e-invoice Readiness Checklist

Based on the E-Invoice Specific Guideline (Version 4.6) issued on 5 January 2026, "readiness" involves understanding the specific data requirements for different scenarios and utilizing the flexibility provided during the Interim Relaxation Period.

1. Administrative Readiness: Mandatory Data Fields

To be ready for submission, your system (like Musufa’s ERPNext) must be able to capture and validate the following details for your buyers:

• For Individual Buyers: Name, TIN, and Identification Number (MyKad/MyTentera) or Passport Number.

• Concession for Individuals: If an individual does not have a TIN, suppliers may use the General TIN (EI00000000010) alongside their MyKad/Passport number.

• Other Required Fields: Address, contact number, and SST registration number (where applicable).

2. Operational Readiness: Consolidation Strategy

The IRBM allows suppliers to consolidate transactions for buyers who do not require an e-Invoice as proof of expense. Readiness in this area means:

• Consolidation Frequency: Aggregating receipts on a monthly basis.

• Submission Deadline: Validating the consolidated e-Invoice with IRBM within seven (7) calendar days after the month end.

• Buyer Details for Consolidation: For these submissions, you must use "General Public" as the Buyer’s Name and "EI00000000010" as the Buyer’s TIN.

3. Compliance Readiness: The Interim Relaxation Period

The Government has provided a six (6)-month interim relaxation period from the mandatory implementation date of each phase to ensure a smooth transition.

• Implementation Phases:

  • Phase 1 (>RM100m): Mandatory from 1 August 2024.

  • Phase 4 (Up to RM5m): Mandatory from 1 January 2026, with a relaxation period currently in effect.

• During Relaxation: Use this time to stabilize your workflows, as the guideline confirms there are specific "e-Invoice treatments" intended for this period to aid taxpayers.

4. Technical Readiness: Prohibited Consolidation Activities

Readiness also means knowing when you cannot consolidate. You must be prepared to issue an individual e-Invoice for specific high-risk or high-value activities listed in Table 3.6. For example:

• Telecommunication Services: Effective 1 January 2026, consolidation is not allowed for postpaid plans, internet subscriptions, and the sale of electronic devices.

5. Self-Billing Readiness

If you deal with foreign suppliers or agents, you must be ready to assume the role of the "Supplier" and issue self-billed e-Invoices.

• Foreign Sellers: Since they are not mandated to implement Malaysia’s e-Invoice, you must issue a self-billed version to document the expense for tax purposes.

• Timing: For imported goods, you should issue the self-billed e-Invoice by the end of the second month following the month of customs clearance.