Which of the two MHMS 2020 frameworks applies to your company, what IHCS requires and what it does not, a side-by-side comparison, and the upgrade path.

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.
MHMS 2020 assigns the two frameworks by industry category, not by a threshold. Article 1 of the standard states it directly: the Internal Halal Control System is bagi kegunaan industri kecil dan mikro — for small and micro industry — and the Halal Assurance System bagi kegunaan industri besar dan sederhana, for medium and large. The diagram that opens the standard shows the same split.
The standard sets no employee count and no revenue figure for either framework.
The four category names — Mikro, Kecil, Sederhana, Besar — do carry published revenue bands, but elsewhere: in MPPHM 2020 (Pindaan 2026), Bahagian III, Jadual 1. That schedule sets certification fees by industry category. It prices certification; it does not assign your framework. The two are easy to confuse because they use identical category names, and reading a fee scale as a regime rule is a common enough error to be worth naming. The fee bands themselves are in our halal certification cost guide.
If your category is genuinely borderline, the determination belongs with your certifying officer, not with a revenue line read off a table.
Article 6 of MHMS 2020 defines the IHCS by three requirements — three, and no more. The company develops an IHCS Manual meeting them, and for each one the standard points to the corresponding HAS requirement:
1. Establish a halal policy — mewujudkan polisi halal. A written statement of commitment to halal integrity, displayed and communicated across the organisation. Cross-referenced to the HAS halal policy requirement, Article 5(2).
2. Develop a raw material control and/or halal risk control procedure — prosedur kawalan bahan mentah dan/atau kawalan risiko halal. Written procedures covering the purchase, receipt and storage of raw materials, with records that can be inspected. Cross-referenced to Article 5(7) and/or 5(6).
3. Develop a traceability procedure — prosedur kebolehkesanan. A written procedure that makes product withdrawal or recall possible if halal non-conformity or contamination is found in what you have already produced. Cross-referenced to Article 5(9).
The third is the one to watch. Traceability is not a HAS-only requirement, and it is explicit in Article 6 — an IHCS audit can ask for the procedure, and a company that treated it as a large-manufacturer concern will not have one.
The items below are sensible for a small manufacturer, and some follow naturally from the three requirements above. But MHMS 2020 does not list them as IHCS requirements. Treat them as recommendations:
Designated halal person-in-charge. IHCS does not require a formal Halal Executive, but someone has to own halal matters in practice, with documented authority.
Basic process controls. Procedures to prevent cross-contamination during processing, handling, storage, and distribution. For a small bakery, documented segregation between halal and non-halal ingredients; for a small cosmetics manufacturer, raw material handling and production line controls.
Record keeping. Documented evidence of compliance activity: supplier certificates, training attendance, cleaning records, incident reports. Retrievable during a JAKIM audit.
Basic internal checks. Periodic self-checks to verify that halal controls are still functioning, short of the formal internal audit programme HAS demands.
Keeping the two lists apart is the point. Merging recommendation with requirement is how traceability — a real Article 6 requirement — disappears from summaries of IHCS.
Compared to HAS, IHCS does not mandate:
One qualification on HCP. Halal Control Point determination sits under Article 5(6), which is one of the two routes Article 6 cross-references for the second IHCS requirement. A company that satisfies that requirement through halal risk control rather than raw material control brings HCP determination with it.
This does not mean the other 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. Since the MPPHM 2020 Pindaan 2026 amendments took effect on 1 April 2026, the Halal Executive's qualification training must be completed through a programme registered with HPB JAKIM (Halal Professional Board). Refresher courses from non-registered providers no longer satisfy the requirement, even when otherwise legitimate. 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 (see our NCR management guide for the full lifecycle). 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 |
| MYeHALAL portal submissions | Required (typically simplified document set) | Required (extended set including HCP records and JKHD minutes) |
| Management review | Not required | Periodic formal review with documented actions |
| Training | Basic halal awareness | Structured programme with competency assessment |
In practice, determining whether your company falls under IHCS or HAS is not always obvious. Several situations create ambiguity:
Companies near the boundary. A company that grows out of the kecil category during its certification period finds that its framework no longer matches its category. It is worth building toward HAS requirements before the category changes, rather than discovering mid-audit that the 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.
What a Halal Assurance System is under MHMS 2020, the components JAKIM assesses, how it grades them A to D, and where HAS overlaps ISO 9001 and HACCP.
Read articleCompliance GuidesMHMS 2020 — the Malaysian Halal Management System — requirement by requirement: what each of the 13 demands, the MYeHALAL digital flow, and a pre-audit checklist.
Read articleReady to streamline your MHMS 2020 compliance?
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