LHDN is giving you until end-2027 to fix your e-Invoice mistakes. Here's how to talk to your accountant about it.
You are probably not the person who will do this work. But you are the person who signs off on it, pays for it, and carries the risk if it's done badly. This is what you need to know to have a useful conversation with your accountant or your software vendor and to tell the difference between a good answer and a confident one.
Last reviewed: 22 August 2026.
What SVDP is, in one paragraph
On 7 July 2026, LHDN opened a Special Voluntary Disclosure Programme for e-Invoices. If your business has been under the e-Invoice mandate for a while and you missed submissions, filed wrong ones, or left transactions out completely, you can go back and fix them without being penalised for those mistakes. The window closes 31 December 2027.
The protection covers what you disclose, provided the disclosure is done properly and in good faith. It does not cover fraud or deliberate avoidance. And it obviously doesn't cover anything you fail to find.
Does this apply to you?
If your annual turnover is above RM1 million, you have passed a mandatory implementation date and this applies. If you're below RM1 million and never opted in voluntarily, it generally doesn't ,though it's worth confirming how your threshold was actually calculated rather than assuming, especially if you're near the line or have multiple entities.
"But our system submits everything automatically"
It probably does submit most things automatically. The gaps aren't usually in the routine sales your system handles. They're in the transactions that sit outside the normal flow, and there are six common ones. Check whether any of these sound like your business.
Invoices a customer specifically asked for. When a buyer requests a proper e-Invoice, that transaction needs its own individual submission, it can't be folded into the monthly summary. These are the ones most likely to have been handled by someone manually, over WhatsApp or email, outside whatever your system does automatically. Sorted out for the customer, never filed with LHDN.
Big-ticket sales. Since 1 January 2026, any single transaction over RM10,000 needs its own individual e-Invoice. It can't be bundled into the monthly summary batch, even if the customer never asked for an invoice. Same for motor vehicle sales, flight tickets, and construction contracts. If your system was set to batch everything, your largest transactions may be sitting in the wrong place which is exactly where you least want a problem.
Money you paid out. This is the one that catches most owners. For certain payments, you are required to issue the e-Invoice, not the person you paid. Overseas software subscriptions. Payments to foreign suppliers. Commissions to agents, dealers or distributors. Rent to an individual landlord. Certain interest payments, though there are carve-outs here worth checking. These are called self-billed e-Invoices, and nothing in a normal purchase ledger flags them. If you've never heard the term, that's the signal to ask.
Timing here is also its own trap , imported goods and imported services each have their own deadline that isn't the invoice date.
Shopee and Lazada sales. For marketplace transactions, the platform issues the e-Invoice on your behalf. You are not supposed to submit those yourself. Two ways this goes wrong: your accountant looks at your own submissions, doesn't see the marketplace sales, and panics that everything's missing — or worse, submits them again, and now you have duplicates to disclose on top of everything else.
Rejected invoices that were never actually cancelled. If a customer rejects an e-Invoice, that document stays valid in LHDN's system until you cancel it. A rejection is a request, not a cancellation. Businesses that treat "customer rejected it" as "it's dealt with" end up with live documents they think are dead.
Credit notes and refunds. Cancelled a sale, gave a refund, adjusted an invoice each needs its own document filed. Easy to fix in your own books and forget in MyInvois.
Why this takes longer than you'd expect
The reasonable owner question is: it's all in LHDN's system, why can't someone just download it and compare?
You can download it. MyInvois gives you your records, sent and received. Getting the data isn't the bottleneck , the comparison is.
A comparison only works when both sides describe the same thing, and often they don't. Your books might show four hundred sales for the month; MyInvois might show one summary document covering all of them, with the receipt numbers buried in a text field. Nothing lines up row to row, so someone has to work out which transactions each record covers before a gap becomes visible. That part is manual, because no accounting system tags transactions by e-Invoice treatment to begin with.
The purchases side has its own catch. You'll see supplier documents once they're validated, so if nothing appears against a payment, it could mean the supplier hasn't submitted yet or submitted something that didn't go through. A blank isn't an answer. Someone has to ask the supplier, and that's phone calls, not software.
The practical implication: anyone selling you a one-click e-Invoice compliance scan is promising something the underlying data access discourages. That doesn't mean tools are useless , it means the honest ones will tell you where the manual work still sits.
What to ask, and what a good answer sounds like
Five questions. You don't need to understand the mechanics to judge the answers.
1. "What date did we actually become mandatory?" Good: a specific date, and how it was determined. Bad: vagueness, or working from turnover figures nobody can source.
2. "Have we checked the money we paid out, not just what we billed?" Good: they immediately mention self-billed, and name which of your payment types are affected. Bad: they only talk about sales. This is the single best test of whether they've thought about it properly.
3. "How are we handling the marketplace sales?" Good: they know the platform issues those and they're checking received documents, not just your own submissions. Bad: they treat marketplace sales the same as direct sales.
4. "How long will this take, and what's manual?" Good: a range, plus honesty that supplier chasing and classification can't be automated. Bad: "the system will handle it."
5. "Are we submitting by month?" Good: yes , LHDN wants previously unreported summaries filed against their own transaction months, not lumped together. Bad: they plan one big filing to cover everything.
What it costs you to do nothing
The window is long enough that it's easy to defer. Two reasons not to.
The work scales with how long you wait every additional month is more transactions to classify and more suppliers to chase. And the amnesty only protects what you disclose. Finding the gaps late in 2027 with a deadline overhead is a materially worse position than finding them now with time to fix them properly.
If nothing else, ask question 2 this week.
A note on sources
Based on LHDN's e-Invoice Guideline v4.7 and Specific Guideline v4.8, published 7 July 2026, and the MyInvois SDK documentation, both checked 22 August 2026.
Stated plainly: the SVDP provisions sit in Section 17 of Specific Guideline v4.8. The description of scope and month-by-month treatment here comes from LHDN's published summary and SDK notes rather than the Section 17 text directly, which I have not been able to pull from the guidelines page. Your tax agent should read it.
Written from an AI and automation background , 14 years in enterprise IT and AI across tech and e-commerce. This is not tax advice. Confirm your implementation date and treatment with a licensed tax agent or directly with LHDN before making any submission.