IRBM Issues Further Clarifications on E-Invoice Guidelines and Grace Period

The Inland Revenue Board of Malaysia (IRBM) has released updated e-invoicing guidelines, providing additional clarifications on the six-month grace (relaxation) period and the conditions for consolidated e-invoicing.

On 30 July 2024, IRBM published:

• E-Invoice Guideline Version 3.2
• E-Invoice Specific Guideline Version 3.0

These updates further explain how the gradual implementation and grace period will apply across different taxpayer groups.

Grace Period Phases

The grace (relaxation) period is structured in phases based on annual turnover or revenue:

• 1 August 2024 – 31 January 2025
  Taxpayers with a turnover exceeding RM 100 million
• 1 January 2025 – 30 June 2025
  Taxpayers with turnover exceeding RM 25 million up to RM 100 million
• 1 July 2025 – 31 December 2025
  All remaining taxpayers

Allowances During the Grace Period

During the applicable grace period, taxpayers may benefit from the following flexibilities:

• Issuing consolidated e-invoices for all activities and transactions
• Issuing consolidated e-invoices even for industries or activities that normally require transaction-level invoices
• Issuing consolidated self-billed e-invoices for all self-billing scenarios
• Flexible input for product or service descriptions and reference numbers
• Using receipt, statement, or bill reference numbers where required for buyer transactions or periodic billing
• No requirement to issue individual e-invoices or self-billed e-invoices, even if requested by buyers or suppliers, provided consolidated rules are followed

Timing for Submission of Consolidated E-Invoices

Consolidated e-invoices and consolidated self-billed e-invoices must be submitted to LHDN within seven calendar days after the end of the month in which the transactions occurred.

Penalty Treatment

No penalties will be imposed for non-compliance as long as taxpayers comply with the consolidated e-invoicing rules during the grace period.

Exemption from E-Invoicing

Taxpayers with annual turnover or revenue below RM 150,000 are exempt from issuing e-invoices, including self-billed e-invoices. Detailed conditions and criteria will be provided in the General FAQ.