e-Invoicing in Malaysia: An Essential Guide for Your Business

By 2025, Malaysia’s financial landscape will be significantly reshaped by e-invoicing, thanks to the Inland Revenue Board’s MyInvois Portal (IRBM). As e-invoicing becomes a cornerstone for efficiency and compliance, CFOs and finance leaders need to stay ahead of the curve.

This guide explores everything you need to know about e-invoicing in Malaysia—from its foundational principles and compliance essentials to the practical benefits of automation. Discover how this digital shift can transform invoicing processes and drive businesses forward.

What is an E-Invoice?

An e-invoice is an electronic version of a traditional paper invoice, formatted in a structured way that allows it to be read and processed automatically by financial systems. Unlike PDF or paper invoices, which require manual entry, e-invoices are designed to be machine-readable, facilitating seamless integration between different accounting systems.

Key Features of an E-Invoice

1. Legal Compliance: E-invoices must adhere to the specific requirements set by the relevant tax authorities, such as the Inland Revenue Board of Malaysia (IRBM), ensuring they meet local regulations and standards.
2. Structured Format: E-invoices are typically formatted in XML or JSON, ensuring a standardized structure that facilitates automated processing and integration with financial systems.
3. Digital Transmission: E-invoices are transmitted electronically from the supplier’s system directly to the buyer’s system, eliminating manual intervention and reducing the potential for errors.

Example: A Malaysian company sends an e-invoice for its services. The e-invoice is automatically delivered to the client's accounting system, where it is processed immediately. This automation cuts down on manual errors and speeds up payment, making the entire process more efficient for both parties.

What Does an E-Invoice Contain?

An e-invoice includes all the necessary data required for invoicing, but in a format that ensures compatibility and easy processing by electronic systems. Below is a breakdown of the typical contents of an e-invoice:

Example: A technology services firm in Kuala Lumpur sends an e-invoice containing all these elements to a corporate client. The structured format ensures that the client's ERP system can automatically parse and enter the invoice data, reducing processing time and improving accuracy.

Types of E-Invoice Documents for Malaysia

Different business transactions require various types of invoicing documents. In Malaysia, the e-invoicing system supports several document types:

1. Standard Invoice: The most common type, used for regular sales transactions.
2. Credit Note: Issued when a reduction in the amount payable is necessary, such as in the case of returned goods or services not rendered.
3. Debit Note: Used when an increase in the amount payable is required, often due to errors in the original invoice.
4. Proforma Invoice: A preliminary invoice that outlines the expected costs before a sale is finalized.

Use Case: A supplier sends a standard e-invoice for a product delivery. However, a discrepancy in the order is identified, and a credit note is issued through the e-invoicing system to adjust the amount.

What is the Inland Revenue Board of Malaysia (IRBM)?

The Inland Revenue Board of Malaysia (IRBM) is the central agency in Malaysia tasked with overseeing tax administration. It manages the collection of various taxes, such as income tax, corporate tax, and goods and services tax (GST), and ensures that tax laws are followed across the country. The IRBM is pivotal in implementing and enforcing tax regulations, including those related to e-invoicing, which is a part of Malaysia’s push towards digital modernization in the financial sector.

IRBM’s Role in E-Invoicing:

• Regulation: The IRBM establishes the standards and technical requirements for e-invoicing to ensure consistency and reliability. This involves defining the formats (such as XML or JSON), data fields, and the processes that businesses must follow to issue and receive e-invoices.
• Compliance: The IRBM ensures that businesses adhere to e-invoicing rules and regulations. This includes providing guidance on how to integrate e-invoicing into existing financial systems, setting deadlines for compliance, and offering support for businesses transitioning to the new system.
• Enforcement: To maintain the integrity of the e-invoicing system, the IRBM monitors compliance and enforces regulations. This includes conducting audits, addressing non-compliance issues, and imposing e-invoicing penalties in Malaysia for failures to comply with e-invoicing requirements. 

IRBM’s MyInvois Portal

The MyInvois Portal is the IRBM’s official platform designed for the management and processing of e-invoices. This portal is central to Malaysia's e-invoicing system, ensuring that all e-invoices meet regulatory standards before they are accepted.

Key Features of MyInvois Portal:

1. Validation: The portal automatically checks each invoice against regulatory requirements, verifying essential details such as tax identification numbers, invoice amounts, and compliance with the format specified by the IRBM.

2. Real-Time Processing: Invoices submitted through the MyInvois Portal are processed and validated quickly, allowing businesses to receive immediate feedback on their submissions. This ensures that any discrepancies or errors are identified and addressed promptly.

3. Integration: The portal supports Application Programming Interfaces (APIs), enabling seamless integration with business ERP systems. This API integration in Malaysia facilitates the automatic transmission of invoices from business systems to the MyInvois Portal, streamlining the invoicing process and reducing manual data entry.

The MyInvois Portal represents a significant step towards digital transformation in Malaysia’s tax administration, providing a robust platform for efficient and compliant e-invoicing.

Who Will Be Required to Comply for E-Invoicing in Malaysia?

The e-invoicing mandate in Malaysia applies to all taxpayers engaged in commercial activities within the country. This includes both businesses and specific non-business transactions. Here are the categories of entities required to comply with e-invoicing requirements:

1. Corporations

2. Associations

3. Bodies of Persons

4. Branches

5. Business Trusts

6. Cooperative Societies

7. Limited Liability Partnerships

8. Partnerships

9. Property Trust Funds

10. Property Trusts

11. Real Estate Investment Trusts

12. Representative Offices and Regional Offices

13. Trust Bodies

14. Unit Trusts

Malaysia e-Invoicing compliance checklist:

• System Readiness: Verify that your accounting software is compatible with e-invoicing.

• Training: Provide training for staff on the new e-invoicing procedures and compliance requirements.

• Integration: Ensure your system is integrated with the MyInvois Portal for efficient submission and validation of e-invoices.

This broad application ensures that all relevant entities are aligned with the e-invoicing regulations, promoting a consistent and transparent invoicing process across various sectors.

What Types of Transactions Are Covered in the E-Invoicing Requirements?

The e-invoicing requirements in Malaysia span a variety of transaction types, each critical for maintaining a streamlined, transparent invoicing process. Here's how they apply across different scenarios:

1. B2B (Business to Business): E-invoicing in the B2B context involves transactions between two companies. For example, a supplier of raw materials issues an e-invoice to a manufacturer for a large shipment of components. This type of e-invoicing ensures that both parties have accurate and up-to-date records of their transactions, reducing administrative errors and streamlining the reconciliation process. The automatic nature of e-invoicing helps in avoiding manual data entry and minimizes the risk of discrepancies.

2. B2G (Business to Government): When businesses provide goods or services to government entities, e-invoicing facilitates a more efficient and compliant invoicing process. For instance, a company contracted to supply office equipment to a government agency would submit an e-invoice through the designated portal. This system ensures that the invoicing meets all regulatory standards and speeds up the payment process, benefiting both the business and the government agency by providing clear, traceable documentation of transactions.

3. B2C (Business to Consumer): In the B2C scenario, e-invoicing applies to transactions where businesses directly invoice individual consumers. An online retailer, for example, generates e-invoices for each purchase made on its platform. This process helps in providing consumers with immediate and accurate billing information, enhances the efficiency of the transaction process, and supports better record-keeping for both the consumer and the business.

By covering these transaction types, Malaysia’s e-invoicing system ensures that various business activities are efficiently managed, aligning with regulatory requirements and fostering transparency across the commercial landscape.

• Early Adoption: Taxpayers who are ready can choose to adopt e-invoicing before their designated implementation date.
• Annual Turnover Reference: Turnover for 2022 can be verified from:
  • Audited financial statements for the year ending 2022, or
  • Tax returns (e.g., Form C, Form B, Form PT) for the year of assessment 2022 filed with the IRBM.
• Pro-rated Turnover: For taxpayers with a financial year differing from the standard 12-month period due to a change in accounting year end, turnover will be adjusted to 12 months for determining the e-invoicing implementation date.

Key Actions Before Deadlines:

1. System Upgrades: Confirm that your invoicing software meets compliance requirements.
2. Staff Training: Prepare your team to manage the new e-invoicing system.
3. Process Review: Update your invoicing processes to align with the new regulations.

Benefits of E-Invoicing in Malaysia

E-invoicing brings multiple advantages to businesses operating in Malaysia. Here’s a closer look at how each benefit contributes to improved business operations:

1. Increased Efficiency: E-invoicing automates the invoicing workflow, allowing businesses to move from manual processes to a streamlined digital system. This automation significantly reduces the time spent on generating, sending, and managing invoices. Businesses can handle higher volumes of transactions without a corresponding increase in administrative overhead, leading to faster processing and reduced workload for finance teams.

2. Enhanced Accuracy: By eliminating the need for manual data entry, e-invoicing reduces the risk of human errors. Automated systems ensure that invoice details are consistent and accurate, which minimizes discrepancies and the need for corrections. This accuracy is crucial for maintaining reliable financial records and preventing disputes with clients or suppliers.

3. Faster Payments: E-invoicing speeds up the invoicing cycle by facilitating quicker transmission of invoices between businesses. This efficiency helps accelerate payment processing times, as electronic invoices are received instantly and can be processed immediately. Faster payments enhance cash flow and financial stability, allowing businesses to manage their resources more effectively.

4. Cost Savings: Transitioning to e-invoicing cuts costs related to paper, printing, and postage. By reducing reliance on physical documents, businesses save on materials and mailing expenses. Additionally, e-invoicing decreases storage costs associated with maintaining paper records and the time required for physical document handling.

5. Improved Compliance: E-invoices are easier to track and audit compared to traditional paper invoices. The digital format allows for better organization and retrieval of invoicing records, which simplifies compliance with tax regulations. Businesses can easily generate reports and access historical data for audits, ensuring they meet regulatory requirements efficiently and with less effort.

These benefits collectively contribute to a more streamlined, cost-effective, and compliant invoicing process, supporting overall business efficiency and financial health.

The e-Invoicing Process in Malaysia

With the mandatory e-invoicing solution for Malaysia set to come into effect on August 1, 2024, businesses need to understand the process thoroughly to ensure compliance. The e-invoicing system aims to streamline invoice management and improve accuracy in tax reporting. Below is a detailed explanation of each step in the e-invoicing process.

Step 1: Generate the Invoice

The first step in the e-invoicing process is generating the invoice. This involves creating a digital invoice that contains all the necessary details of the transaction.

Details:

• Invoice Data: Ensure that the invoice includes key information such as the seller’s and buyer’s details, invoice number, date of issue, description of goods or services, quantity, unit price, total amount, and applicable taxes.
• Format: The invoice must be generated in a format that complies with the specifications outlined by the Lembaga Hasil Dalam Negeri (LHDN). Typically, this will be an XML or JSON format, as specified by the Malaysian e-invoicing system.
• Software Requirements: Use e-invoicing software or an ERP system that supports the creation of compliant e-invoices. The LHDN Software Development Kit (LHDN SDK) provides guidelines and tools for generating invoices in the required format.

Step 2: Send the Invoice to the LHDNM for Validation

After generating the invoice, it needs to be sent to the LHDN’s MyInvois system for validation. This step ensures that the invoice meets all regulatory requirements and is formatted correctly.

Details:

• Submission: The invoice is transmitted electronically to the MyInvois system via an API (Application Programming Interface) provided in the LHDN SDK.
• Validation Checks: MyInvois performs various validation checks, including syntax validation, data validation, and business rule validation to ensure the invoice is accurate and compliant.
• Response: Upon successful validation, the system returns a response code indicating that the invoice is approved or if there are any errors that need correction.

Step 3: Digital Signature Attachment

Once the invoice is validated, it must be digitally signed to ensure its authenticity and integrity. The digital signature confirms that the invoice is genuine and has not been tampered with.

Details:

• Digital Signature: Attach a digital signature to the invoice using a digital certificate issued by a recognized certification authority. This step is crucial for verifying the identity of the issuer and ensuring the invoice’s validity.
• Integration: Many e-invoicing systems and ERP solutions provide built-in functionality for digital signatures. Ensure that your system integrates this feature or use an external service that complies with Malaysian regulations.
• Validation of Signature: The digital signature must be validated by the recipient to confirm its authenticity and that the invoice has not been altered after signing.

Step 4: Issue the Invoice

After attaching the digital signature, the invoice is ready to be issued to the recipient. This step involves sending the final e-invoice to the buyer.

Details:

• Delivery Method: The e-invoice is typically sent to the buyer via email or through a secure electronic portal. Ensure that the delivery method complies with the buyer’s preferences and any relevant regulations.
• Record Keeping: Keep a record of the issued invoice, including the recipient’s confirmation of receipt. This is important for tracking and audit purposes.
• Compliance: Verify that the invoice is issued in accordance with any additional requirements set by the LHDN or other regulatory bodies.

Step 5: Archive the Invoice

The final step in the e-invoicing process is archiving the invoice. Proper archiving ensures that invoices are preserved for future reference and compliance with legal requirements.

Details:

• Storage: Store the invoice electronically in a secure, accessible manner. This may involve using cloud storage, on-premises servers, or a combination of both, depending on the organization’s needs.
• Retention Period: Follow the legal retention period for invoices as stipulated by Malaysian regulations. Typically, invoices must be kept for a minimum period of seven years.
• Access Control: Implement access controls to ensure that only authorized personnel can access archived invoices. This is important for maintaining confidentiality and integrity.

E-Invoice Malaysia Penalties

Non-compliance with e-invoicing rules can result in fines of RM200 to RM20,000, imprisonment for up to 6 months, or both. These penalties apply per instance of non-compliance.

Penalty for Not Issuing Tax Invoices

Even before e-invoicing is mandatory, failure to issue tax invoices under Sales & Service Tax in Malaysia  can result in fines up to RM 30,000 or imprisonment for up to 2 years.

Understanding and complying with e-invoicing regulations is essential for avoiding e-invoicing penalties in Malaysia and ensuring smooth business operations. Early adoption and preparation can provide numerous benefits.

Continuous Transaction Control (CTC) Model

The CTC model is essential in modern e-invoicing systems, including Malaysia's. It ensures real-time validation and oversight of transactions, enhancing accuracy and compliance.

Key Features:

• Real-Time Validation: Invoices are validated instantly, reducing errors and ensuring compliance.

• Integrated Monitoring: Continuous tracking helps detect issues and prevent fraud.

• Streamlined Compliance: Automates compliance processes, easing regulatory adherence.

• Enhanced Accuracy: Minimizes manual entry errors through automated checks.

MyInvois Portal Hosted by the IRBM

The MyInvois Portal, managed by the Inland Revenue Board of Malaysia (IRBM), is a cornerstone of the country's e-invoicing system. This portal centralizes the process of submitting, validating, and managing e-invoices, ensuring adherence to Malaysian tax regulations and enhancing overall operational efficiency. Here’s a detailed look at its key features and their benefits:

Key Features of MyInvois Portal:

1. Real-Time Validation: The MyInvois Portal performs immediate validation of each submitted invoice, comparing it against the standards set by the IRBM. This real-time checking helps prevent errors and ensures compliance with tax laws before invoices are processed. By catching issues early, businesses can avoid delays and reduce the risk of compliance-related penalties.

2. User-Friendly Interface: Designed with user experience in mind, the MyInvois Portal features an intuitive interface that simplifies the e-invoicing process. Businesses of all sizes can easily navigate the portal, upload invoices, and track their status. This ease of use helps reduce the learning curve and operational disruptions associated with adopting new technology.

3. API Integration: One of the portal’s standout features is its support for API integration. Businesses can seamlessly connect their existing Enterprise Resource Planning (ERP) or accounting systems with the MyInvois Portal. This integration automates the submission and validation processes, eliminating the need for manual data entry and ensuring that invoices are handled efficiently and accurately. By integrating their systems, businesses can streamline their invoicing workflows and enhance data accuracy.

Overall, the MyInvois Portal is designed to facilitate a smooth transition to e-invoicing, offering businesses the tools they need to comply with regulatory requirements while improving their invoicing processes.

Application Programming Interface (API) for E-Invoicing

Application Programming Interfaces (APIs) are vital in the e-invoicing landscape, Malaysia e-invoicing API integration facilitating seamless interaction between a company’s internal systems and the MyInvois Portal. This integration is essential for businesses looking to streamline their invoicing processes, comply with regulatory standards, and enhance overall operational efficiency.

Role of APIs in E-Invoicing

APIs are crucial in the e-invoicing landscape, enabling seamless integration between a company's internal systems and the MyInvois Portal. This connection automates invoice data exchange, streamlining operations and ensuring compliance with regulatory standards.

Role of APIs

• Automation: Streamlines invoicing by reducing manual entry and errors.

• Real-Time Updates: Provides instant feedback on invoice status, ensuring quick issue resolution.

• Scalability: Handles large volumes of transactions with ease.

Importance of API Integration

• Efficiency: Saves time and reduces administrative workload.

• Accuracy: Minimizes errors in data transmission.

• Speed: Accelerates invoice processing and payments.

• Compliance: Ensures all invoices meet regulatory standards.