When Malaysian companies begin their JAKIM halal certification journey under MHMS 2020, one of the first questions they face is deceptively straightforward: does my company need an IHCS or a HAS?
The answer depends on the size of your organisation — but the implications of choosing the wrong framework, or underestimating the requirements of either, can delay your certification or trigger non-conformities during audit.
This guide explains both systems in practical terms, clarifies the differences, and helps you determine which one applies to your company.
MHMS 2020 — the Malaysian Halal Management System — recognises that a multinational food manufacturer with 500 employees and a small bakery with 5 staff cannot reasonably implement the same compliance framework. The operational complexity, resources, and risk profile are fundamentally different.
To address this, MHMS 2020 defines two distinct halal management systems:
Both serve the same purpose: ensuring that halal integrity is systematically managed, documented, and auditable. The difference lies in scope, depth, and documentation requirements.
The Internal Halal Control System is a simplified halal management framework designed for micro and small companies. It provides a structured but proportionate approach to halal compliance that smaller organisations can realistically implement with limited staff and resources.
Under MHMS 2020 classification:
| Category | Criteria |
|---|---|
| Micro enterprise | Fewer than 5 employees OR annual revenue below RM300,000 |
| Small enterprise | 5–29 employees (manufacturing) or 5–9 employees (services) OR annual revenue RM300,000–RM15 million |
If your company falls within these thresholds, IHCS is your required framework.
Although simplified, IHCS is not optional or informal. It requires:
Halal policy and commitment. A written statement from top management committing to halal integrity, communicated to all staff.
Designated halal person-in-charge. Unlike HAS, which requires a formal Halal Executive and committee structure, IHCS requires at least one designated person responsible for halal matters. This individual must have basic halal competency and documented authority.
Raw material and supplier control. All raw materials must be verified as halal-compliant. Supplier halal certificates must be collected, verified, and monitored for expiry — the same fundamental requirement as HAS, though the documentation may be less formal.
Basic process controls. Procedures to prevent cross-contamination during processing, handling, storage, and distribution. For a small bakery, this might mean documented segregation between halal and non-halal ingredients. For a small cosmetics manufacturer, it covers raw material handling and production line controls.
Record keeping. Documented evidence of compliance activities: supplier certificates, training attendance, cleaning records, and any incident reports. Records must be retrievable during a JAKIM audit.
Basic internal checks. While IHCS does not require the formal internal audit programme that HAS demands, the organisation must conduct periodic self-checks to verify that halal controls are functioning.
Compared to HAS, IHCS does not mandate:
This does not mean these elements are discouraged — it means they are not audit requirements for companies operating under the IHCS framework.
The Halal Assurance System is the comprehensive halal management framework required for medium and large enterprises. It is significantly more demanding than IHCS in terms of documentation, organisational structure, and ongoing management.
| Category | Criteria |
|---|---|
| Medium enterprise | 30–199 employees (manufacturing) or 10–29 employees (services) OR annual revenue RM15 million–RM50 million |
| Large enterprise | 200+ employees (manufacturing) or 30+ employees (services) OR annual revenue above RM50 million |
HAS includes everything in IHCS plus substantially more:
Formal organisational structure. A designated Halal Executive (Eksekutif Halal) who meets MHMS 2020 competency requirements, reports to top management, and has documented authority. A functioning JKHD with defined membership, meeting schedules, and documented minutes. For a complete breakdown of every HAS component, see our Halal Assurance System guide.
Comprehensive HCP mapping. Every Halal Control Point across all production lines must be formally identified, documented, and monitored with ongoing records — dates, times, responsible personnel, and outcomes.
Structured internal audit programme. Trained internal auditors must conduct scheduled audits against the full MHMS 2020 scope. Audits must generate formal findings and NCRs.
Full NCR workflow. Non-conformities must be formally raised, root-cause analysed, corrected, verified, and closed — with documented evidence at each stage. Auditors will review not just individual NCRs but patterns and trends.
Supplier qualification system. Beyond basic certificate verification, HAS requires a documented supplier qualification procedure including risk assessment, ongoing monitoring, and procedures for handling non-compliant suppliers.
Management review. Top management must conduct periodic reviews of HAS effectiveness, documented with attendance, agenda, findings, and action items.
Document control. All HAS documentation must be version-controlled, with defined procedures for document creation, approval, distribution, revision, and obsolescence.
| Requirement | IHCS (Micro/Small) | HAS (Medium/Large) |
|---|---|---|
| Halal policy | Required (basic) | Required (formal, displayed, communicated) |
| Responsible person | Person-in-charge (basic competency) | Halal Executive (MHMS qualifications) |
| Internal committee | Not required | JKHD with defined membership and meetings |
| Raw material control | Certificate collection and basic monitoring | Full supplier qualification with risk assessment |
| HCP documentation | Basic awareness of critical points | Formal HCP mapping with monitoring records |
| Internal audit | Periodic self-checks | Structured programme with trained auditors |
| NCR management | Basic incident recording | Full workflow: raise, root-cause, correct, verify, close |
| Document control | Basic recordkeeping | Version-controlled system with approval workflows |
| Management review | Not required | Periodic formal review with documented actions |
| Training | Basic halal awareness | Structured programme with competency assessment |
| Typical documentation volume | 10–20 documents | 50–100+ documents |
In practice, determining whether your company falls under IHCS or HAS is not always obvious. Several situations create ambiguity:
Companies near the threshold. If you have 28 employees and are hiring, you may cross into medium enterprise territory during your certification period. It is worth building toward HAS requirements proactively rather than discovering mid-audit that your framework is insufficient.
Multi-site operations. A small company with two manufacturing locations may face different audit expectations than a single-site operation of the same size. Consult with your certification body.
Contract manufacturers. If you manufacture on behalf of larger brands, those brands may require you to meet HAS-level standards regardless of your company size — as a condition of their own supplier qualification process.
Growth trajectory. If your business plan involves scaling from small to medium within the next 2–3 years, consider implementing HAS from the start. Rebuilding your entire compliance framework during a growth phase is significantly more disruptive than building it right initially.
The safe default: when in doubt, implement to the higher standard. No auditor will penalise you for exceeding requirements.
Yes — and many growing companies need to. The transition from IHCS to HAS is not a complete restart, but it does require significant expansion:
Whether you operate under IHCS or HAS, the core compliance challenge is the same: maintaining documented, auditable halal controls as an ongoing operational activity — not a periodic exercise.
For IHCS companies, a digital platform can:
For HAS companies, the value multiplies:
The operational burden of HAS — particularly for companies with complex supply chains or multiple production lines — makes manual management increasingly unsustainable. The organisations that manage HAS effectively are increasingly the ones that have invested in purpose-built compliance infrastructure.
The IHCS vs HAS decision is determined primarily by your company size under MHMS 2020 classification. But the strategic question is broader: what level of halal management maturity does your business need?
If you are a small company selling to large manufacturers, they may expect HAS-level compliance from their supply chain. If you are growing rapidly, building IHCS today and rebuilding for HAS tomorrow is more expensive than building HAS once.
The framework you implement should reflect not just where your company is today, but where it is heading.
MHMS 2020 provides two proportionate frameworks — IHCS for smaller enterprises and HAS for larger ones — to ensure that every halal-certified company in Malaysia maintains systematic, documented compliance appropriate to its scale.
Understanding which framework applies to your organisation is the first step. Implementing it as a genuine operational system — not just audit documentation — is what sustains your certification.
If you are building or upgrading your halal management system, TAQYID supports both IHCS and HAS workflows — with scalable tools for supplier monitoring, audit management, NCR tracking, and compliance reporting that grow with your organisation.
Understand the Halal Assurance System (HAS) required by JAKIM under MHMS 2020. Learn what HAS covers, who needs it, and how to build one for your organisation.
Read articleCompliance GuidesUnderstand the Malaysian Halal Management System 2020. A practical MHMS 2020 guide covering HAS, IHCS, HCP and JAKIM requirements for certified manufacturers.
Read articleReady to streamline your MHMS 2020 compliance?
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