Malaysia updates e-Invoice rules with specific guideline version 4.9

Malaysia has updated its e-Invoice framework with Specific Guideline Version 4.9, published on 7 September 2026. The update adds dedicated SVDP guidance and follows the increase of the e-Invoice exemption threshold from RM1 million to RM3 million.

The Inland Revenue Board of Malaysia (IRBM) has published e-Invoice Specific Guideline Version 4.9, dated 7 September 2026. The guideline is issued under Section 134A of the Income Tax Act 1967 and replaces Version 4.8. It complements the main e-Invoice Guideline Version 4.8, which was published on 30 August 2026.

The update comes as part of a wider series of changes to Malaysia’s e-Invoicing framework. Within a short period, IRBM updated the main e-Invoice Guideline on 30 August, the General FAQs on 4 September and the Specific Guideline on 7 September 2026. These documents should therefore be reviewed together when determining the latest requirements. The specification can be found on the following link:

https://www.hasil.gov.my/wp-content/uploads/IRBM-e-Invoice-Specific-Guideline.pdf 

One of the most important changes in Version 4.9 is the inclusion of a dedicated chapter covering the e-Invoice Special Voluntary Disclosure Programme (SVDP). It was introduced on 7 July 2026 and runs until 31 December 2027. It is designed to allow taxpayers to regularize certain e-Invoice compliance issues, including cases where e-Invoices were not submitted, were submitted with incorrect or incomplete information, or otherwise did not comply with the applicable e-Invoice requirements.

Under the program IRBM generally will not carry out e-Invoice compliance reviews or enforcement action, including penalties and prosecution, in relation to e-Invoices properly submitted under the SVDP. However, this protection does not apply where the submission itself does not meet the required specifications or where the disclosure involves fraud, deliberate default or negligence.

The SVDP also has a technical element. Taxpayers participating through system integration must use the dedicated SVDP 1.2 document version where no digital signature is used or SVDP 1.3 where a digital signature is used. These versions are specifically intended for voluntary disclosures under the programe.

Version 4.9 places this new SVDP chapter immediately after the section dealing with e-Invoice treatment during the interim relaxation period. The guideline also retains detailed guidance and annexes covering areas such as transactions with buyers, consolidated e-Invoices, periodic statements, disbursements and reimbursements, self-billing, payments to agents and distributors, cross-border transactions, profit distributions, foreign income and e-commerce.

The Specific Guideline update should also be viewed together with the important change introduced in the main e-Invoice Guideline Version 4.8: the exemption threshold has increased from RM1 million to RM3 million in annual turnover or revenue.

Under the updated rules, taxpayers with annual turnover or revenue of less than RM3 million are generally exempt from implementing e-Invoice. However, this exemption is subject to additional conditions.

In particular, the exemption does not apply where the taxpayer has a non-individual shareholder, or equivalent, with annual turnover or revenue of at least RM3 million. It also does not apply where the taxpayer is a subsidiary of a holding company meeting that threshold, or where it has a related company or joint venture with annual turnover or revenue of at least RM3 million.

This means businesses should not determine their exemption simply by checking their own turnover. Ownership and group relationships may also affect whether the RM3 million exemption can be used.

Implementation dates for new businesses

The updated guideline also clarifies the timetable for newer businesses.

Businesses that commenced operations between Year of Assessment (YA) 2023 and YA 2025 and have annual turnover or revenue of at least RM3 million are required to implement e-Invoicing from 1 July 2026.

For businesses commencing from YA 2026 onwards, implementation generally starts on 1 July 2026 or on the date operations begin, as applicable. However, if annual turnover or revenue in the first year is below RM3 million, implementation is deferred until 1 January of the second year following the year in which turnover or revenue reaches RM3 million.

The result is that companies need to monitor both current turnover and changes in turnover over time rather than treating an exemption as permanent.

In our view, the most important part of these updates is not simply the publication of another guideline version, but the change in the practical compliance population. Raising the exemption threshold to RM3 million removes a significant number of smaller businesses from mandatory e-Invoicing, including some that had already invested in implementation.

At the same time, the new SVDP chapter shows that IRBM is moving from implementation support toward a more structured approach to correcting past non-compliance. Businesses that remain within scope should therefore not interpret the higher threshold as a general relaxation of e-Invoice controls. For larger businesses, the focus should remain on data quality, correct invoice treatment and system compliance.

Implementation Impact and What Businesses Should Do

Businesses should review the latest rules rather than relying on their previous e-Invoice implementation classification:

• Check whether the business is below the RM3 million threshold and whether it meets all additional exemption conditions.
•  Review group and ownership structures, because a shareholder, parent company, related company or joint venture can prevent use of the exemption.

Businesses that have already implemented e-Invoicing but are now exempt should decide whether to stop issuing e-Invoices or continue voluntarily; no separate IRBM approval is required for eligible taxpayers.

Businesses remaining within scope should review the new SVDP rules and determine whether any historical omissions or incorrect e-Invoices need to be corrected before the programe ends on 31 December 2027.

ERP, accounting and e-Invoice solution providers should ensure that systems support the latest IRBM requirements, including the relevant SVDP document versions where voluntary disclosure functionality is required.

The source of this text above is based on the text published by VATupdate. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

Linkedin profile