Key Updates: Malaysia e-Invoice Guideline Version 2.3

In Malaysia, the landscape of invoicing is evolving rapidly with the advent of electronic invoicing (e-Invoicing), driven by the country’s tax authority, the Inland Revenue Board of Malaysia (IRBM). Keeping abreast of these changes is essential for businesses and taxpayers to ensure compliance with the latest guidelines and regulations.

The recent release of the e-Invoice Guideline (Version 2.3) and e-Invoice Specific Guideline (Version 2.1) on 6 April 2024 by the IRBM marks significant updates to the regulatory framework governing e-Invoicing practices. These guidelines, issued under Section 134A of the Income Tax Act, 1967, introduce notable amendments and clarifications aimed at streamlining e-Invoice processes and enhancing transparency in tax transactions.

Here we’ll discuss the updates and changes from the latest Malaysia e-Invoicing guidelines, offering insights into the changes affecting various aspects of e-Invoicing procedures. From exemptions to mandatory fields, validation processes to consolidation practices, and considerations for cross-border transactions, we’ll examine the implications of these revisions on businesses and individuals operating in Malaysia’s tax ecosystem.

Here are the latest Malaysian e-Invoicing updates:

• Version 2.3 of the e-Invoice Guideline removes “Scholarship” from the list of income or expense exempted from e-Invoice (including self-billed e-Invoice).

• Creation and Submission of e-Invoice via MyInvois Portal– For Batch upload, only pre-defined Microsoft Excel spreadsheet will be allowed with some restriction on number of invoices.
• e-Invoice Validation – IRBM Unique Identifier Number, date and time of validation, and validation link will be assigned to the validated e-Invoice.
• Reporting and Dashboard Services for Taxpayers – CSV report is removed from the latest update. Essential invoice details can be requested and retrieved by suppliers as well as buyers in XML/Json (bulk or single), meta data, grid and PDF format except CSV.

• API response for e-Invoice validation will now include the IRBM Unique Identifier Number, validation date and time, and information required to generate a validation link.
• Intermediaries will need to create a validation link themselves as there will be no direct link or QR code provided.
• The Notifications API Section has been completely removed, as notifications will be automatically sent to both the Supplier and Buyer upon successful validation of the e-Invoice.
• CSV report and PDF formats have been eliminated.
• Essential invoice details can now be retrieved via API in XML/JSON format (bulk or single) along with metadata.

Field	Change
Supplier’s E-mail	Optional word added
Buyer’s E-mail	Optional word added
Original e-Invoice Reference Number	Changed from “Where Applicable” to “Mandatory where applicable”
Issuer Digital Signature	Changed to ensure integrity and non-repudiation of documents. Specifies the use of issuer’s or service provider’s digital certificate for signing the e-Invoice. Please refer to the SDK for more details on the digital certificate. Intermediaries/service providers can use their digital signature.
Currency Exchange Rate	Changed from “Where Applicable” to “Mandatory where applicable”
Tax Rate	Changed from “Mandatory if Applicable” to “Mandatory where applicable”
Total Net Amount, Rounding Amount, Total Taxable Amount Per Tax Type, Quantity, Measurement, Discount Rate, Discount Amount, Fee/Charge Rate, Fee/Charge Amount (at invoice level)	Changed from “Optional, where applicable” to “Optional”
Fee/Charge Rate, Fee/Charge Amount	Removed the word “imposed” after tax from description

Where buyer requires an e-Invoice 

• Replaced the words “individual buyers” to “individuals”
• Removed Buyer’s Email from the list of Buyer details
• Added Shipping Recipient’s details – 3.5.6
• The details to be provided by the individual Shipping Recipient for the issuance of Annexure to the e-Invoice are as follows: Name, Address, TIN, Registration/identification no/passport no.

Where buyer does not require an e-Invoice – Consolidate 

• Methods of consolidation – For branches, can be consolidated for all branches together or opt for branch wise consolidation.
• Changed from “(c) Each branch or location will submit a consolidated e-Invoice, adopting either (a) or (b) above for the receipts issued by the said branch or location.”
• To “(c) Branch(es) or location(s) to submit consolidated e-Invoice, adopting either (a) or (b) above for the receipts issued by the branch(es) or location(s).
• Added below:
  3.6.4 In order to improve the performance of the MyInvois System, the following limitations have been put in place:
  (a) maximum size of 5MB per submission;
  (b) maximum of 100 e-Invoices per submission; and
  (c) maximum size of 300KB per e-Invoice.

As such, Suppliers are allowed to split the receipts into several consolidated e-Invoices to meet the above requirements.

Some self-billed invoices can be consolidated - 3.6.5

• Kindly note that consolidation does not apply to self-billed e-Invoices, except for the following self-billed circumstances:
  (a) Acquisition of goods or services from individual taxpayers (who are not conducting a business)
  (b) Interest payment to public at large (regardless businesses or individuals)
• Removed Buyer’s Email from the list of Buyer details
• Removed Quantity from the list of Buyer Details.

Certain activities that require e-Invoice to be issued for each transaction (i.e., consolidation of e-Invoice is not allowed) 

• Luxury goods and jewellery – Added words “Taxpayers are allowed to issue consolidated e-Invoice (in the event the buyers do not request for e-Invoice) until further notice”

Where buyer requires e-Invoice 

• Added – “The statements / bills may also include adjustments to prior period’s statements / bills and payments / credit to Buyers (e.g., rebate).”
• Added - “In other word, Suppliers are allowed to include the amount owed by Buyers to the Supplier as well as payment / credit to Buyers in the same e-Invoice.” – Earlier this was covered under Self-billed e-Invoice, now added here.
  Here’s an example for better understanding:
  Jenny has been a loyal subscriber of Delca Telco Sdn Bhd’s postpaid plan for years. In appreciation of Jenny’s loyalty, Delca Telco Sdn Bhd has decided to provide a RM10 monthly rebate for a period of 24 months.
  Delca Telco Sdn Bhd is required to include the RM10 monthly rebate in the e-Invoice (in the visual representation format of statement / bill) issued to Jenny, along with the monthly plan commitment fee payable by Jenny.
• Removed Buyer’s Email, Frequency of billing[optional] and Billing Period [Optional] from the list of Buyer details

Where buyer does not require an e-Invoice – Consolidate

• Removed Buyer’s Email from the list of Buyer details
• Removed Quantity from the list of Buyer Details.

• Changed wordings from “allowed to issue” to “required to issue” and “self-billed e-Invoice will be allowed” to “buyer shall issue self-billed e-Invoice”
• Added words–
  (f) Acquisition of goods or services from individual taxpayers (who are not conducting a business) (applicable only if the other self-billed circumstances are not applicable
  (g) Interest payment, except:
  i. Businesses (e.g., financial institutions, etc.) that charge interest to public at large (regardless of businesses or individuals);
  ii. Interest payment made by employee to employer; and
  iii. Interest payment made by foreign payer to Malaysian taxpayers.
  Note that the Supplier is required to issue e-Invoice for exceptions mentioned above. This means for the above exceptions suppliers will issue a normal e-Invoice while buyers don’t have to issue a self-billed e-Invoice.
• Removed “(g) Payment/ Credit to taxpayers recorded in a statement/ bill issued on a periodic basis (e.g., rebate)” from narrative as well as table – Mostly Removed as its included in the statements on periodic basis section
• A new example has been included to illustrate a situation where self-billing isn’t necessary if the supplier isn’t mandated to issue e-Invoices yet.

Example 13 

Farhan, an employee at Perniagaan Nusa Kasih, purchases cupcakes from Mak Cik Rosa on May 29, 2025, for a client meeting. Mak Cik Rosa operates a small roadside stall near Perniagaan Nusa Kasih and provides Farhan with a handwritten receipt as she isn’t yet mandated to issue e-Invoices.

Perniagaan Nusa Kasih isn’t required nor allowed to self-bill for this expense, and they may use the handwritten receipt from Mak Cik Rosa for tax purposes. Upon the full implementation of e-Invoicing on July 1, 2025, Mak Cik Rosa will be required to issue e-Invoices for all her sales and submit them for validation by IRBM.

• New Example for individual not conducting business

Example 14 

Best Mesra Sdn Bhd has leased a new office space owned by three individuals: Kamal, Cheng, and Sunita. After discussions with the landlords, Best Mesra Sdn Bhd learns that they are non-business individuals.

Therefore, Best Mesra Sdn Bhd must act as the Supplier and issue separate self-billed e-Invoices to each property owner based on their agreed-upon proportion. 

• Example for interest payment by individual to bank, where bank needs to issue e-Invoice and no self e-Invoice by buyer

Example 15 

Adi has secured a mortgage loan from Bank Primaras at a fixed annual interest rate of 3.75%. He will be making monthly instalment payments to the bank, covering both interest and principal amounts.

As Adi is an individual making interest payments on the loan to the bank, Bank Primaras is required to issue an e-Invoice to Adi for the instalment related to the mortgage loan. This requirement is in accordance with the exception specified in Section 8.3(g)(i) of the e-Invoice Specific Guideline.

• Example for Interest payment where self-billed is required

Example 16

Cee Sdn Bhd has obtained a RM10 million loan from its parent company, Beeny Sdn Bhd, for business needs. Beeny Sdn Bhd applies an arm’s length interest rate for the loan. As per Section 8.3(g) of the e-Invoice Specific Guideline, Cee Sdn Bhd is required to act as the Supplier and generate a self-billed e-Invoice for the interest payments made to Beeny Sdn Bhd.Top of Form

• New point added for QR code on self-billed e-Invoice

8.5 As the Buyer is required to assume the role of Supplier and issue self-billed e-Invoice, the Buyer is obliged to share validated self-billed e-Invoice with the Supplier upon validation.

Where the Buyer submits the self-billed e-Invoice for IRBM’s validation via MyInvois Portal, the visual representation of the self-billed e-Invoice generated from the MyInvois Portal will include a QR code, which can be used to validate the existence and status of the e-Invoice via the MyInvois Portal.

Where the Buyer submits the self-billed e-Invoice for IRBM’s validation via API transmission, in the event the Buyer shares the visual representation of the self-billed e-Invoice to the Supplier, the Buyer is required to ensure that the QR code is embedded accordingly prior to sharing it with the Supplier.

• Additional Clarification –Table added for Buyer Tin and Registration/identification/passport for individuals and changes made in supplier details table for same Malaysian Individuals –
  (1) Actual TIN and identification no will be “000000000000” or
  (2) TIN – EI00000000010 and identification number MyKad/MyTenteraNon-Malaysian –(1) Actual TIN and identification no will be “000000000000” or

  (2) TIN – EI00000000030 and identification number passport/MyKas/MyPr

  Removed Supplier’s Email

Issuance of self-billed e-Invoice from Seller to Agent/ Dealer/ Distributor 

• Added line “In facilitating a more efficient e-Invoice issuance process as well as to ease the burden of individual Suppliers in providing TIN and identification number details, IRBM provides a concession to individual Suppliers. Please refer to Section 3.5.4 and Section 8.8 of this e-Invoice Specific Guideline for further details.”
• Removed Supplier’s Email

Timing of issuance of e-Invoice:

• Import of goods changed from “upon obtaining custom clearance” to “upon latest by the end of the month following the month of custom clearance being obtained.”
• Import of services- Lines added “Meanwhile, in relation to importation of services, self-billed e- Invoice should be issued latest by the end of the month following the month upon (1) payment made by the Malaysian Purchaser; or (2) receipt of invoice from foreign supplier, whichever is earlier.
• The determination of the aforementioned (1) and (2) is in accordance with the prevailing rules applicable for imported taxable service.
• Removed Supplier’s Email

Foreign Buyer Malaysian Seller

• Removed Buyer’s Email
• Buyer’s SST registration – NA can be added if information is not applicable, not available, or not provided

 

Domestic Distribution: 

• Removed Supplier’s Email
• Supplier’s SST registration - NA can be added if information is not applicable, not available, or not provided

• Removed Buyer’s Email
• Buyer’s SST registration – NA can be added if information is not applicable, not available, or not provided

Earlier there were three options as below – Which is now deleted 13.3 Supplier may opt to provide either of the following for the purposes of e-Invoice issuance:

• Supplier may submit the e-Invoice in the relevant foreign currency and the applicable currency exchange rate, without the RM-equivalent;
• Supplier may submit the e-Invoice in the relevant foreign currency and the applicable RM-equivalent, without the currency exchange rate; or
• Supplier may submit the e-Invoice in the relevant foreign currency, the applicable RM-equivalent along with the currency exchange rate.

New Changes Added 

• 13.3 Supplier is required to provide currency exchange rate in the e-Invoice if the said e-Invoice is required to be converted into RM-equivalent.
• 13.4 For the purposes of self-billed e-Invoice for importation of goods, the Malaysian taxpayers may use their internal currency exchange rate.

E-Invoice from Ecommerce platform provider to purchaser-

• e-commerce platform providers assume the role of Supplier in facilitating issuance of e-Invoice
• New line added – “Kindly note that the issuance of e-Invoice is for the purposes of complying with relevant tax legislation (e.g., Income Tax Act 1967, Labuan Business Activity Tax Act 1990, Petroleum (Income Tax) Act 1967) only and does not change the nature of transaction nor the commercial liability associated with the transaction.”
• Removed Buyer’s Email
• Buyer’s SST registration – NA can be added if information is not applicable, not available or not provided.

Self-billed e-Invoice by the e-commerce platform provider to Merchant and/or Service Provider-

• Removed Supplier’s Email
• Supplier’s SST registration - NA can be added if information is not applicable, not available, or not provided

E-Invoice from e-commerce platform provider to Merchant and/or Service Provider 

• Removed Buyer’s Email

• In case of Malaysian individual who provides only MYKAD/MYTENTERA, then “EI00000000010” this can be used – Here earlier the word used was buyer and hence interpretation could have been made that for B2B also TIN can be used as this, but now this clarifies that this TIN can be used only in case of Malaysian individuals.

• Removed Buyer’s Email

• Removed “Payment/ Credit to taxpayers recorded in a statement/ bill issued on a periodic basis (e.g., rebate)”

• Removed Buyer’s Email

The comprehensive revisions introduced in these guidelines touch upon various aspects of e-Invoicing practices, ranging from exemptions to mandatory fields, portal changes to API integration, and considerations for cross-border transactions. Notable changes include the removal of certain exemptions, enhancements to the MyInvois Portal functionalities, and clarification on the issuance and validation processes for e-Invoices.

Furthermore, the guidelines provide detailed insights into transactional scenarios involving individual buyers, periodic statements or bills, self-billed e-Invoices, cross-border transactions, and e-commerce transactions. These updates aim to foster greater transparency, efficiency, and accuracy in tax reporting and compliance across diverse business landscapes. By embracing electronic invoicing practices in accordance with the updated guidelines, businesses can not only streamline their operations but also contribute to a more robust and transparent tax ecosystem in Malaysia.