The Sandakan Central Market is a key component of the Sandakan Harbour Square waterfront development, and occupies a strategic positioning on the site that allows the efficient screening off and control of the servicing areas. The central concept of the building design is the creation of a service corridor system that handles the efficient waste/drainage disposal as well as goods delivery via a layout of wet corridors that links to the main service yard. Effectively, wet service circulation is kept separated from dry public circulation at all times, with the market stalls being the interface of the service and public areas.

A simple, functional Nautical theme is adopted for the architectural design, with a protruding Fish Jetty being emphasized to provide an immediately recognizable icon for Sandakan.