e-Invoices & Foreign Suppliers: Who Issues the Invoice? (Cross-Border)

Introduction

Your business buys goods or services from a foreign supplier. In the e-Invoice system, the key question is: who issues the e-Invoice — the foreign supplier or you as the buyer?

This article explains the role of the Malaysian buyer when a foreign supplier does not issue an e-Invoice on MyInvois, the current exemption threshold, and the timeline of the mandatory phases.

Who issues the e-Invoice when a foreign supplier cannot?

The basic principle in the MyInvois technical documents: foreign suppliers do not issue e-Invoices on the MyInvois system. Instead, the Malaysian buyer issues a self-billed e-Invoice in place of the supplier.

That means: if you buy from a foreign supplier, the obligation to issue an e-Invoice (self-billed type) lies with you as the buyer, not the foreign supplier.

Current exemption threshold: RM3 million

According to the e-Invoice Guideline v4.8 (s.1.6.1(e)): taxpayers with annual turnover/revenue of less than RM3 million are generally exempted from issuing e-Invoices — including self-billed.

However, this exemption does not apply if the taxpayer:

• (a) has non-individual shareholders with turnover ≥RM3 million;
• (b) is a subsidiary of a parent company with turnover ≥RM3 million; or
• (c) has related company/joint venture with turnover ≥RM3 million.

Phase 4: mandatory from 1 January 2026

The guideline lists the mandatory phases (Schedule 16.1):

• Phase 4 (turnover RM3 million–RM5 million) — mandatory from 1 January 2026.
• Relaxation period — until 31 December 2027.
• Penalty enforcement — from 1 January 2028.

The RM10,000 rule

From 1 January 2026: any single transaction exceeding RM10,000 cannot be consolidated and requires an individual e-Invoice.

Guideline status

The e-Invoice Specific Guideline v4.9 was issued on 7 September 2026, replacing v4.8 (7 July 2026), and was issued under s.134A ACP 1967.

SVDP: opportunity for penalty-free correction

SVDP (voluntary disclosure programme) — the period 7 July 2026 to 31 December 2027 offers an opportunity for penalty-free correction for e-Invoice compliance issues.

What is not yet known

Do not claim "all foreign suppliers are exempted" — the role differs by transaction type; refer to the cross-border chapter.

Frequently Asked Questions (FAQ)

Q. I bought goods worth RM50,000 from a foreign supplier. Who issues the e-Invoice? A. The foreign supplier does not issue an e-Invoice on MyInvois; you, as the Malaysian buyer, issue a self-billed e-Invoice.

Q. Are all small businesses exempted from e-Invoicing? A. Generally yes if annual turnover is less than RM3 million. But the exemption does not apply if you have non-individual shareholders, a subsidiary or a related company/joint venture with turnover ≥RM3 million.

Q. What is the RM10,000 rule? A. From 1 January 2026, any single transaction exceeding RM10,000 cannot be consolidated and requires an individual e-Invoice.

Q. When does Phase 4 start? A. Phase 4 (RM3 million–RM5 million) is mandatory from 1 January 2026, with a relaxation period until 31 December 2027 and penalty enforcement from 1 January 2028.

Glossary

• e-Invoice — an electronic invoice validated through the MyInvois system.
• MyInvois — HASiL's official e-Invoice system.
• Self-billed — an e-Invoice issued by the buyer (not the supplier).
• Turnover — a business's annual sales revenue/collections.
• SVDP — voluntary disclosure programme for e-Invoice compliance issues.
• s.134A — provision of ACP 1967 empowering HASiL to issue e-Invoice guidelines.