DICA Blacklists 25 Companies for Non-compliance Registered Office Requirement

Generally, companies incorporated in Myanmar are required to comply with the Myanmar Companies Law 2017 (“MCL”) and its implementing regulations, as well as various other laws and regulations that are relevant to their business activities. Companies that do not comply with are generally subject to administrative actions taken by the Directorate of Investments and Companies Administration (“DICA”) and other related departments.

On 2 December 2025, the DICA took the action to blacklist 25 companies that did not have an office at the location listed as their registered address in the MyCO (Myanmar companies online) system, a violation of Section 141 of the MCL. Under the MCL, such non-compliance is punishable with a fine of MMK400,000. Reporting this type of violation is done by the Bureau of Special Investigation, the Internal Revenue Department, and the Ministry of Foreign Affairs to the DICA for it to take the necessary action.

The DICA announced that 25 companies are blacklisted until the end of the 2026-2027 financial year. It is unclear what actions the DICA and other authorities might take for subsequent compliance failures.

Nevertheless, it is clear that the Myanmar authorities are implementing stricter actions to ensure companies conducting business in Myanmar are in full compliance with current regulations. We are seeing more instances of the DICA and other authorities, especially the Ministry of Commerce, blacklisting and imposing other restrictions on companies for failure to comply with regulations.

Since the procedure to remove a company from the blacklist is relatively new, and government officials are not very familiar with it, it generally takes a long time to process. Therefore, companies should ensure compliance with all applicable laws to avoid unnecessary complications and negative consequences that may arise from non-compliance.