
A Klang Valley logistics SME gets a 40-question “Act 854 supplier security questionnaire” from a port operator client. Does the new cyber law now apply to its small WordPress site and quote form?
This guide answers that from the website side: who the Cyber Security Act 2024 actually binds, how it still reaches small businesses, how it differs from the PDPA, and a practical checklist. It comes from ZenWeb, a Malaysian Google Partner agency with 500+ clients that builds and maintains business websites, lead forms and web systems.
This post is general information, not legal advice. Please confirm your own situation with a lawyer or a licensed cyber security adviser.
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This short explainer from a Malaysian law firm walks through the Act’s structure first.
Source video: HHQ on YouTube. A general overview recorded in August 2024; the website-specific points are set out below.
Quick Answer: The Cyber Security Act 2024 (Act 854) is Malaysia’s law for protecting National Critical Information Infrastructure. It was gazetted on 26 June 2024 and came into force on 26 August 2024. It is enforced by NACSA, the National Cyber Security Agency, and it also licenses certain cyber security service providers.
According to NACSA’s Act 854 page, the Act sets up the National Cyber Security Committee, the powers of NACSA’s Chief Executive, and duties for NCII sector leads and NCII entities. In plain terms, it does three things:
Notice what is missing: there is no general rule that every business website must meet a security standard. That job still sits mostly with the PDPA, which our guide to PDPA security for web systems covers in detail.
Quick Answer: NACSA lists 11 NCII sectors, from government and banking to energy, healthcare services and trade. Being in a sector is not enough. A business only takes on Act 854 duties when its sector lead designates it as an NCII entity because it owns or operates a critical system.
The NACSA NCII page defines NCII as systems whose disruption would affect national defence, the economy, public health and safety or the Government’s ability to function. The table shows how an SME usually meets each sector: as a supplier, not the designated entity.
| NCII sector | How an SME usually meets it |
|---|---|
| Government | Vendor building or hosting a portal for an agency |
| Banking and finance | Merchant using a bank’s payment gateway |
| Transportation | Logistics supplier to a port or airport operator |
| Defence and national security | Contractor under a defence supply contract |
| Information, communication and digital | Customer of a telco, cloud or data centre provider |
| Healthcare services | IT or facilities vendor to a hospital group |
| Water, sewerage and waste management | Contractor to a utility operator |
| Energy | Vendor to a power or oil and gas operator |
| Agriculture and plantation | Supplier to a large plantation group |
| Trade, industry and economy | Vendor to a major trade or market operator |
| Science, technology and innovation | Tech supplier to a research or innovation body |
Source: Sector list from NACSA’s NCII page, read October 2026; “how an SME meets it” column is ZenWeb’s illustrative summary, not a designation list. Licence.
NACSA does not publish a list of designated companies, so you usually hear it from your client or sector lead. If your online store only accepts card payments through a gateway, your card-data duties come from your acquirer, not Act 854; see our guide to PCI DSS for small online stores.
Quick Answer: Rarely in a direct way. A normal SME with a company website, lead forms and ads is not an NCII entity and is not a licensed provider, so Act 854 imposes no direct duty on its site. The Act reaches SMEs indirectly, through NCII clients’ contracts and through the security vendors they hire.
The bar table scores common situations by how directly Act 854 touches them. It is illustrative, not a legal ruling.
| Situation | Where the duty comes from | Score | Directness |
|---|---|---|---|
| Designated NCII entity | The Act and its regulations | 10 / 10 | |
| Sells pen testing or SOC monitoring | NACSA licensing rules | 10 / 10 | |
| Supplier with system access to an NCII client | The client’s contract and questionnaire | 6 / 10 | |
| SME hiring a pen tester for its site | Choosing a licensed vendor | 3 / 10 | |
| Typical SME site with forms and ads | PDPA, not Act 854 | 1 / 10 |
Source: Illustrative scenario by ZenWeb, based on the structure of Act 854 as described by NACSA, as at October 2026. Not a legal opinion. Licence.
The middle row is where most SMEs feel the Act, as NCII entities push security clauses down to vendors. Expect questions on admin access, hosting, backups, incident reporting and whether your CRM sits overseas; our guide to cross-border data transfer and overseas CRMs helps with that answer.
Quick Answer: NCII entities must follow their sector’s code of practice, run a cyber security risk assessment at least once a year, be audited at least once every two years, and report incidents to NACSA and their sector lead: immediately, with details within six hours and a full report within 14 days.
These timelines come from the regulations made under the Act, listed on NACSA’s legal page, which took effect with the Act on 26 August 2024. These are the clocks behind an NCII client’s questions to you.
| When | NCII entity duty | What a supplier may be asked for |
|---|---|---|
| Immediately | Notify NACSA and the sector lead of an incident | Fast alert if your system is involved |
| Within 6 hours | Send incident details and severity | Logs, timeline, affected accounts |
| Within 14 days | Send full report on impact and fixes | Root cause and what you changed |
| Every year | Cyber security risk assessment | Annual security questionnaire |
| Every 2 years | Cyber security audit | Evidence of controls, policies and access |
Source: ZenWeb summary of the Cyber Security (Notification of Cyber Security Incident) Regulations 2024 and the Cyber Security (Period for Cyber Security Risk Assessment and Audit) Regulations 2024, as listed by NACSA, as at October 2026. Supplier column is illustrative. Licence.
A six-hour clock is short. A supplier who needs three days to work out who has admin access to its own site is a risk the client may drop. If personal data is involved, a separate PDPA clock also applies, covered in our guide to data breach notification steps in Malaysia.
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Quick Answer: Only if they sell managed SOC monitoring or penetration testing. Those two services need a NACSA licence; applications opened on 1 October 2024 through licence.nacsa.gov.my. Normal web design, hosting setup, plugin updates and SEO are not licensed services under the Act.
NACSA’s licensing page covers both companies and individuals. Providers had a grace period to the end of 2024, so from 2025 offering these services unlicensed risks prosecution. This matters when you buy security work:
For what routine care looks like and costs, see our guide to website maintenance in Malaysia. If your site has already been compromised, start with our steps to clean malware from a hacked website.
Quick Answer: For a normal business website, the Personal Data Protection Act 2010 is the law that matters. It applies to anyone collecting personal data in commercial transactions, including lead forms, WhatsApp chats and tracking. The Cyber Security Act 2024 adds duties only if you are an NCII entity or a licensed provider.
Both laws talk about “security” and “incidents”, so they are often mixed up. Here is where each one bites for a marketing website.
| Point | Act 854 | PDPA 2010 (as amended) |
|---|---|---|
| Who it covers | Designated NCII entities and licensed providers | Any business processing personal data commercially |
| What it protects | Critical systems and services | Personal data of individuals |
| Regulator | NACSA and sector leads | Personal Data Protection Commissioner |
| Lead forms and CRM | Not covered unless part of an NCII system | Covered: notice, consent, security, retention |
| Breach reporting | NCII incidents to NACSA (6 hours / 14 days) | Personal data breaches to the Commissioner |
Source: ZenWeb comparison based on NACSA’s Act 854 pages and the Personal Data Protection Commissioner’s website, read October 2026. Licence.
Guidance from the Personal Data Protection Commissioner is where your website obligations really sit. Pay attention to the higher-risk areas:
Quick Answer: List everyone with admin access, turn on two-factor login, keep the CMS and plugins updated, run daily off-site backups, keep activity logs, know where your data is hosted, and write a one-page incident plan with named contacts. These cover most questions in an Act 854-driven supplier questionnaire.
Illustrative example. The Klang Valley logistics SME found four admin accounts on its site, two belonging to former staff, and no logs. After the checklist it had two named admins with two-factor login, monthly updates, off-site backups and an activity log, and the questionnaire took one afternoon instead of a week.
Payments and invoicing tools add their own surface. Our guides to payment gateway integration in Malaysia and an e-invoice request form on your website show how to add them safely. Check your public pages too: e-commerce website legal requirements lists what must be shown, and our guide to the Copyright Act 1987 for marketers covers the content side.
Quick Answer: Treat routine website security, such as updates, backups and monitoring, as an ongoing running cost in your maintenance plan. Larger one-off work, like a rebuild to meet a client’s security terms, may be treated differently in your accounts. Ask your tax agent how to classify it.
Security spending raises three practical money questions for SMEs:
Keep the vendor’s scope and reports either way; they double as evidence for your NCII client’s audit.
The Cyber Security Act 2024 is a serious law, but it is aimed at critical infrastructure and at licensed security providers. For most SMEs, it does not apply directly to the company website. It reaches you through NCII clients, their contracts, and the security vendors you hire. The PDPA remains the law for your lead forms and tracking. As at October 2026, we found no amendment widening Act 854 to ordinary business websites, but NACSA can update codes and designations, so check its site before relying on this guide.
Usually not directly. The Act binds designated NCII entities and licensed cyber security service providers. A normal SME website with lead forms is mainly governed by the PDPA, though NCII clients may impose security terms through contracts.
Act 854 was gazetted on 26 June 2024 and came into force on 26 August 2024. Its four main regulations on incident notification, risk assessment and audit, licensing and compounding took effect at the same time.
Not for web design, hosting setup, updates or SEO. A licence is needed only for managed security operation centre monitoring or penetration testing services, whether offered by a company or an individual.
Immediately after it becomes aware, with incident details within six hours and a full report within 14 days, to NACSA and its sector lead. Suppliers to NCII entities are often asked to support these timelines by contract.
Not automatically. Only entities designated by their sector lead because they own or operate NCII take on the duties. If you are unsure, ask your sector lead or a lawyer.
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