Svdp for E-Invoice in Malaysia
An e-Invoice is a digital representation of a transaction between a supplier and a buyer, effectively replacing traditional paper or electronic documents such as invoices, credit notes, and debit notes. It contains the same essential information as a traditional document, including supplier’s and buyer’s details, item descriptions, quantities, price excluding tax, applicable taxes and total amount, which records transaction data for day-to-day business operations.
To ease the compliance burden for Micro, Small and Medium Enterprises transitioning to this digital framework, the Inland Revenue Board of Malaysia (hereinafter referred to as “IRBM”) has announced the implementation of the Special e-Invoice Voluntary Disclosure Program (hereinafter referred to as “SVDP”) for taxpayers, which offers a full waiver of penalties for eligible voluntary disclosures. The SVDP is effective immediately will be available until 31 December 2027.
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Eligibility for SVDP
The SVDP is applicable to taxpayers who fall into any of the following categories:
(1)
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taxpayers who failed to issue or missed submitting mandatory e-invoices for any given period following their respective statutory implementation dates;
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(2)
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taxpayers who actively generated e-Invoices but filed documents containing data errors, or failed to align with the precise specifications dictated by prevailing tax laws and official guidelines;
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(3)
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taxpayers who completely omitted the implementation of e-Invoicing and did not submit any e-Invoices since the mandatory e-Invoice implementation date; and
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(4)
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taxpayers who are currently undergoing or have been notified by the IRBM that they will be undergoing an e-Invoice compliance review.
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The SVDP shall not apply where:
(1)
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the e-Invoices submitted under the e-Invoice SVDP do not comply with the specifications and requirements prescribed under the prevailing tax laws and official guidelines.
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(2)
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the voluntary disclosure involves fraud, wilful default or negligence.
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Taxpayer’s responsibility
For voluntary disclosures under the e-Invoice SVDP to be accepted by IRBM, taxpayers must act in good faith and fully comply with the frameworks prescribed for the programme. Taxpayers are responsible to ensure that all submitted voluntary disclosures are accurate, complete and in accordance with the requirements as set out by IRBM.
This initiative provides an opportunity for taxpayers regularise its e-Invoice compliance. Taxpayers can voluntarily review and make corrections regarding e-Invoice issuance requirements to enjoy the penalty waiver, in order to support digitalization aspirations in business operations.
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Requirement
Taxpayers participating in the e-Invoice SVDP are required to use specific the e-Invoice versions depending on the submission method:
(1)
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SVDP 1.2: for taxpayers who are submitting without digital signature; and
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(2)
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SVDP 1.3: for taxpayers who are submitting with digital signature.
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These designated e-Invoice versions must only be used for the purpose of making voluntary disclosures under the e-Invoice SVDP and shall not be used for any e-Invoice submission outside of this program.
Where the voluntary disclosures involve consolidated e-Invoices that were not previously submitted, the consolidated e-Invoices shall be submitted according to the respective month in which the transactions took place. Taxpayers are not allowed to submit the consolidated e-Invoice on a lump-sum basis (covering multiple months).
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Practical application
To illustrate the operational application of the unsubmitted e-Invoice SVDP, consider the scenario of VinaticPA Sdn. Bhd., a Company with an annual revenue of RM10,000,000 in the financial year 2022. Under Phase 3 of the mandatory implementation, the company was required to implement e-Invoicing starting from 1 July 2025.
Due to a high staff turnover rate in its accounting department who was in charge of e-Invoicing, VinaticPA Sdn. Bhd. failed to submit e-Invoices for its transactions from January 2026 to June 2026.
The breakdown of the unsubmitted transactions during this period is as follow:
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Month
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Number of
transactions
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Transactions valued below RM10,000
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Transactions valued above RM10,000
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January
2026
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12
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9
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3
|
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February
2026
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6
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4
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2
|
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March
2026
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20
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11
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9
|
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April
2026
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13
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9
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4
|
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May
2026
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13
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6
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7
|
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June
2026
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9
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3
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6
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Under the e-Invoice SVDP guidelines, VinaticPA Sdn. Bhd. must regularise its submissions based on the following criteria:
(1)
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for transactions equal to or exceeding RM10,000, transactional e-Invoices must be issued individually
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(2)
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for transactions below RM10,000, the company is allowed to issue a consolidated e-Invoice, provided the buyers did not request individual e-Invoices.
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The required submissions for VinaticPA Sdn. Bhd. under the SVDP must be filed on a monthly basis as follows:The required submissions for VinaticPA Sdn. Bhd. under the SVDP must be filed on a monthly basis as follows:
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Month
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January 2026
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February 2026
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March 2026
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April 2026
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May 2026
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|
June 2026
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VinaticPA Sdn. Bhd. must submit using the “SVDP 1.2” if they are submitting without digital signature or using the “SVDP 1.3” if they are submitting with digital signature, for the purposes of the e-Invoice SVDP to qualify for the penalty waiver.
For further information, please visit the official website of the Inland Revenue Board of Malaysia at
https://www.hasil.gov.my/en
KAIZEN Group, together with its associate firms in Malaysia, can help the clients to perform these compliances formalities so as to maintain the Malaysia company in good standing. Please call and talk to our professional accountants in Kaizen for further clarification.
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KNOWLEDGE
