This article is also available in Bahasa Malaysia and Chinese.
If you have ever looked at your MyInvois submissions and thought "I'm not sure all of that went through properly" — this article is for you.
On 7 July 2026, HASiL (LHDN) introduced the e-Invoice Special Voluntary Disclosure Programme (SVDP) through Section 17 of the e-Invoice Specific Guideline (Version 4.8). It gives businesses a defined window to come forward, correct historical e-Invoice mistakes, and have those mistakes accepted in good faith — without penalties, enforcement action or prosecution on the disclosed items.
The window closes on 31 December 2027. After that, the same gaps found during a HASiL review are simply non-compliance.
Most SMEs we speak to are not deliberately avoiding anything. They switched systems mid-year, misread which transactions needed a consolidated e-Invoice, or had submissions rejected that nobody went back to fix. The SVDP exists precisely for those situations.
First: are you still in scope?
This changed after the SVDP was announced, and it changes who needs to read the rest of this article.
On 30 August 2026, LHDN raised the e-Invoice exemption threshold to RM3 million in annual turnover or revenue (e-Invoice General Guideline Version 4.8, §1.6.1(e), effective 1 September 2026). If your business is now exempt, LHDN has confirmed that you are not required to participate in the SVDP — even if you have gaps in what you previously submitted — and you may stop issuing e-Invoices immediately, with no penalty for the period you missed.
So before reconciling anything:
- Under RM3 million turnover, and you pass the ownership test? You are likely exempt. The SVDP is probably not your concern — read our guide to the RM3 million exemption instead.
- At or above RM3 million? You remain in scope. The SVDP applies to you, and the rest of this article is written for you.
- Under RM3 million, but you have a corporate shareholder, holding company, related company or joint venture at RM3 million or more? The ownership test in §1.6.10 disqualifies you from the exemption. You are still in scope, and the SVDP still matters.
That last case is the one businesses get wrong. Confirm which side of the line you are on before deciding you can ignore either the mandate or this programme.
Who should apply?
The programme is aimed at taxpayers who fall into one of four categories. Read them against your own records:
- You did not submit certain e-Invoices from your mandatory implementation date onwards.
- You submitted e-Invoices containing errors or information that did not meet HASiL's requirements.
- You missed e-Invoices for a particular period or transaction type — a month that slipped, or a category you did not realise was in scope.
- You are undergoing, or have been notified of, a HASiL e-Invoice compliance review.
Does this sound like your business?
A quick self-check — if any of the following sounds like your business, the SVDP is worth a conversation.
- ✓ You went live on MyInvois but are not confident every month was submitted
- ✓ Some invoices were rejected by MyInvois and never resubmitted
- ✓ You issued normal invoices for transactions you later learned needed an e-Invoice
- ✓ Your consolidated e-Invoices were skipped, late, or lumped together
- ✓ You changed accounting software and the submission trail broke
- ✓ Self-billed e-Invoices for foreign suppliers were never raised
The common thread is good faith. This is a route for businesses that want to put things right voluntarily — not a shelter for deliberate under-reporting.
How it works
Participation is a reconciliation exercise before it is a submission exercise. The sequence that works:
- Confirm your mandatory implementation date. Everything is measured from the date your business entered the e-Invoice mandate — get this wrong and the whole review is scoped wrong.
- Reconcile your accounting records against your MyInvois records. Invoice by invoice, month by month. This is where the real work sits, and where the gaps actually surface.
- Separate your findings by transaction type and month. Sales, credit notes, self-billed, consolidated — they are corrected differently.
- Prepare and submit the corrections using the SVDP document versions.
- Retain your reconciliation and supporting documents. Your disclosure needs to be evidenced, not asserted.
SVDP 1.2 and 1.3 — which one?
HASiL released two document versions specifically for this programme, and standard e-Invoice versions will not do:
| Version | Use it when |
|---|---|
| SVDP 1.2 | Submitting without a digital signature |
| SVDP 1.3 | Submitting with a digital signature |
Both can only be used during the SVDP window. Your software or MyInvois batch upload templates may need updating before you can select them, so check this early rather than in December 2027.
One detail that catches people out: where missing consolidated e-Invoices span several months, they must be submitted against the relevant transaction month — not combined into a single catch-up submission.
The timeline
| Date | What it means |
|---|---|
| 7 July 2026 | SVDP window opened |
| Now → mid-2027 | Reconcile and correct — the sensible working period |
| 31 December 2027 | Final deadline. Last day to disclose |
| From 1 January 2028 | Gaps are ordinary non-compliance again |
Eighteen months sounds generous. It is not, if you have three years of records across two accounting systems and a December year end competing for your finance team's attention.
The real benefit: what you are protected from
HASiL's position is that where a disclosure is made in good faith and is complete and accurate, it will not pursue e-Invoice compliance reviews, enforcement action, penalties or prosecution in relation to the matters disclosed.
In practice, that converts an open-ended worry into a closed file. You stop carrying an unknown liability into your next audit or financing conversation.
But the protection is conditional. Here is the honest picture:
| You are protected when | Protection does not apply when |
|---|---|
| Disclosure is made voluntarily and in good faith | The disclosure involves fraud or wilful default |
| The information is complete and accurate | There is negligence in the disclosure |
| Corrections are submitted using SVDP 1.2 / 1.3 | The submitted e-Invoices still do not comply |
| Supporting records are retained | The information given is inaccurate or incomplete |
| You stay compliant going forward | You fail to act in good faith |
Two points worth being blunt about.
First, a half-disclosure is worse than none. The relief attaches to what you disclose properly. An incomplete submission does not buy protection for the parts you left out — and it puts your file in front of HASiL anyway.
Second, the SVDP addresses the e-Invoice compliance layer. It is about whether and how invoices went through MyInvois in the correct format. It does not repair an underlying transaction that was never reported or taxed correctly. If your reconciliation uncovers that kind of issue, it needs separate advice before you file anything.
Separately — and worth asking about while you are reviewing your setup — there are accelerated capital allowance rules for e-Invoice implementation costs, covering qualifying ICT equipment and the development or customisation of software. If you have invested in getting compliant, some of that spend may be claimable faster than normal. Conditions apply, so confirm your position before relying on it.
Common questions
Does disclosing put me on HASiL's radar? This is the fear that stops most businesses, and it is the wrong way round. The gaps already exist in HASiL's data — MyInvois knows what was validated and what was not. Disclosure is what converts a discoverable problem into a closed one.
Do we need to register or apply for the programme? No. HASiL has confirmed there is no separate registration or application to participate. You regularise the non-compliance within the SVDP period using the correct e-Invoice version — typically by issuing a credit note e-Invoice to reverse the incorrect one, then issuing a corrected e-Invoice.
We disclosed already, then found more problems. Can we disclose again? Yes. Additional voluntary disclosures can be submitted during the SVDP period as further non-compliance comes to light, provided they land before 31 December 2027. You are not locked into a single submission.
We have several companies in a group. Can we file one disclosure for all of them? No. Each entity must submit its own voluntary disclosure. A group-level filing is not accepted — plan for separate reconciliations per company.
Our software vendor caused the errors. Does that change anything? You can still participate, but it does not shift responsibility. HASiL is explicit that compliance remains the taxpayer's obligation regardless of any third-party service provider or system vendor appointed.
We are already under a compliance review. Are we too late? Not necessarily. Taxpayers undergoing or notified of a review are named in the eligible categories. The specifics of your case matter here, so take advice before responding.
What if we find issues but cannot fix everything by December 2027? Start with the highest-value and highest-frequency gaps. A prioritised, well-documented reconciliation is far stronger than a scramble in the final quarter.
Do we need new software? Not necessarily, but you do need the SVDP document versions available in whatever you use. Check with your provider now — not the week you plan to submit.
What to do next
If any of the self-check boxes above applied to you, the next step is a reconciliation between your accounting records and your MyInvois submissions. That single exercise tells you whether you have an issue, how big it is, and what disclosing would involve.
We can run that review for you. KL CONSULT PLT works remotely with SMEs across Malaysia and Singapore, and e-Invoice reconciliation is exactly the kind of work our tax advisory and compliance service handles day to day. A first conversation costs nothing and carries no obligation.
- Book a free consultation → Contact us
- Prefer to scope it first? → Request an itemised quote
New to the e-Invoice mandate, or unsure whether you are still in scope after the threshold increase? Start with our guide to the RM3 million exemption.
Sources: e-Invoice Specific Guideline Version 4.8, Section 17 (published 7 July 2026 under Section 134A of the Income Tax Act 1967); e-Invoice General Guideline Version 4.8, §1.6.1(e) (published 30 August 2026) for the RM3 million exemption; and the official e-Invoice FAQ. Note that the General and Specific Guidelines are separate documents that both carry a version 4.8.
This article is general guidance current at the date of publication, not advice for your specific circumstances. Programme terms and guideline versions are updated by HASiL from time to time — confirm the current position before acting. KL CONSULT PLT is a remote-first practice whose team are members of the Malaysian Institute of Accountants (MIA) and the Association of Chartered Certified Accountants (ACCA), providing tax advisory, accounting and fractional CFO services to SMEs, with audit and company secretarial delivered through independent allied firms.