# e-Invoice, MyInvois and Your Statutory Records

> Three record-keeping regimes now run in parallel — Companies Act 2016 s.245, Income Tax Act 1967 s.82 and s.82A, and MyInvois validated documents. Their retention clocks differ, and a validated e-Invoice is not automatically a sufficient s.245 record.

- Category: accounting
- Language: en
- Status: published
- Updated: 2026-07-20
- Canonical: https://negaraku.md/en/accounting/e-invoice-accounting-records

---

The most common misconception in Malaysian finance functions right now is that
MyInvois has taken over the filing cabinet. It has not. LHDN says so itself, in one
sentence buried in step eight of its own guideline, and almost nobody has read it
against the Companies Act.

Three record-keeping regimes now run over the same transaction, and they do not agree
on what has to be kept, where, in what form, or for how long.

## The three regimes

| | Companies Act 2016 | Income Tax Act 1967 | MyInvois |
| --- | --- | --- | --- |
| Provision | s.245 | s.82, s.82A, s.82C | e-Invoice Guideline v4.7, issued under s.134A ITA |
| What must be kept | Accounting and other records that sufficiently explain transactions and financial position | Sufficient records to ascertain business income, and documents to ascertain chargeable income | Nothing — IRBM stores the validated document |
| Retention clock | 7 years from **completion of the transaction** (s.245(3)) | 7 years from the **end of the year the income relates to** (s.82(1)(a)); 7 years from the **end of the year of assessment** (s.82A(1)) | No published retention commitment |
| Where | Registered office or as directors think fit (s.245(4)) | **In Malaysia** (s.82(8), s.82A(5)) | IRBM database |
| Entry deadline | 60 days from completion (s.245(2)) | 60 days from each transaction (s.82(6)) | 72 hours to reject after validation |
| Penalty | Up to RM500,000 or 3 years, or both (s.245(9)) | RM300 to RM10,000, or 1 year, or both (s.119A) | — |

Three retention anchors is not a drafting curiosity. For a transaction completed in
March 2026 by a company with a 31 December year end, the section 245 clock runs to
March 2033, the section 82 clock to the end of 2033, and the section 82A clock to the
end of 2033 by reference to year of assessment 2026. If the return for that year is
never filed, section 82(1A) restarts the clock from the end of the year in which it
eventually is — which is an indefinite obligation dressed as a seven-year one.

**Set the policy to the latest applicable date, per year, and stop trying to optimise
it.** The saving from destroying records nine months early is nothing; the cost of
being unable to substantiate a deduction is the deduction plus penalties.

## What LHDN actually says about storage

The e-Invoice Guideline (Version 4.7), published 7 July 2026 and replacing Version
4.6 of 7 December 2025, deals with storage at paragraph 2.3.7 for the MyInvois Portal
route and paragraph 2.4.6 for the API route. Both say the same thing:

> All validated e-Invoices will be stored in IRBM's database. Notwithstanding the
> storage of e-Invoice by IRBM, taxpayers are reminded to retain sufficient records
> and documentation in relation to the transaction.

That is LHDN telling you the database is not your archive. The guideline offers
retrieval of e-Invoice details through the portal or API in XML or JSON, metadata,
grid or PDF form — a convenience, not a guarantee, and not a substitute for records
you control.

## Why a validated e-Invoice is not a sufficient section 245 record

Section 245(1)(a) requires records that **sufficiently explain the transactions and
financial position** of the company and enable true and fair accounts to be prepared.
Section 245(1)(b) requires them to be kept so they can be **conveniently and properly
audited**.

A validated e-Invoice is one document, containing a defined field set, evidencing that
a supply was invoiced. It is strong evidence of that fact and nothing more. It does
not contain:

- the **contract or purchase order** that establishes the terms, and therefore the
  cut-off and the performance obligation;
- **delivery or acceptance evidence** — the goods received note, the signed timesheet,
  the milestone certificate;
- the **costing** behind the margin, or the inventory movement behind the cost of sale;
- the **judgement** behind a provision, an impairment, an accrual or a related-party
  pricing position;
- the **settlement** — the bank record proving whether and when it was paid.

An auditor testing revenue recognition, or LHDN testing a deduction, works through
that chain. The e-Invoice is one link.

Four specific gaps are worth naming because they recur.

**Consolidated e-Invoices aggregate.** Where a business submits a consolidated
transaction invoice under s.82C(7), the validated document is a monthly summary. It
does not identify buyers or individual sales, so it cannot on its own explain the
transactions behind it. Note also **s.82(2B)**: a person required to submit a
consolidated transaction invoice **must still issue a receipt for every sum
received**, notwithstanding the general dispensation in s.82(2A).

**Self-billed e-Invoices** record the buyer's view of a supply. The supporting
evidence of what was actually supplied sits with the buyer, not in the document.

**Rejections and cancellations** happen in a 72-hour window and leave a state change
that has to be reconcilable in your ledger. If your system stores only the final
document, you cannot explain the movement.

**Substitute e-Invoices** issued under s.82C(8) to correct an error must be issued
within three days of the defective document. You need both documents and the reason
for the substitution, not just the corrected one.

## Where the e-Invoice does replace something

To be fair to the regime, it removes one obligation cleanly. **Section 82(2A)**
provides that where a person issues an e-Invoice under s.82C, the printed serially
numbered receipt requirement in s.82(1)(b) may be dispensed with. That requirement
applies where gross takings exceed RM150,000 from the sale of goods or RM100,000 from
services, so it caught a large number of small businesses. For those issuing
e-Invoices per transaction, it is gone.

For those relying on consolidation, as noted, s.82(2B) takes it back.

## The format and location conditions people miss

Section 82(7) of the Income Tax Act 1967 imposes conditions the Companies Act does not:

- records kept electronically must be retained in an **electronically readable form**
  and kept so as to be **readily accessible and convertible into writing**; and
- where records originally kept manually were later converted to electronic form, the
  **original manual records must still be retained** in their original form.

And **s.82(8)**: all records relating to a business in Malaysia must be **kept and
retained in Malaysia**. Section 82A(5) says the same for documents relating to income
in Malaysia. A cloud accounting platform hosted offshore, integrated to MyInvois
through a middleware provider, satisfies neither statute by itself. You need a
Malaysian retained set.

## Common mistakes

- **Treating MyInvois as the archive.** LHDN's own guideline says it is not.
- **Applying one seven-year rule.** There are three clocks with three anchors, plus
  the open-ended s.82(1A) extension where no return has been filed.
- **Retaining the PDF visual representation only.** It is a rendering. Retain the
  submitted XML or JSON and the validation response, which carry the unique identifier
  number and the validation state.
- **Assuming the e-Invoice satisfies SST invoicing.** Section 82C(4) says that where
  the particulars conflict with another written law's invoice requirements, the
  e-Invoice is valid for Income Tax Act purposes only.
- **Discarding rejected or cancelled documents.** The state history is part of what
  explains the ledger.
- **Letting the middleware provider be the system of record.** If the contract ends,
  the obligation does not.

## What's next

Two things follow. If your records or your ERP sit outside Malaysia, section 82(8) and
section 245(5) set conditions that most regional shared-service arrangements do not
meet as designed. And if you have not yet mapped what section 245 requires beyond the
invoice, that is the list your retention policy should be built from — not the field
list in the e-Invoice specification.

## Sources

- e-Invoice Guideline (Version 4.7) — https://www.hasil.gov.my/wp-content/uploads/IRBM-e-Invoice-Guideline.pdf (LHDN)
- Income Tax Act 1967 (Act 53), reprint as at 21 May 2024 — https://www.hasil.gov.my/wp-content/uploads/20240521-akta-cukai-pendapatan-1967-akta-53.pdf (LHDN)
- Companies Act 2016 (Act 777), reprint as at 1 August 2022 — https://www.ssm.com.my/Pages/Legal_Framework/Document/Companies%20Act%202016_Akta%20777_BI%20(1.8.2022).pdf (SSM)
- e-Invoice Specific Guideline (Version 4.8) — https://www.hasil.gov.my/wp-content/uploads/IRBM-e-Invoice-Specific-Guideline.pdf (LHDN)

---
Source of truth: https://github.com/negaraku-md/NegaraKu.md
License: CC BY-SA 4.0