Navigating the statutory complexities of engineering consultancy, structural compliance, and building certification in Malaysia requires a comprehensive understanding of statutory liabilities, local authority submissions, and professional engineering accountability. Under the regulatory purview of the Board of Engineers Malaysia (BEM) and core legislation such as the Registration of Engineers Act 1967 (Act 138) and the Street, Drainage and Building Act 1974 (Act 133), engineering practitioners, property developers, and building owners must adhere to stringent design integrity, quality assurance, and life-safety protocols.
FAQs for Professional Engineers in Malaysia: plan submission, endorsement, supervision and the Certificate of Completion and Compliance (CCC).
- In Malaysia, the practice of professional engineering is strictly governed by the Board of Engineers Malaysia (Lembaga Jurutera Malaysia) in accordance with the Registration of Engineers Act 1967 (Revised 2015) .
- When design discrepancies, execution errors, or material non-compliances arise during the construction lifecycle, immediate technical evaluation is imperative.
- The statutory Certificate of Completion and Compliance (CCC) framework, regulated by the Ministry of Housing and Local Government (KPKT) , replaced the legacy municipal Certificate of Fitness for Occupation (CFO).
01Statutory Framework: BEM, Act 138, and Plan Submission Authority
In Malaysia, the practice of professional engineering is strictly governed by the Board of Engineers Malaysia (Lembaga Jurutera Malaysia) in accordance with the Registration of Engineers Act 1967 (Revised 2015). A pivotal area of statutory governance concerns who possesses the legal authority to sign and submit engineering drawings and calculations to Local Authorities (Pihak Berkuasa Tempatan or PBT) through the One Stop Centre (OSC) system.
Under the statutory framework, only a Professional Engineer with Practising Certificate (PEPC), a separate registration category under section 10D of the Act, or an Engineering Consultancy Practice, may submit plans, drawings and calculations to the authorities, and a PEPC may do so only in the branch of engineering in which he is registered. Registered Graduate Engineers and Professional Engineers without a practising certificate may not submit engineering plans to the authorities. Under section 8A, a PE may submit plans or drawings relating to equipment, a plant or a specialist product invented or sold by him or his employer, and the PE who submits such plans bears the liability even if he did not prepare them.
02Principal Submitting Person (PSP) vs. Submitting Person (SP) Roles
The distinction between the Principal Submitting Person (PSP) and the Submitting Person (SP) is fundamental under Malaysian building legislation, specifically the Uniform Building By-Laws 1984 (UBBL 1984):
- Principal Submitting Person (PSP): Represents the lead qualified professional responsible for spearheading the total building plan submission to the local council. Under the UBBL, the PSP can be a Professional Architect, a PEPC, or a Registered Building Draughtsman. Under the Joint Memorandum of the Board of Architects and BEM, only a Professional Architect may act as PSP for Appendix A projects, the PEPC for Appendix B projects, and either for Appendix C projects. Only a PEPC (Civil) may act as PSP, and only a PSP may sign Form F. The PSP oversees the overall process, validates statutory agency clearances, and ultimately issues Form F (Certificate of Completion and Compliance).
- Submitting Person (SP): A registered Professional Engineer with a practicing certificate who submits disciplinary engineering plans—including structural analysis, foundation piling schemes, civil earthworks, and mechanical and electrical (M&E) networks. Each SP remains legally accountable for their specific engineering calculations, detailing standards, and safety factors under national design codes such as MS EN 1992 (Eurocode 2 for concrete structures) and MS EN 1997 (Eurocode 7 for geotechnical design).
When design discrepancies, execution errors, or material non-compliances arise during the construction lifecycle, immediate technical evaluation is imperative. Engaging professional Structural Repair Consultancy ensures that structural anomalies, honeycombing, shear cracks, or deflection issues are diagnosed and remediated before mandatory stage certifications proceed.
03The Certificate of Completion and Compliance (CCC) & Forms G1–G21
The statutory Certificate of Completion and Compliance (CCC) framework, regulated by the Ministry of Housing and Local Government (KPKT), replaced the legacy municipal Certificate of Fitness for Occupation (CFO). Under this self-certification model, the burden of verifying construction integrity shifts from local council inspectors to the appointed PSP, SPs, and licensed contractors.
Form F (CCC) is issued together with all 21 Form Gs (G1 to G21), each one completed by the relevant Submitting Person (or the PSP) and the contractor, as set out in BEM’s Circular No. 007 and its guide to Forms G1–G21. Key structural milestones include:
- Form G1 (Earthworks): SP is a PEPC (Civil or Geotechnical) only.
- Form G2 (Setting Out): a Licensed Land Surveyor endorses it where setting-out plans are submitted, and the PSP confirms. Where only engineering setting out is required, the PSP signs it off as “Not Applicable”.
- Form G3 (Foundations): SP is a PEPC (Civil or Geotechnical) only.
- Form G4 (Structural): SP is a PEPC (Civil or Structural) only.
Statutory Rule under Act 133: A Local Authority cannot withhold or prevent the issuance of Form F if all statutory prerequisites, internal utility certifications (Tenaga Nasional Berhad, Air Selangor or regional water boards, Indah Water Konsortium, and BOMBA), and Form G stage clearances are technically verified and deposited.
Prior to handover, comprehensive quality audits protect property owners and Joint Management Bodies (JMB) under the Strata Management Act 2013 (Act 757). Independent property stakeholders regularly conduct a systematic Property Defect Inspection (DLP) to systematically catalog latent construction defects, water ingress pathways, and architectural flaws during the 24-month Defect Liability Period.
04Project Takeovers and the “Last Man Standing” Liability
One of the most legally precarious situations faced by engineering consultants in Malaysia involves taking over stalled, distressed, or previously abandoned developments. BEM’s Professional Practice FAQ states that the ‘last man standing’ rule applies: whoever is the Submitting Person signing off the completion of works will assume full liability even if some of the works had been carried out before his involvement.
Before signing any statutory assumption documents or local council resubmissions, the incoming engineer must not supplant, intervene in, or take over the work of another registered engineer unless he has that engineer’s consent, or has been formally notified by the client that the first engineer’s services have been terminated in accordance with their contract (Regulation 31). The procedure is in BEM Circular No. 008. Where there is a dispute over unpaid fees, the client may request the Board to act as stakeholder. Crucially, establishing a clear, documented structural baseline through a professional Dilapidation Survey, coupled with core extraction, carbonation testing, and rebound hammer testing, is good practice to protect the incoming engineering team against pre-existing structural distress.
05Supervision of Temporary Works, CIDB Act 520, and Building Audits
Under the Construction Industry Development Board (CIDB) Act 520 and Department of Occupational Safety and Health (DOSH) guidelines, construction safety mandates strict professional engineering control over temporary structures. BEM Guideline No. 001 sets out the role and responsibility of PEs for temporary works during construction. For temporary works that may affect the safety of workers and the public—such as multi-tier falsework, heavy steel shoring, deep basement contiguous bored pile (CBP) retaining walls, tower crane foundation ties, and bridge launching gantries—the Submitting Person should ensure the contractor engages a PEPC to design, endorse and supervise them. Unless stated in the scope of works, checking temporary works is not part of the permanent-works consultant’s scope.
Engineers are legally prohibited from endorsing works without documented, continuous, and competent site supervision. In modern asset management and recurrent structural safety audits, engineering teams deploy advanced non-destructive inspection technologies, including aerial Façade & Roof Inspection (Drone) methodologies. This enables high-resolution thermal imaging and photogrammetry across complex building envelopes, spandrel panels, and high-altitude roof trusses without subjecting personnel to hazardous rope-access or extensive scaffolding configurations.
Frequently Asked Questions (FAQ)
Can a Professional Engineer without a practicing certificate submit building plans to Malaysian local councils?
No. Under the Registration of Engineers Act 1967 (Act 138), only a Professional Engineer with Practising Certificate (PEPC), a separate registration category under section 10D of the Act, or an Engineering Consultancy Practice may submit plans, drawings and calculations to the authorities, and a PEPC may do so only in the branch of engineering in which he is registered. A PE without a practising certificate may not submit plans, except under section 8A for equipment, plant or a specialist product invented or sold by the PE or his employer. Only a PEPC can be the Submitting Person to the Local Authority.
Who bears statutory liability when latent defects emerge post-CCC issuance?
The Principal Submitting Person (PSP) and the respective Submitting Persons (SPs) who endorsed the Form G certificates and Form F carry statutory and civil liability for ensuring that structural and architectural components conformed strictly to approved engineering calculations and UBBL 1984 standards. If defects result from structural design errors or negligent site supervision, liability extends to the endorsing professional engineers under Malaysian law.
What steps are required when replacing an engineering consultant midway through a project?
The incoming engineer must not supplant, intervene in, or take over the work of another registered engineer unless he has that engineer’s consent, or has been formally notified by the client that the first engineer’s services have been terminated in accordance with their contract (Regulation 31). The procedure is in BEM Circular No. 008. Because the Submitting Person who signs off the completion of works assumes full liability under the ‘last man standing’ rule, it is good practice to carry out an independent structural condition assessment, structural audit and dilapidation survey before endorsing takeover submissions.
What is the legal standing of Forms G1 through G21?
Forms G1 through G21 represent mandatory statutory stage certifications established under the Uniform Building By-Laws 1984. Each form validates a discrete trade package (such as G1 Earthworks, G2 Setting Out, G3 Foundations, and G4 Structural Works) and requires concurrent endorsement from both the supervising qualified professional and the licensed trade contractor before the final Form F (CCC) can be executed.
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