Getting an undocumented child into a Sabah government school: what the KPM circular actually says

Every year in Sabah, families walk into a primary school with a child who has no birth certificate, no MyKid, and sometimes no passport — and walk out being told the school “cannot accept” the child. The parent or guardian goes home defeated, and another year of the child’s education is lost.

What most families are never told is that the Ministry of Education already has a written procedure for exactly this situation. It is set out in Surat Pekeliling Ikhtisas Bil. 3/2018 — Pengurusan Murid Bukan Warganegara di Sekolah Kerajaan dan Sekolah Bantuan Kerajaan. The circular has been in force for eight years. Its existence is simply not well-publicised at the school gate.

This note explains, in plain terms, how the circular works — particularly for children in the care of a Malaysian citizen who is not their biological parent, which is the most common situation we see in Sabah.

The legal starting point

Two instruments sit behind an undocumented child’s right to attend school:

The Zero Reject Policy (2019) directs that no child of schooling age should be turned away from a government school purely for want of documentation. The policy is a statement of principle; it does not, by itself, tell the headmaster what paperwork to accept.

The KPM Bil. 3/2018 circular is the paperwork. It creates four admission pathways for non-citizen children, depending on the child’s status. For a child living with a Malaysian guardian — an aunt, a grandparent, a foster family, a community member who has taken the child in — the relevant pathway is Paragraph 3.1(c).

The Para 3.1(c) pathway, in order

Step 1 — The JKM letter. Before the school, before the form, go to the nearest Pejabat Kebajikan Masyarakat Daerah (PKMD) and apply for a Surat Akuan Penjagaan Kanak-Kanak. This is the gatekeeper document; nothing else moves without it. JKM will typically want to see the guardian’s MyKad, any police report about how the child came into the guardian’s care, a statutory declaration by the guardian, and often a home visit or interview. Expect the process to take a few weeks.

Step 2 — Borang PU(A) 275. This is the formal admission application under the Education (Admission of Pupils to Government and Government-Aided Schools) Regulations 1998. Three copies. Part I is filled by the guardian; Part II is filled by the headmaster of the chosen school. The form is available from the PPD (Pejabat Pendidikan Daerah) or the school itself.

Step 3 — Submit to the school. The guardian hands in the form together with the JKM letter, a copy of the guardian’s MyKad, any police report and SD already prepared, and a short covering letter explaining why a birth certificate or passport does not exist.

Step 4 — School → PPD → JPN Sabah. The school forwards the application up the chain. Final approval rests with Jabatan Pendidikan Negeri Sabah.

Step 5 — Pay the prescribed fee. RM120 per year for primary school, RM240 per year for secondary school.

Step 6 — Use the two-year grace period. Paragraph 4 of the circular gives the guardian two years from admission to complete the child’s identity documentation — late birth registration under the Births and Deaths Registration Act, adoption proceedings where appropriate, or a passport application in the child’s country of citizenship. School fees continue to be payable during this period.

The gap between policy and the school gate

Even with the circular and the Zero Reject Policy, enforcement is inconsistent. Some schools admit a child on the spot once the JKM letter is produced; others refer the family to the PPD; a few still refuse and ask for documents the circular does not require. Part of the reason is that the circular is internal to KPM and is not routinely given to parents. The JKM letter, held in the guardian’s hand, is often the single most persuasive piece of paper — because it tells the headmaster that another arm of government has already verified the guardianship.

In our experience, applications move faster when the JKM letter is accompanied by a short written explanation from a lawyer, a legal aid centre, or an NGO: not because the law requires it, but because it signals that the family has support and that the paperwork has been checked. Where a school still refuses, the next step is a written complaint to the PPD and, if necessary, to JPN Sabah citing the circular by name.

A note for guardians

If you are caring for a child who is not yours by birth and the child is of schooling age, the most useful thing you can do Every year in Sabah, families walk into a primary school with a child who has no birth certificate, no MyKid, and sometimes no passport — and walk out being told the school “cannot accept” the child. The parent or guardian goes home defeated, and another year of the child’s education is lost.

What most families are never told is that the Ministry of Education already has a written procedure for exactly this situation. It is set out in Surat Pekeliling Ikhtisas Bil. 3/2018 — Pengurusan Murid Bukan Warganegara di Sekolah Kerajaan dan Sekolah Bantuan Kerajaan. The circular has been in force for eight years. Its existence is simply not well-publicised at the school gate.

This note explains, in plain terms, how the circular works — particularly for children in the care of a Malaysian citizen who is not their biological parent, which is the most common situation we see in Sabah.

The legal starting point

Two instruments sit behind an undocumented child’s right to attend school.

The Zero Reject Policy (2019) directs that no child of schooling age should be turned away from a government school purely for want of documentation. The policy is a statement of principle; it does not, by itself, tell the headmaster what paperwork to accept.

The KPM Bil. 3/2018 circular is the paperwork. Paragraph 3.1 of the circular addresses children taken in by a Malaysian citizen — whether by formal adoption, court-ordered guardianship, or welfare-verified care. It accepts any of three documents as proof: (a) a Sijil Pengangkatan from the Jabatan Pendaftaran Negara, (b) a court order for custody, or (c) a Surat Akuan Penjagaan Kanak-Kanak from the Jabatan Kebajikan Masyarakat. For the informal arrangements most common in Sabah — where a relative, foster family or community member has simply taken the child in — the realistic route is (c), the JKM letter.

The pathway, in order

Step 1 — The JKM letter. Before the school, before the form, go to the nearest Pejabat Kebajikan Masyarakat Daerah (PKMD) and apply for a Surat Akuan Penjagaan Kanak-Kanak. This is the gatekeeper document; nothing else moves without it. JKM will typically want to see the guardian’s MyKad, any police report about how the child came into the guardian’s care, a statutory declaration by the guardian, and often a home visit or interview. Expect the process to take a few weeks.

Step 2 — The admission form. The formal admission application is made under the Peraturan-Peraturan Pendidikan (Penerimaan Masuk Murid Ke Sekolah, Penyimpanan Daftar dan Syarat Bagi Pengekalan Murid Belajar di Sekolah) 1998 [PU(A) 275/1998]. The prescribed form (three copies) is filled in two parts — Part I by the guardian, Part II by the headmaster of the chosen school. The form is obtained from the PPD (Pejabat Pendidikan Daerah) or the school itself.

Step 3 — Submit to the school. The guardian hands in the form together with the JKM letter, a copy of the guardian’s MyKad, any police report and statutory declaration already prepared, and a short covering letter explaining why a birth certificate or passport does not exist.

Step 4 — School PPD JPN Sabah. The school forwards the application up the chain. Final approval rests with the Jabatan Pendidikan Negeri Sabah.

Step 5 — Pay the prescribed fee. RM120 per year for primary school, RM240 per year for secondary school.

Step 6 — Use the two-year grace period. Paragraph 4 of the circular gives the guardian two years from admission to complete the child’s identity documentation — late birth registration under the Births and Deaths Registration Act, adoption proceedings where appropriate, or a passport application in the child’s country of citizenship. School fees continue to be payable during this period.

The gap between policy and the school gate

Even with the circular and the Zero Reject Policy, enforcement is inconsistent. Some schools admit a child on the spot once the JKM letter is produced; others refer the family to the PPD; a few still refuse and ask for documents the circular does not require. Part of the reason is that the circular is internal to KPM and is not routinely given to parents. The JKM letter, held in the guardian’s hand, is often the single most persuasive piece of paper — because it tells the headmaster that another arm of government has already verified the guardianship.

In our experience, applications move faster when the JKM letter is accompanied by a short written explanation from a lawyer, a legal aid centre, or an NGO: not because the law requires it, but because it signals that the family has support and that the paperwork has been checked. Where a school still refuses, the next step is a written complaint to the PPD and, if necessary, to JPN Sabah citing the circular by name.

A note for guardians

If you are caring for a child who is not yours by birth and the child is of schooling age, the most useful thing you can do today is not to apply to the school. It is to go to your nearest Pejabat Kebajikan Masyarakat and begin the Surat Akuan Penjagaan application. Everything else follows from that letter.

Note: the Education (Amendment) Act 2025, which extends compulsory education to the secondary level, was passed in October 2025. It applies only where the child is a Malaysian citizen and does not affect the admission pathway described above. As at the date of this note, the Act has been assented and gazetted but is not yet in force — commencement awaits a separate order by the Minister under section 1(2). is not to apply to the school. It is to go to your nearest Pejabat Kebajikan Masyarakat and begin the Surat Akuan Penjagaan application. Everything else follows from that letter.

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