Do I Need e-Invoice?我需要做电子发票吗？

What changed on 1 September 2026

The exemption threshold for LHDN e-Invoicing was raised from RM1 million to RM3 million, announced on 30 August 2026 and effective from 1 September 2026 (LHDN e-Invoice Guideline, version 4.8). It is the second increase this year — the threshold was RM500,000 until it went up to RM1 million on 1 January 2026. If you checked before September and concluded you were in scope, check again.

The part that catches small companies: the group rule

The exemption is not only about your own turnover. Under §1.6.10 of the guideline, a business below RM3 million still has to implement e-Invoicing if any of these has turnover of RM3 million or more:

• a shareholder of yours that is a company rather than a person;
• your holding company, if you are a subsidiary;
• a related company or joint venture (as defined in section 2 of the Promotion of Investments Act 1986).

So a small trading company turning over RM800,000 is exempt on its own numbers — but if it is owned by a larger company, it is not. This is exactly the kind of detail that surfaces in an audit rather than before one.

What e-Invoicing actually changes

An e-Invoice is not a PDF emailed to your customer. It is a structured document submitted to LHDN, validated in near real time, and returned with a unique identifier and a QR code. Only the validated version is a valid tax document. You can keep using invoicing software, but it has to talk to MyInvois — through the portal for low volumes, or an API integration for higher ones.

When you start

For businesses that started in 2022 or earlier, the phase is fixed on the FY2022 audited accounts or tax return, and later changes in turnover do not change the obligation.

The relaxation period

Each phase came with a penalty-free grace window, and they are not all the same length. During it you can issue consolidated e-Invoices, descriptions can be more general, and LHDN will not impose penalties under section 120 of the Income Tax Act 1967 — provided you are registered on MyInvois and genuinely working towards compliance. The phase that started on 1 January 2026 has the most room: that window was extended in April 2026 and runs to 31/12/2027. Treat it as time to get your systems right, not as an extension of the deadline.

If you are exempt

A customer who is in scope may need to self-bill for purchases from you and will ask for your business details. And because the threshold has already moved twice in one year, it is worth rechecking this once a year rather than assuming it is settled.