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1. Will hospitals need to change how they issue invoices?
Right now, hospitals issue invoices based on who is paying:

Patients who pay for themselves
Insurance companies, employers, or guardians paying on behalf of a patient
Companies covering medical expenses for employees
These billing arrangements will stay the same under e-Invoicing in healthcare industry. Exception: If the patient is a minor (under 18), the invoice should include the parent/guardian’s details.

2. Can hospitals issue one e-Invoice for all self-paying patients?
Yes! If a patient does not need an e-Invoice, the hospital can issue a single consolidated e-Invoice for all similar transactions.

3. How does e-Invoicing work for insurance claims?
Currently, hospitals send a proforma bill to insurance companies before getting a Final Guarantee Letter (FGL) and finalizing the bill.

With e-Invoicing:
Hospitals can continue using proforma invoices for insurance claims. If an e-Invoice is requested, it must be issued after the final bill is ready (e.g., after the patient is discharged).

If no e-Invoice is requested, hospitals can issue a normal bill and later submit a consolidated e-Invoice within 7 days after month-end.

4. How should hospitals issue e-Invoices for independent consultants?
Hospitals work with independent consultants in two ways:

(1) Co-Provision of Medical Services
Both the hospital and consultant will issue separate e-Invoices to the patient.

(2) Outsourcing Arrangement
The hospital issues an e-Invoice to the patient, covering both hospital and consultant fees. The consultant (or their company) issues an e-Invoice to the hospital for their services.

5. Do locum doctors and nurses need to issue e-Invoices?
It depends on how they are hired:
If they are independent (contract for service), they must issue an e-Invoice to the hospital.

If they work through an agency, the agency must issue the e-Invoice.

If they are hospital employees, no e-Invoice is needed.

6. What happens when a patient is transferred between hospitals?
Scenario 1:
The first hospital discharges the patient before transfer. Both hospitals issue separate e-Invoices for their treatments.

Scenario 2:
The first hospital waits until the patient returns before issuing a bill. First hospital issues an e-Invoice for all services, including those from the second hospital. Second hospital issues an e-Invoice to the first hospital for its services.

Both methods are acceptable under e-Invoicing rules.

7. Do hospitals need to issue e-Invoices for space rental & service fees?
Yes! Hospitals must issue e-Invoices for:

Rental fees charged to independent consultants
Rental payments from cafes, convenience stores, or other tenants
8. Should hospitals submit summary or detailed bills for e-Invoicing?
Hospitals must issue e-Invoices based on thedetailed bill (itemized breakdown of charges).

9. Do medical consultants need to implement e-Invoicing if the hospital is required to?
Not necessarily. Even if a hospital’s revenue exceeds RM100 million, individual consultants only need to comply when their own revenue meets the threshold.

10. What about deposits collected by hospitals?
Refundable deposit: No e-Invoice needed.
Non-refundable deposit: E-Invoice required.
For self-paying patients who don’t need an e-Invoice, hospitals can issue a consolidated e-Invoice.
11. How should hospitals handle e-Invoices for staff medical benefits?
If the hospital already issues invoices for staff medical benefits:
It must now issue an e-Invoice (with a nil amount if services are free).

If no invoices are issued today:
No need to start issuing e-Invoices for staff medical benefits.

Conclusion
The e-Invoicing in healthcare is designed to improve compliance, transparency, and efficiency in Malaysia’s healthcare industry. Most hospitals can keep their current billing process, but they must ensure e-Invoices are issued where required.


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A. General
Issuing of Consolidated E-Invoices for Certain Transactions:
Insurance companies can grant consolidated e-invoices for revenue from policyholders who do not require individual e-invoices.This method simplifies reporting and ensures compliance

The consolidated e-invoices must be in compliance with the rules mentioned in section 3.6 of the e-invoice specific guideline released by IRBM.

Role of Annual Premium Statements for Consolidated E-Invoices:
Annual premium statements can be used for consolidated e-invoices if the policy holder does not request e-invoices, Insuch a case, they must continue to issue regular statements or bills as per current practices.

Accumulated submission:
Aggregate data from these statements or bills to create a consolidated e-invoice. Submit the consolidated e-invoice to the IRBM within seven calendar days after the month-end. Detailed guidance is provided in Section 4.3 of the e-Invoice Specific Guideline.

Full-Year Premium Data Transmission If the first annual premium statement (for January to December 2024) is only available in February or March 2025, companies can:

Include the entire year’s data (January to December 2024) in the February/March 2025 submission.

There is no requirement to separate data for the period from January to July 2024, although mandatory e-invoicing begins on August 1, 2024.

Dealing with ad-hoc requests for valid e-invoices:
When e-invoices usually follow the consistent issuance cycle, the insurance company must consider policyholder requests outside this cycle:
Simple procedure: Establish a direct process to deal with such requests.

Effective communication: Notify customers on how to request consolidated e-invoices during regular invoice cycles to evadepostponements or misunderstanding.

Issuing E-Invoices for Products that do not have a tax-respite:
Policyholders may ask for consolidated e-invoices for products are not in tax relief category. In sucha scenario:
For e-invoicing purposes, the policyholder is assumed to be the buyer.

Insurance companies are obliged to grant a consolidated e-invoice on request, despite the product’s tax relief status.





B. Underwriting and subscription





C. Claims and Benefit Payments





D. Other Considerations

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1. Issuing e-Invoices for Flight Tickets and Private Air Charter services
The sale of flight tickets and private air charter services, make it mandatory for an e-invoice to be issued. This condition comes with certain requirements depending on the type of airline operator, explained as below:

Local Airline Operators: All local airline operators are bound to issue e-invoices for all flight tickets and services. This isirrespective of where the sale occurs.
Foreign Airline Operators: All foreign airline operators are bound to issue e-invoices only when the point of sale is in Malaysia, as defined by the International Air Transport Association (IATA).
Key consideration: Consolidated e-invoices are not allowed for thesedealings. For furtherinformation on this, refer to Sections 2.3, 2.4, and 3.7 of the e-invoice Guidelines.

2. Buyer Information in E-Invoices
Information of the buyer in e-invoicing in aviationdiffersbased on the nature of the buying:

In case of Personal Travel:Details of the individual who made the purchase must be entered as buyer’s details.
In case of Group Bookings:Airlines have two options:
All the invoices can contain the details of the person who made the purchase for all the invoices
Each invoice can have the details of the respective passenger
3. Privacy Concerns with Buyer Data
Global data protection laws, such as GDPR, may cause airlines to face challenges in gathering personal details like Tax Identification Numbers (TIN).

In order to mitigate this issue, the Inland Revenue Board of Malaysia (IRBM) provides the following temporary options:

Buyer’s Name: Enter “General Public.”
TIN: Enter “EI00000000020.”
Business Registration Number (BRN): Enter “N/A.”
Other Details (Address, Contact Number, SST Registration Number): Enter “N/A.”
This methodensures complete compliance in e-invoicing in aviation, adhering to privacy laws.

4. E-Invoices for Excess Baggage Fees
Airlines must issue e-invoices based on the following conditions, in situations where fee is charged on excess baggage during checkin:

If Requested: e-invoice must be issued instantly.
If Not Requested: Must provide a receipt and consolidate these transactions into a e-invoice within seven days after the end of the month.
5. Handling Price Adjustments and Refunds
Changes in ticket prices need specific e-invoicing procedures:

In case of increase in price, they are required toissue a separate e-invoice or debit note for the difference.
In case of reductions in price or Refunds they are required toissue a credit note or refund note.
In cases where there are no changes in monetary value, additional e-invoice is not required.
6. Issuing E-Invoices for Ancillary Services
When it comes to flight and non-flight related ancillary services, the following e-invoicing in aviation rules must be followed by airlines:
Flight related Ancillary services Eg: Seat selection, baggage: If these items are sold together in one deal, there are two options available for airlines:
1. A single e-invoice can be issued consisting of both ticket and ancillary services.
2. Separate e-invoices can be issued, one for the ticket and one on ancillary services.
If ancillary services and flight ticket are sold separately:
1. A separate e-invoice for the flight ticket
2. Based on the request of the buyer, either an e-invoice or receipt will be issued for the ancillary service.
Non-flight related ancillary services (Eg: car rentals, travel insurance)
1. In cases where airline is the main provider of the service, they must issue the e-invoice.
2. The service provider must issue the e-invoice or receipt in cases where the airline acts as agent.
Key Takeaways for e-invoicing in aviation
Airline operations, need to understand the rules for e-invoicing in aviation in order to stay compliant with the Income Tax (Issuance of Electronic Invoice) Rules 2024. By understanding these rules, the airlines can transition seamlessly to e-invoicing and mitigate any regulatory or compliance issues.
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A few key considerations for financial institutions transitioning to e-Invoicing:

1. Customer’sapproval for e-Invoices
It is important for financial institutions to take customer’s consent or approval in order to align the e-invoicing compliance with FSA and IFSA regulations. This protects confidentiality and aligns with data protection laws.

2. Consolidated e-Invoices – description field
For e-invoicing in financial institutions, it is not mandatory to disclose the statement or bill reference numbers in the “Description of Product or Service” field. As an alternative, institutions should make sure the presence of relevant descriptions that are in line with the regulatory standards.

3. Income from Overseas Branches
Income generated by both Malaysia and overseas branches must be accounted for and e-invoice must be issued by resident financial institutions that are running a banking business. They must be mindful to ensure complete e-invoicing compliance in all their transactions.

4. Customer-Issued e-Invoices for Income Received
Income received through sources such as interest on fixed deposit, financial institutions must issue e-Invoices as and when it is requested by the customer. An e-invoice containing reports of sums due and received guarantees transparency thus firming up e-invoice compliance.

5. Consolidated e-Invoices for Non-Requested Transactions
In cases, where the consumers do not explicitly require an e-invoice, financial institutions can issue a consolidated e-invoice. E-invoicing compliance guidelines mentioned in in Section 3.7 of the e-Invoice Specific Guideline document should be followed to avoid any errors.

6. Loan Repayments and Interest
There is no requirement for financial institutions to issue an e-invoice on the repayment of principal amount on loan. However, e-invoicing compliance mandates the issue of e-invoices for interest that is charged on loans.

7. Interbank Lending and Borrowing Interest
In cases of interbank transactions, the bank lending must issue the e-invoice for the interest that is charged to the borrowing bank, thisshowcases transparency and enablese-invoicing compliance in the banking industry.

8. Treasury Product Premiums and Upfront Fees
E-invoicing compliance requires financial institutions to issue e-Invoices for non-refundable premiums or upfront fees, ensuring clear documentation of such transactions.

9. Joint and Multi-Party Accounts
For joint, custodial, trust, or escrow accounts, one e-Invoice is generally issued for the principal account holder. However, e-invoicing compliance allows for separate e-Invoices to be generated upon request by other account holders.

10. Charges and Fees for Card Networks and Operators
Foreign Processors: Financial institutions must issue self-billed e-Invoices for charges paid.
Local Processors: Local operators issue e-Invoices for fees received, ensuring e-invoicing compliance by presenting them in XML or JSON format for easy interpretation.
11. Processing Fees for Inward Remittances
Financial institutions must issue:

Self-billed e-Invoices for fees paid to foreign agents.
E-Invoices for fees charged to local recipients to maintain compliance.
12. Upfront Payments for Property Auctions
E-invoicing compliance mandates e-Invoices for non-refundable upfront payments. However, refundable payments do not require an e-Invoice.

13. Cashback and Rewards Programs
Cashbacks can be documented within e-Invoices in XML or JSON format, detailing amounts owed and credits provided.

For reward points:

Free points: No e-Invoice is required.
Redemption: E-Invoices are issued only for additional charges incurred beyond the redeemed value.
14. Adjustments in e-Invoices
To ensure smooth compliance, financial institutions can include adjustments in subsequent e-Invoices rather than issuing separate credit, debit, or refund notes.

15. Treasury Product Income
E-invoicing compliance does not require e-Invoices for certain accounting adjustments, such as:

Realized or unrealized gains and losses.
Amortization or accretion of premiums or fees.
Foreign exchange gains or losses.
Conclusion
E-invoicing compliance is essential for financial institutions to streamline invoicing processes while ensuring adherence to FSA and IFSA regulations. By integrating these guidelines into their operations, institutions can enhance transparency, improve efficiency, and foster trust with both customers and regulatory authorities.


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According to s. no.16, in the IRBM e-Invoice Specific Guidelines (version 3.1, published October 4, 2024), the Malaysian government has implemented a six-month interim relaxation period for each phase of mandatory e-invoicing, requiring taxpayers to transition to issuing consolidated monthly e-Invoices for all transactions—B2B, B2C, and self-billed.

The relaxation phase must be implemented as follows:
No. Targeted tax payer Interim relaxation period
1 Annual turnover or revenue > 100 million 1 August 2024 to 31 January 2025
2 Annual turnover or revenue > 25 million an up to RM 100 million 1 January 2025 to 30 June 2025
3 All other tax payers 1 July 2025 to 31 December 2025
Reference taken from table 16.1 (IRBM e-Invoice Specific Guidelines (version 3.1, published October 4, 2024))

Anusaar, an e-invoicing solution, by Lenorasoft simplifies this process by supporting invoice consolidation and offering robust features for compliance.

During this period, individual invoices are on hold, and are allowed to generate a consolidated e-invoice. Taxpayers have flexibility to input any details in the “description of product or service” field.

In other words, taxpayers are not restricted to input the receipt/ statement / bill reference numbers as required under Section 3 and 4 of this e-Invoice Specific Guideline.

However, consolidating transactions can create some challenges.

Here is how Anusaar, an e-invoicing solution, can help address challenges that may arise due to consolidating invoices:
Consolidated invoicing can lead to missing individual transaction records, increasing the risk of audit discrepancies and data loss. Anusaar, an e-invoicing solution, addresses this by providing secure long-term record-keeping, backup and archival, ensuring seamless audit reconciliation and compliance.

Example: A wholesale supplier processes 500 transactions in a day. Instead of recording each transaction separately, the supplier consolidates them into a single daily invoice totaling RM50,000. However, during an audit, authorities have raised a requirement to present all 500 transactions.

Using Anusaar, the supplier can maintain detailed, secure records for all 500 transactions while still generating consolidated reports and will be able to present the records to the authorities as and when requested.

Additionally, our system organizes and stores invoice data systematically, ensuring continuity and allowing new personnel to quickly understand and manage the information, facilitating seamless team transitions between resources ensuring zero dependency on manual intervention.
Anusaar, our cutting edge e-invoicing solution, makes month-end invoice consolidation easy by automating the process directly from your ERP system. Instead of manually picking and creating consolidated invoices, Lenorasoft’s experts set up smart workflows to do it for you. This automation ensures accurate data is sent to Anusaar, saving you time and effort during busy month-end periods.
Stay compliant and efficient with Anusaar’s comprehensive e-invoicing solutions.


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In this article, we outline the key e-invoicing obligation in donation and contribution cases, based on the latest guidance issued by the Inland Revenue Board of Malaysia (LHDN).

1. Are e-Invoices Required for Donations or Contributions?
Yes, e-Invoices—whether individual or consolidated—must be issued for donations or contributions received, with the following exceptions:

Religious institutions or organisations established exclusively for the purpose of worship or advancing religion.
Other entities receiving non-tax-exempt donations or contributions under the Income Tax Act 1967.
However, this exemption does not apply if the religious organisation:

Is an approved institution or fund under subsections 44(6), 44(6B), 44(11B), 44(11C), or 44(11D); or
Manages a charity/community project approved under paragraph 34(6)(h).
Such organisations are still required to issue e-Invoices for the donations received, thereby falling under the e-invoicing obligation in donation rules.

2. Treatment of Monetary Donations
Monetary contributions—regardless of the payment method (cash, cheque, bank transfer, etc.)—require e-Invoice issuance:

If a donor requests an e-Invoice: an individual e-Invoice must be issued.
If no request is made: a consolidated e-Invoice must be issued within 7 calendar days after month-end, covering all relevant transactions.
This reinforces the e-invoicing obligation in donation transactions, even when donors do not explicitly ask for documentation.

Refer to Sections 3.5 and 3.6 of the LHDN e-Invoice Specific Guideline for technical instructions.

3. Donations-in-Kind
For donations-in-kind (i.e., non-monetary items such as goods or services), no e-Invoice is required. This is an exception to the e-invoicing obligation in donation scenarios, where monetary value is not directly involved.

4. Donor’s Obligation to Self-Issue e-Invoices
Donors are not required to issue self-billed e-Invoices for donations or contributions made to organisations that are not tax-exempt under the Income Tax Act 1967. However, understanding when e-invoicing obligation in donation applies to recipient organisations remains crucial.

5. Religious Institutions Involved in Other Activities
Religious institutions or organisations managing places of worship are not required to issue e-Invoices for donations received.
However, if they engage in commercial activities, such as the sale of goods or provision of services, they must issue e-Invoices for those transactions.

Even in hybrid operational models, knowing the boundaries of the e-invoicing obligation in donation versus business income is essential for compliance.

6. Self-Billed e-Invoices for Imports and Foreign Services
Organisations, including those not approved for tax exemption, must issue self-billed e-Invoices for:

Imported goods, or
Services acquired from foreign suppliers,
if the criteria under Section 8.3 of the e-Invoice Guideline apply.

7. Obligation to Provide Buyer Information to Suppliers
Where a transaction involves activities for which consolidated e-Invoices are not allowed—such as purchase of motor vehicles, construction services, or materials—all buyers, regardless of tax-exempt status, are required to provide their identification details to the supplier.

8. Business Registration Number (BRN) for e-Invoice and TIN Purposes
Entities registered with any of the following can use their official registration number as their BRN when registering for a Tax Identification Number (TIN) or issuing e-Invoices:

Registrar of Societies (ROS)
Companies Commission of Malaysia (SSM)
Legal Affairs Division of the Prime Minister’s Department (BHEUU)
Other recognised regulatory bodies in Malaysia
Final Remarks
As e-Invoicing becomes a cornerstone of Malaysia’s digital tax landscape, it is essential for all types of organisations—including those receiving donations—to understand their responsibilities. Proper knowledge of the e-invoicing obligation in donation will ensure transparency, accountability, and alignment with LHDN’s broader digital transformation goals.

If your organisation is impacted and you require guidance on e-Invoice implementation, feel free to reach out to our team of tax technology specialists.
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Revolutionize e-invoicing with AI—secure, seamless, and compliant. Optimize workflows and automate business document exchange.

Anusaar is a next-gen SaaS-based e-invoicing software that automates financial operations and ensures tax compliance. ERP-agnostic and AI-powered, it streamlines workflows, reduces costs, and optimizes processes like AR, AP, and tax filings. With real-time analytics, advanced security, and seamless integration, Anusaar drives accuracy, efficiency, and financial control.

Our electronic invoicing system provides robust data extraction, validation, standardization, and secure archival, ensures precise and compliant e-invoicing. Built with enterprise-grade security, it boasts SOC 2 Type 2 and ISO 27001 certifications, delivering peace of mind and trusted compliance.




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