Latest Update on E-Invoicing

The Inland Revenue Board of Malaysia (“IRBM”) has published the following in relation to e-Invoice on 28 January 2025: -

E-Invoice Guideline (Version 4.1) to replace E-Invoice Guideline (Version 4.0)
E-Invoice Specific Guideline (Version 4.0) to replace E-Invoice Specific Guideline (Version 3.1)
Updated General / Industry Specific Frequently Asked Questions (FAQs)

The above can be downloaded from IRBM’s website at https://www.hasil.gov.my/en/e-invoice/

To recap, the mandatory e-Invoice implementation timeline will commence in phases (see below): -

Targeted Taxpayers	Implementation Dates	Interim Relaxation Period (or Grace Period) (^)
Taxpayers with an annual turnover or revenue of more than RM100 million	1 August 2024	1 August 2024 to 31 January 2025
Taxpayers with an annual turnover or revenue of more than RM25 million and up to RM100 million	1 January 2025	1 January 2025 to 30 June 2025
All other taxpayers (including new businesses commencing operations from year 2023 onwards)	1 July 2025 (less than 5 months from now)	1 July 2025 to 31 December 2025

(^) With conditions. It is important to note that non-compliance penalty will still be applicable if taxpayers do not comply with the IRBM’s requirements during the Grace Period. Due date to submit consolidated e-Invoice / self-billed e-Invoice is within seven (7) calendar days after month end.

Phase 2 – For those who opted for Grace Period

=> Due date for first consolidated e-Invoice / self-billed e-Invoice is on or before 7 January 2025.

HOW PREPARED ARE YOU?

At a minimum, businesses should focus on the following three (3) factors: -

Factors	Points to Consider
1. People	Have you formed a dedicated project team to drive and oversee the e-Invoicing implementation? Are your stakeholders (e.g. customers, suppliers, employees) made aware of their roles and responsibilities in the e-Invoice regime (even post-implementation)?
2. Process	Have you reviewed your current invoicing process to incorporate IRBM’s requirements on e-Invoice (e.g. self-billed e-Invoice)? Have you collated relevant details from suppliers and customers for purpose of completing the e-Invoice?
3. System	Have you decided on the suitable model for submission of e-Invoice (e.g. MyInvois Portal, direct integration, middleware)? What is your backup plan when the system is down?

HOW WE CAN ASSIST

No.	Scope of Services
1	Customised Awareness Training
2	Getting Ready for e-Invoicing
a	Gap Assessment (Non-IT aspect)
b	Tax Support (including post-implementation)
c	Technology / Systems Support - Assisting with Implementation (IT aspect)*

*To be agreed separately with the Technology Provider (not related / part of RSM)

Author

Anston Cheah

Executive Director, Tax

Lee Pei Fern

Senior Manager, Tax