3 e-Invoice Mistakes LHDN Is Flagging — Check Before You Use SVDP

In its 20/06/2026 media statement, HASiL identified four specific e-Invoice non-compliance patterns it is actively monitoring. Three of them — inconsistent issuance, format non-compliance, and late consolidated e-Invoice submission — have not been widely covered. This post deals with those three.

The fourth issue — failure to issue individual e-Invoices for transactions above RM10,000 from 01/01/2026 — is covered separately in our earlier posts on 5 Red Flags LHDN Will See From Your e-Invoice Data and e-Invoice and the LHDN Means Test.

Pattern 1 — Issuing e-Invoices for Some Transactions But Not Others

HASiL described this as issuing e-Invoices for part of your transactions while failing to issue them for subsequent ones. In practice, this usually isn’t deliberate — it’s a workflow split.

The most common version: a business operates across two or more sales channels — for example, invoice-based B2B sales and walk-in cash sales, or online marketplace orders alongside direct sales. The e-Invoice issuance process is wired to one channel but not the other. Months pass before anyone notices the gap, by which point the pattern is visible in the MyInvois data.

Pattern 2 — e-Invoices That Do Not Meet the Format Requirements

An e-Invoice submitted to MyInvois and validated is not automatically a compliant e-Invoice. The e-Invoice Specific Guideline prescribes mandatory fields, document types, and content requirements. MyInvois validates the technical submission — it does not check whether every required field has been correctly populated.

Common causes we see: the supplier’s e-Invoice template was set up without reference to the Guideline’s current version; mandatory fields such as the buyer’s TIN or the correct classification code were left blank or incorrectly filled; or the wrong document type was used — for example, a consolidated e-Invoice issued where an individual e-Invoice was required.

Pattern 3 — Consolidated e-Invoices Submitted After the Allowed Window

Consolidated e-Invoicing allows suppliers to aggregate transactions with buyers who do not require individual e-Invoices — typically individual consumers or buyers who have not provided their TIN. The consolidated e-Invoice must be submitted to IRBM within 7 calendar days after the end of the month in which those transactions occurred.

That is a tight window. A business that processes its consolidated e-Invoice submission as part of a monthly accounts cycle — typically completed two to three weeks after month end — is systematically late. The Guideline permits consolidated invoicing; it does not extend the submission deadline to match your close cycle.

The Common Thread

All three patterns share the same root: e-Invoice compliance was treated as a one-time implementation task rather than an ongoing operational process. The system was set up, it ran, and nobody checked whether it was running correctly. HASiL’s analytics are now doing that check instead.

The RM10,000 individual e-Invoice requirement — and what it means for data visibility and the means test — is covered in detail in our earlier posts linked above.

Source: HASiL media statement dated 20/06/2026, “E-Invois Perkukuh Pematuhan Cukai: 52,540 Pembayar Cukai Tampil Laporkan Pendapatan RM4.07 Bilion” (PDF).