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border data transfer procedures. Dezan Shira’s Vietnam Briefing
account credentials. Processing sensitive data triggers higher standards for consent, access controls, security measures, and internal governance, making data mapping and classification threshold compliance tasks rather than best practices. Decree 356 also tightens the rules for obtaining consent and procedural timelines. Verifiable consent must be obtained and documented, with default settings, pre-ticked boxes, and ambiguous interface designs expressly prohibited. Controllers must respond to data subject requests within fixed statutory deadlines, supported by formal workflows and comprehensive documentation. While limited exemptions and grace periods apply to micro-enterprises and qualifying startups, most employers will need to update internal policies, consent mechanisms, and cross-
III roles will fall between RM5,000 and RM9,999, with a higher minimum of RM7,000 applied in manufacturing and related services. The updated bands are designed to better align expatriate eligibility with seniority and specialist expertise. The framework also introduces defined limits on expatriate tenure. Category I and II passes may be issued for up to 10 years, with Category II approvals linked to succession planning, while Category III passes will be capped at five years. These changes signal a shift toward time-bound expatriate roles focused on leadership, specialisation, and skills transfer rather than long-term workforce reliance. ASEAN Briefing from Dezan Shira & Associates offers further insight into how employers can adapt hiring, compensation, and succession strategies under the revised rules.
provides detailed guidance on initial
compliance priorities and implementation requirements under the new framework. Malaysia From June 1, 2026, Malaysia will begin revising its expatriate employment framework, updating the way foreign professionals are hired, compensated, and retained under the Employment Pass system. The changes are a response to concerns over salary compression between expatriate and senior local roles, as well as prolonged reliance on foreign professionals in sectors where local talent pipelines have matured. Under the revised framework, minimum salary thresholds will increase across all Employment Pass categories. Category I roles will require a minimum monthly salary of RM20,000, while Category II positions will range from RM10,000 to RM19,999. Category
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ISSUE 20 GLOBAL PAYROLL MAGAZINE
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