22 Jul e-Invoice for New Companies in 2026: Your Implementation Date Depends on Two Questions
A new director walked into our office this week convinced his 2026 Sdn Bhd had until 2027 before e-Invoice was his problem. He was half right. The real answer turns on two things he hadn’t looked at — and getting either one wrong creates a problem, in either direction.
Here is how to work out where your company actually stands, using LHDN’s own FAQ examples.
First Question — Who Owns Your Company?
Before turnover even matters, check whether your company qualifies for the e-Invoice exemption. Most people skip this step and go straight to the revenue question. Don’t.
The exemption falls away the moment any one of these applies:
- A corporate shareholder (or equivalent) with annual turnover of RM1 million or more owns shares in your company
- Your company is a subsidiary of a holding company with annual turnover of RM1 million or more
- Your company has a related company or joint venture with annual turnover of RM1 million or more
If your shareholders are individuals — you, your spouse, a business partner — and there is no group above you, you likely pass. Go to the second question.
If there is a holding company in the picture, or a corporate shareholder above RM1 million, the exemption is gone. Jump to Step 3 below.
A brand new subsidiary with zero revenue still fails the test if the parent is above RM1 million. Zero revenue does not help you. The structure is what disqualifies you, not the numbers.
Second Question — What Was Your YA2026 Turnover?
If you passed the shareholding check, your company is outside e-Invoice scope until a specific date arrives. No obligation yet. The deferral is the buffer — you do not need Phase 4 relaxation because the mandate hasn’t reached you.
What determines when it does reach you is your first-year turnover.
YA2026 turnover above RM1 million: e-Invoice kicks in from 01/01/2028. Nothing required before that.
LHDN example (FAQ 13(b)): Warung Salima opened on 01/01/2026. YA2026 revenue RM1.12 million. e-Invoice start date: 01/01/2028.
YA2026 turnover below RM1 million: Exempt for now. The obligation only starts from 01/01 in the second year after turnover eventually crosses RM1 million. If it never does, it never applies.
LHDN example (FAQ 13(b)): Pinggan Mangkuk Enterprise opened 01/01/2026. YA2026 revenue RM308,000 — exempt. YA2027 revenue RM1.14 million — threshold crossed. e-Invoice start date: 01/01/2029.
One thing directors miss: the clock starts in the year you cross RM1 million, not the year you file accounts or realise the number. If your YA2026 closes above RM1 million, the 01/01/2028 date is locked in — whether or not your accounts are finalised yet.
Failed the Shareholding Test? Here Is Your Position
Your e-Invoice start date is 01/07/2026 or your operation commencement date, whichever comes later. You are in scope from that day.
LHDN example (FAQ 13(a)): Coco Lock Sdn Bhd, subsidiary of a Phase 1 group, commenced operations 01/09/2026. Start date: 01/09/2026 — later than 01/07/2026, so commencement date applies.
Being in scope does not mean you need everything running perfectly from day one. The Phase 4 relaxation period runs until 31/12/2027 for both the 01/01/2026 and 01/07/2026 implementation dates — and that includes companies that started after July. During this window, consolidated e-Invoices are allowed for all transactions, including those above RM10,000.
The relaxation is not permission to do nothing. Consolidated e-Invoices must still reach IRBM within 7 calendar days after month end — that is a fixed window, not your monthly close date. Missing it is one of the three patterns HASiL is actively flagging this year.
Where Does Your Company Stand?
| Situation | Condition | e-Invoice Start Date |
|---|---|---|
| Passes shareholding test, YA2026 above RM1M | Individual shareholders, no group, turnover above RM1M in YA2026 | 01/01/2028 |
| Passes shareholding test, YA2026 below RM1M | Individual shareholders, no group, turnover below RM1M in YA2026 | 01/01 in second year after RM1M first crossed |
| Fails shareholding test | Subsidiary, group company, or corporate shareholder above RM1M | 01/07/2026 or commencement date, whichever later. Phase 4 relaxation until 31/12/2027. |
Two Questions. Answer Them Now.
Assuming you are exempt when your shareholding structure disqualifies you means non-compliance from your commencement date — potentially already months behind. Assuming you must implement immediately when you qualify for deferral means spending time and money on a system you don’t need yet.
Both mistakes are avoidable. The answers are sitting in your SSM filing and your management accounts.
The check is every entity connected to you that might trigger the disqualification. And if your YA2026 turnover is anywhere near RM1 million, track it now. The date locks in based on when you cross the threshold, not when your accountant tells you about it.
Source: LHDN, Implementation of e-Invoice in Malaysia — Frequently Asked Questions (Updated 05/05/2026), FAQ 13, FAQ 90, FAQ 104 (PDF).
Not sure which track your company is on?
KS Chia & Associates Chartered Accountants (AF001828)
WhatsApp: 011-2366 5233 | Kuala Lumpur