Short answer. Some businesses and transactions are outside mandatory e-invoicing, either because they fall below a stated turnover level or because the guideline lists them as exempt. Being exempt is different from simply not having reached your start date. Confirm your status against the current LHDN guideline and keep a written record of the basis.
Axecta provides accounting and e-invoice readiness for companies across Malaysia. Talk to our team.
In this article
- Exempt versus not yet required
- Categories and conditions in official guidance
- What exempt businesses still need to keep
- How consolidated or simplified treatment works
- How to confirm your position with LHDN
- What changes if your turnover changes
- What LHDN’s timeline page says
- Practical consequences of being exempt
- How to document your position
- Frequently asked questions
Exempt versus not yet required
These two situations are often confused:
- Exempt: the business, or a type of transaction, is excluded from the obligation under the guideline or an official order.
- Not yet required: the business is in scope but its phase start date or relief period has not ended.
The first can be long-lasting but is conditional. The second is temporary. Treating the second as the first is a common cause of surprises. See implementation and transitional relief.
Categories and conditions in official guidance
Exemptions in the guideline have generally fallen into groups such as:
- Businesses below a stated annual turnover or revenue level.
- Certain types of income or persons that the guideline names.
- Specific transaction types for which the guideline allows a simplified or alternative treatment.
For each, the guideline sets conditions. Some depend on a measurement period; some depend on the nature of the transaction. Read the exact wording, not a summary. If you are quoting a rule to a customer or auditor, cite the section.
What exempt businesses still need to keep
Need this done for you? Axecta’s accounting and e-invoice readiness team can handle this for your company. See the accounting and e-invoice readiness service.
Even without e-invoicing:
- Issue proper invoices, receipts and credit notes under normal rules.
- Keep full accounting records and supporting documents.
- Keep a file note recording why you consider the business exempt, the figures used and the date checked.
- Be ready to receive e-invoices from suppliers. Your suppliers may be in scope and may request your TIN and details.
How consolidated or simplified treatment works
For some low-value or consumer transactions, the guideline permits consolidating them into periodic submissions rather than issuing one e-invoice per sale, subject to conditions. This is not an exemption from e-invoicing; it is a permitted method within it. Use it only if your transactions meet the conditions.
How to confirm your position with LHDN
- Read the current guideline and FAQ on the LHDN site.
- Calculate your figures using the stated method.
- If a point is unclear, use LHDN’s enquiry channels and keep the reply.
- Record the conclusion, the sources and the date in your compliance file.
Your accountant can prepare this file. Axecta does this for clients as part of an e-invoice readiness review.
What changes if your turnover changes
If your revenue grows beyond a stated level, or you start a new activity, your status can change. Re-test the position when you close each financial year, when you register a new entity and after any Budget or LHDN announcement.
What LHDN’s timeline page says
The LHDN timeline states that taxpayers with annual turnover or revenue of less than RM3,000,000 are exempted from e-Invoice implementation. The page was last updated on 30 August 2026. Earlier announcements and some secondary sources refer to other exemption levels, such as RM1 million and RM500,000, which were stated at different times. The point for a business owner is to rely on the current official page and the latest guideline, not on a blog that may be dated.
Practical consequences of being exempt
- You do not have to issue e-invoices yourself, but you should keep a file note showing the revenue test and the date.
- If a customer is in scope, they may ask for your TIN and details so they can issue self-billed documents or record purchases.
- If your revenue passes the threshold, you move into the phase for your size. Plan for that before year-end.
- You can still adopt e-invoicing voluntarily if it helps your customers or your systems.
How to document your position
Write a short memo and keep it with the tax file:
- Revenue figure and the year used.
- The LHDN page read, with its “last updated” date.
- The conclusion (exempt or in scope, and the date).
- The reviewer and the review date.
Re-do the memo each year. Your accountant can prepare it as part of year-end. See Does my Sdn Bhd need e-Invoicing?.
Frequently asked questions
Who is exempt from e-invoicing?
Exemptions have covered businesses below a stated turnover level and certain named types of income or persons, subject to conditions. The list is set by LHDN and has been revised, so check the current guideline.
Is there a turnover exemption?
LHDN has recognised a turnover level below which businesses are not required to issue e-invoices. The level and conditions are set officially; confirm the current position before relying on it.
Do exempt businesses still issue invoices?
Yes. They issue normal invoices and receipts and keep records. They may also have to receive e-invoices from suppliers.
Can I opt in voluntarily?
Generally yes, businesses can choose to adopt e-invoicing before they are required. Axecta can help you set it up.
What is the exemption level on LHDN’s page?
Less than RM3,000,000 annual turnover or revenue, as stated on the timeline page updated 30 August 2026.
Why do some articles quote RM1 million or RM500,000?
They reflect earlier or different announcements. Use the current LHDN page.
Do I need to keep a record if I am exempt?
Yes. A short file note showing your revenue test and sources protects you.
Want a written confirmation of your position?
Axecta Management Services is a full-suite accounting, company secretarial and consulting firm in Kuala Lumpur, serving companies from SMEs to MNCs.
Ask us to confirm your status
Keep reading
Official sources to check
- LHDN e-Invoice guideline and FAQ
- Ministry of Finance and LHDN announcements
- Gazetted orders where applicable
This article is general information and not legal, tax or accounting advice for your company. Rates, thresholds, deadlines and procedures change, so confirm current requirements with the sources above or with Axecta.