MyInvois Implementation Phases, Thresholds and Relaxation Dates

Two numbers decide everything: your FY2022 turnover, which fixes your phase permanently, and RM1,000,000, below which you are out of the system entirely. Everything else on this page is detail.

This page is maintained as data because the dates have moved more than once. The figures below are read off the e-Invoice Guideline version 4.7 and the e-Invoice Specific Guideline version 4.8, both published 7 July 2026.

What are the mandatory phase dates?

Phase	Targeted taxpayers	Mandatory from
1	Annual turnover or revenue above RM100 million	1 August 2024
2	Above RM25 million and up to RM100 million	1 January 2025
3	Above RM5 million and up to RM25 million	1 July 2025
4	Up to RM5 million	1 January 2026

There is no phase 5. A fifth phase for the RM150,000–RM500,000 band appeared in earlier guideline versions and is gone from version 4.7.

How is my phase determined?

Situation	Basis
You have audited financial statements	Turnover or revenue in the statement of comprehensive income for financial year 2022
You do not have audited financial statements	Annual revenue reported in the YA2022 tax return
You changed your FY2022 year end	Turnover pro-rated to 12 months

Once fixed, it is fixed. Section 1.5 of the Guideline is explicit: later changes to turnover do not change your implementation date. A company that did RM30 million in 2022 and RM4 million today is still a phase 2 taxpayer.

When do new businesses start?

Business commenced	e-Invoice implementation date
2023 to 2025, turnover at least RM1,000,000	1 July 2026
2026 onwards	1 July 2026 or the commencement date
2026 onwards, first-year turnover below RM1,000,000	1 January of the second year following the year turnover reached RM1,000,000

Who is exempt?

Section 1.6.1 of the Guideline exempts, from issuing any e-Invoice including self-billed:

• Taxpayers with annual turnover or revenue less than RM1,000,000
• Foreign diplomatic offices
• Individuals not conducting a business
• Statutory bodies, statutory authorities and local authorities, for statutory collections, and for goods sold or services performed before 1 July 2025
• International organisations, for goods sold or services performed before 1 July 2025

The exemption attaches to the person, not the group. Section 1.6.5: a company owned by an exempt person still implements on its own timeline.

Separately, section 1.6.7 removes specific income types from the net — employment income, pension, alimony, zakat, certain dividend distributions, exchange-traded securities and derivatives contract values, and disposals of unlisted shares except where the disposer is a company, LLP, trust body or co-operative society.

What does the interim relaxation period allow?

Agreed by the Government on 26 July 2024, six months from each phase date — except phase 4, which was extended far beyond that.

Phase	Interim relaxation period
1	1 August 2024 – 31 January 2025
2	1 January 2025 – 30 June 2025
3	1 July 2025 – 31 December 2025
4 (both the 1 Jan 2026 and 1 Jul 2026 start dates)	until 31 December 2027

During the relaxation period, section 16.2 of the Specific Guideline permits a taxpayer to:

• consolidate all activities, including the industries in Table 3.6 that are otherwise barred from consolidating
• consolidate all self-billed circumstances
• put any text in the Description of Product or Service field, rather than receipt or statement reference numbers
• decline a buyer’s or supplier’s request for an individual e-Invoice

LHDN will also not prosecute under s.120 of the Income Tax Act 1967 during the period, provided the taxpayer is at least submitting consolidated documents.

That last condition is the one people miss. The relaxation is not permission to submit nothing.

What is the e-Invoice SVDP?

A Special Voluntary Disclosure Programme runs from 7 July 2026 to 31 December 2027 for taxpayers who missed submissions, submitted non-compliant e-Invoices, or are already under an e-Invoice compliance review. Compliance reviews and penalties are not pursued on what is disclosed, unless the disclosure involves fraud, wilful default or negligence.

Submissions must use e-Invoice version SVDP 1.2 (no digital signature) or SVDP 1.3 (with digital signature), and missed consolidated e-Invoices must be filed month by month — not lumped into one catch-up document.

Where does the legal obligation actually come from?

Not the Guideline. Section 82C of the Income Tax Act 1967, inserted by the Finance (No. 2) Act 2023 (Act 851), creates the duty to issue an electronic invoice for each transaction and to transmit it for the Director General’s validation. Section 82C(6) covers self-billed invoices, s.82C(7) consolidated invoices, and s.82C(8) allows a substitute e-Invoice within three days of a defective one. Section 120(1)(d) makes contravention of s.82C(1), (6) and (7) an offence.

Common mistakes

• Treating the RM1 million figure as a deferral. It is a standing exemption in section 1.6.1. It is also not a phase — there is no phase 5.
• Recomputing your phase from current turnover. The test is FY2022, once.
• Reading the phase 4 relaxation as a holiday. Consolidated submissions are the condition of the concession, not an alternative to it.
• Assuming the 72-hour window is a correction window. It cancels; it does not amend. After 72 hours you issue a credit, debit or refund note e-Invoice.
• Missing that the phase-3 date is also the cut-off for statutory bodies and international organisations, whose exemption only covered transactions before 1 July 2025.

What’s next

Confirm which of your transactions can be consolidated at all — several industries never could, and any single transaction above RM10,000 has been carved out since 1 January 2026. If you buy from foreign suppliers or pay individuals, the self-billed rules apply to you regardless of how small your sales ledger is. Implementers should start from the field list rather than the timeline.