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Summary
What the law says
Timeline
E-invoicing mandate technical details
E-Invoicing initiative
Cross-border invoices
Invoice archiving
Our advice
Get your project implemented
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Last update: 2024, May 28

E-Invoicing is currently not mandatory in Malaysia.

It will become mandatory for all invoices (B2G, B2B, B2C) following a phased roll-out starting in August 2024, through the central platform MyInvois.

What the Law Says

Current Situation

E-invoicing is currently not mandatory in Malaysia, meaning that businesses can transmit their invoices in all the usual ways:

  • Paper-based invoices
  • PDF invoices with e-signature or complete audit trail
  • EDI

Additionally, the Malaysian government, through the Malaysia Digital Economy Corporation (MDEC), is driving a national e-invoicing initiative that primarily encourages the use of the Peppol network and the Malaysian Peppol International (MY PINT) invoice format.

All invoices must be archived for 7 years.

Upcoming E-Invoicing Mandate

The government of Malaysia, by the intermediary of its tax authority, the IRBM (Inland Revenue Board of Malaysia) is going to implement an e-invoicing mandate that will apply to all types of transactions (B2G, B2B and B2C). 

Surprisingly, as described in the official guidelines, the mandate will only apply to private companies, as the public sector seems exempted from issuing e-invoices for the time being.

The mandate will gradually enter into effect depending on companies revenue:

  • August 1, 2024: mandatory for companies exceeding RM 100 million annual turnover (~20M€)
  • January 1, 2025: mandatory for companies exceeding RM 25 million annual turnover (~5M€)
  • July 1, 2025: mandatory for all companies

Under this mandate, suppliers must submit all invoices to the MyInvois central platform, either manually via a web interface or automatically through an API in UBL 2.1 format (XML or JSON).

Once the invoice content is verified, the MyInvois platform validates it and generates an e-invoice with a Unique Identifier Number (UIN) and a PDF version of the invoice with a QR code. The supplier is then responsible for delivering either (or both) to the buyer through their preferred channel.

All validated e-invoices will also be automatically archived by the IRBM and accessible through the MyInvois platform.

Timeline

E-Invoicing Mandatory - Large Companies
Large companies (turnover > RM 100M) must send electronic invoices through the MyInvois central platform
E-Invoicing Mandatory - Mid-size Companies
The e-invoicing mandate starts applying to medium-sized companies (turnover > RM 25M)
E-Invoicing Mandatory - All Companies
All invoicing transactions must be performed in an electronic way through the MyInvois central platform
Aug 1, 2024
Jan 1, 2025
July 1, 2025

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Resources

Public entity in charge of e-invoicing in Malaysia

Guidelines & technical specifications maintained by the IRBM

MyInvois is part of the MyTax portal

Comprehensive set of technical resources to interact with the MyInvois platform

Peppol Authority in Malaysia

Guidelines, certified providers & technical specifications for the use of Peppol in Malaysia

E-Invoicing Mandate - Technical Details

The following technical details focus on the upcoming e-invoicing mandate. Comprehensive guidelines and a SDK (Software Development Kit) are also maintained by the IRBM, providing more ample information.

Schema of the Malaysia e-invoicing landscape using the MyInvois central platform for validation and delivery of the invoice by the supplier
E-Invoicing in Malaysia:
invoice validation by the MyInvois central platform & invoice delivery by the supplier

E-Invoice Validation

(Steps 1 & 2 as illustrated in the schema above)

In Malaysia, all e-invoices must undergo validation by the tax authority through the MyInvois central platform before reaching their final recipient.

To submit an e-invoice to MyInvois, suppliers have two options:

  • Manual data input via a web interface: this method is suitable for small volumes and companies without automated e-invoicing solutions. The web interface is currently unavailable but will be released alongside the mandate’s first deadline on August 1, 2024.
  • Automated submission via a REST API: e-invoices submitted this way must adhere to the UBL 2.1 standard and be formatted in either XML or JSON.
All invoices must include a Tax Identification Number (TIN), an official identifier for all Malaysian taxpayers introduced in 2022 and used to properly identify all parties during the invoicing process.
 

Once validated by MyInvois, the supplier will receive an e-invoice containing a Unique Identifier Number (UIN) and a PDF version of the invoice containing a QR code.

Both the supplier and the buyer also get notified by MyInvois alerting them about the e-invoice.

E-Invoice Delivery

(Step 3 as illustrated in the schema above)

Upon validation by MyInvois, it becomes the supplier’s responsibility to ensure the invoice is delivered to the buyer. Both the supplier and the buyer are free to agree on their preferred delivery method

Typically, most companies will opt to share the PDF invoice (with the QR code) via email. But the IRBM also strongly encourages sharing the e-invoice (in XML/JSON UBL 2.1 format) containing the UIN through the Peppol network, in order to maximize the benefits of e-invoicing, such as streamlining operations and reducing manual processing through automation.

The UIN and/or the QR code then enable the buyer to verify the validity of the e-invoice on MyInvois.

Furthermore, there is a 72-hour window after the invoice validation for the supplier to cancel the invoice or for the buyer to reject it. As the buyer received a notification from MyInvois upon validation of the e-invoice, they are aware that they should expect to receive an e-invoice from their supplier very soon.

National E-Invoicing Initiative (via Peppol)

In addition to the e-invoicing mandate primarily aimed at tax reporting, the Malaysian government is promoting a (non-mandatory!) national e-invoicing initiative through the Malaysia Digital Economy Corporation (MDEC), which has published official guidelinesThis voluntary program encourages companies to adopt e-invoicing to leverage the numerous benefits of automation, such as faster processes and fewer manual errors.

Relying on the Peppol network, service providers wanting to offer Peppol services in Malaysia must be certified by the MDEC, which maintains lists of certified Peppol Service Providers and certified Peppol-Ready Service Providers are maintained. All Peppol requirements are also detailed in the Peppol Authority Specific Requirements for Malaysia.

Using the Malaysian version of the Peppol International (MY PINT) format, this initiative also allows compatibility with the e-invoicing mandate. The Peppol service provider of the invoice sender can indeed ensure compliance by sending the required data (in UBL 2.1 format) to the MyInvois portal, retrieving the UIN, and sending a MY PINT e-invoice via Peppol to the recipient.

Cross-Border Invoices

Foreign companies do not have to comply with the mandate. Rather, this responsibility falls upon the Malaysian company.

Sending Cross-Border Invoices

Sending cross-border invoices will not differ significantly from sending domestic invoices for a Malaysian company.

When a Malaysian seller invoices a foreign buyer, they must follow the mandated process by validating their e-invoice through MyInvois (steps 1 & 2) and must then send a copy of the invoice to the foreign buyer in a mutually agreed format (step 3).

The only difference stands in the fact that Malaysian businesses are not required to use the e-invoice or the PDF with QR code generated by MyInvois for foreign transactions. They can rather use the mutually agreed-upon format & channel with their foreign buyer.

Schema of the management of the sending of cross-border invoices for an business operating in Malaysia
Malaysia: sending cross-border invoices

Receiving Cross-Border Invoices

Receiving cross-border invoices introduces a bit more complexity for the Malaysian company.

When a foreign seller invoices a Malaysian buyer, the foreign seller is free to issue the invoice as they see fit (step 1).

Then, the Malaysian buyer must subsequently issue a corresponding self-invoice and submit this self-invoice to MyInvois for validation (steps 2 & 3).

Schema of the management of the reception of cross-border invoices for an business operating in Malaysia
Malaysia: sending cross-border invoices

Invoice Archiving

All e-invoices validated by the MyInvois platform will be archived automatically by the IRBM.

Suppliers and buyers then have the ability to retrieve those invoices in various formats, either using MyInvois web interface or via its API:

  • E-invoice (XML or JSON format)
  • Metadata
  • PDF invoice (via web interface only)
  • Grid (via web interface only)

Resources

Public entity in charge of e-invoicing in Malaysia

Guidelines & technical specifications maintained by the IRBM

MyInvois is part of the MyTax portal

Comprehensive set of technical resources to interact with the MyInvois platform

Peppol Authority in Malaysia

Guidelines, certified providers & technical specifications for the use of Peppol in Malaysia

The Invoicing Hub Word

Malaysia is adopting a pre-clearance e-invoicing mandate akin to those in effect in Latin America

Under this approach, suppliers must initially validate their invoices through the MyInvois central platform, which then generates e-invoice and PDFs containing validation proofs. Suppliers are then free to send those verified invoices through their usual channels

While this type of mandate reduces project scale as the actual delivery of the invoice is not in scope, it falls short in harnessing the full potential of e-invoicing, likely offering minimal automation benefits.

Nevertheless, Malaysia emerges as a pioneering nation in the Asia-Pacific region to enact a comprehensive e-invoicing mandate, setting a precedent for others to follow suit. 

Moreover, the Malaysia tax authority offers clear guidelines, detailed use cases, and comprehensive technical documentation, thus easing the burden for companies falling under the mandate’s scope.

Female consultant providing explanations to a business executive on a whiteboard in the company's offices

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