinking fund balance, and when were the lifts, the roof and the external paint last done. If the balance is small and those items are old, the shortfall is coming to you as a special levy — it is only a question of which year.
What actually happens if you stop paying maintenance charges
Stopping payment of maintenance charges triggers a statutory sequence, not a negotiation: a Form 11 notice from a JMB (s.34(1)) or Form 20 from a management corporation (s.78(1)) giving not less than 14 days, interest capped at 10% per annum, then a debt claim, a warrant of attachment over your movable property, or criminal prosecution.
Lewis Conclusion
Withholding charges is the one protest that cannot work, because arrears also disqualify you from the committee and from voting — the exact levers you would need to fix whatever you are protesting about. Pay under protest, then fight it at the tribunal or the AGM where you still have standing.
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Ask whether your manager is a registered property manager under Act 242 and request the registration details.
Send
If not registered, ask for the Form 12 bond and check the amount is twelve months' fees or RM50,000, whichever is higher.
Send
For a COB-appointed managing agent, ask for the Form 24 bond under s.88 and regulation 44.
Send
Confirm a COB-appointed agent has no professional or pecuniary interest in the scheme, as s.87(1) requires.