Overview

In Malaysia’s e-Invoicing framework, a consolidated e-Invoice is a single electronic invoice that aggregates multiple transactions for reporting to the tax authority. The Inland Revenue Board of Malaysia (IRBM) requires businesses to use consolidated e-Invoices for transactions where the buyer does not request an individual Invoice. Instead of sending an e-Invoice for each sale, the supplier can issue their usual receipt or bill to the customer at the point of sale and later compile those transactions into one consolidated e-Invoice for IRBM’s purposes (e-Invoice Specific Guideline 4.1, Section 3.6). This approach ensures that all sales are reported and validated through the MyInvois system, even when customers (often end-consumers) do not themselves require an e-Invoice.

When to Use a Consolidated e-Invoice

Use Case: A consolidated e-Invoice is used when the buyer does not require an e-Invoice for a transaction. In such cases, the seller follows normal business practice by issuing a paper receipt, point-of-sale invoice, or bill (Figure 3.4 below) to the customer instead of an immediate e-Invoice. However, the seller must still report these sales to IRBM. According to IRBM’s guidelines, the supplier is required to aggregate all transactions with buyers who did not request e-Invoices on a monthly basis and submit one consolidated e-Invoice covering those transactions. The consolidated e-Invoice for a given month must be sent to IRBM within seven (7) calendar days after the end of that month  (e-Invoice Specific Guideline 4.1, Section 3.6.2).

For example, if a business has numerous retail sales in January where customers only take standard receipts, the business will compile those January sales into a consolidated e-Invoice and submit it by 7 February. Once this consolidated e-Invoice is validated by IRBM, it serves as the official record of those sales for tax purposes. The individual customers do not receive the consolidated e-Invoice – they already have their original receipts – but the IRBM does. Notably, if a buyer later decides they need an e-Invoice (for instance, a customer changes their mind within the same month of purchase), the buyer can request an e-Invoice from the supplier within that month, and the supplier must then issue a standard e-Invoice for that transaction instead of waiting to include it in the month-end consolidation (e-Invoice Specific Guideline 4.1, Section 3.6.8). In summary, consolidated e-Invoices are a compliance mechanism to cover sales where no individual e-Invoice was issued to the buyer at the time of sale, ensuring IRBM still receives the sales data in a timely manner.

Preparation and Submission Requirements

Frequency & Deadline

Content & Format

1. Method (a): List each individual receipt/bill as a separate line item. Each line would typically include a reference (e.g. receipt number or date), the total amount of that receipt, and the tax charged on it. This method essentially itemizes every transaction that is being consolidated.
   

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1. Method (b): Group receipts into ranges and list each continuous range of receipt numbers as one line item. For instance, if receipts #1001 through #1010 were issued to various customers consecutively, the supplier can aggregate them as a single line item (showing the aggregated total and tax for that range). When there is a break in the sequence (e.g., a missing number or a reset in numbering), a new line item is started for the next continuous range. This option allows a slightly higher-level summary if listing every single receipt is impractical.
   

Buyer Information

Restrictions: Transactions Not Eligible for Consolidation

While consolidated e-Invoices provide flexibility for many retail and consumer transactions, not all sales can be reported in a consolidated manner. IRBM’s rules explicitly prohibit the use of consolidated e-Invoices for certain types of transactions and industries (Specific Guideline, Section 3.7). In these cases, even if the buyer does not request an e-Invoice, the supplier must issue an individual e-Invoice for each transaction. According to Section 3.7 of the e-Invoice Specific Guideline (Version 4.1), consolidated e-Invoicing is not allowed for the following activities and transactions:

1. Motor Vehicle Sales: The sale of any motor vehicles (e.g. cars, motorcycles, etc.) must be invoiced individually, due to the high-value and regulatory nature of these sales (Specific Guideline, Section 3.7).
2. Airline Tickets: The sale of flight tickets cannot be consolidated. Each ticket sale should be accompanied by its own e-Invoice if required (Specific Guideline, Section 3.7).
3. Charter of Aircraft: Services involving private chartered aircraft are excluded from consolidation (Specific Guideline, Section 3.7).
4. Luxury Goods and Jewellery: Transactions involving luxury items or jewellery (as defined by IRBM’s forthcoming detailed guidance) must be individually invoiced (Specific Guideline, Section 3.7).
5. Construction Contracts: Any works under construction contracts (by contractors as defined in the Income Tax (Construction Contracts) Regulations 2007) are barred from consolidated invoicing (Specific Guideline, Section 3.7).
6. Sale of Construction Materials: Sales of construction materials by wholesalers or retailers, regardless of volume, must be issued as standard e-Invoices per sale (Specific Guideline, Section 3.7).
7. Betting & Gaming Payouts: Payouts to winners from licensed betting or gaming activities cannot be reported via a consolidated invoice (Specific Guideline, Section 3.7).
8. Agent/Dealer/Distributor Payments: Any payments made to agents, dealers, or distributors (as defined under Section 83A(4) of the Income Tax Act 1967) must be individually e-invoiced rather than consolidated (Specific Guideline, Section 3.7).

For all the above categories, the nature of the transaction is such that IRBM requires a one-to-one e-Invoice (often for specific tax tracking or documentation reasons). If a business is involved in any of these activities, it cannot use the monthly consolidated approach for those particular transactions. Instead, it must issue e-Invoices for each transaction as if the buyer had requested them, irrespective of the buyer’s preference (Specific Guideline, Section 3.7).

Interim 6-Month Grace Period for Implementation

To ease the transition into mandatory e-Invoicing, IRBM announced a six-month interim relaxation period at the start of each phase of the rollout (Phase 1 starting 1 August 2024, Phase 2 on 1 January 2025, etc.). During this grace period, businesses are given flexibility to use consolidated e-Invoices for all transactions, even those in the normally prohibited categories, and even if a buyer technically requests an e-Invoice. In other words, for the first 6 months of a business’s e-Invoice mandate, the taxpayer may choose to only submit monthly consolidated e-Invoices covering their sales, without issuing individual e-Invoices for each transaction. This concession was provided via an official IRBM media release and is intended to allow additional time for companies to fully adjust their systems and processes. Importantly, the grace period does not delay the enforcement date – it simply means IRBM will not impose penalties for not issuing individual e-Invoices during that initial period, provided that the taxpayer does submit a proper consolidated e-Invoice each month. After the six months pass, the business is expected to comply with the standard e-Invoicing requirements (including issuing e-Invoices transaction-by-transaction where required, and only using consolidation in eligible situations as per the guidelines). This interim measure applies to all industries and also allows consolidated self-billed e-Invoices for expense scenarios during the period. By the end of the grace period, businesses should have their e-Invoicing fully in place beyond just consolidated reporting.