Dear Clients & Partners,
With Malaysia’s phased rollout of the IRBM e-Invoice mandate, it’s vital to understand where consolidated e-Invoices are prohibited. While consolidation can ease reporting for some businesses, the IRBM requires strict individual e-Invoicing for certain sectors and transaction types due to the need for clear audit trails, regulatory transparency, or industry-specific risks.
This newsletter details the industries, activities, and scenarios where only single, per-transaction e-Invoices are allowed — with examples to guide your compliance.
🔍 What is a Consolidated e-Invoice?
A consolidated e-Invoice combines multiple transactions from the same buyer into a single invoice, typically issued daily, weekly, or monthly.
🟢 Allowed for low-value, high-volume B2C transactions (like grocery or retail sales).
🔴 Not allowed when traceability, buyer identity, or itemization is required for compliance.
🚫 When Consolidated e-Invoices Are Not Allowed
1. B2B Transactions – Per Transaction Required
📌 Example: A wholesaler sells RM10,000 worth of IT equipment to a corporate client over three separate deliveries.
✅ Must issue three separate e-Invoices (one per delivery).
❌ Cannot issue one consolidated invoice at the end of the month.
Why: Input tax claims require invoice-by-invoice traceability.
2. Export of Goods
📌 Example: A manufacturer ships products to a client in Singapore across multiple dates.
✅ Each shipment must be accompanied by a unique e-Invoice.
❌ No monthly summary invoices allowed.
Why: Customs and cross-border authorities require invoice-specific documentation.
3. Transactions Involving Government Entities
📌 Example: A construction firm bills a state agency for progress billing on a public works project.
✅ Must issue an e-Invoice for each milestone payment.
❌ Cannot consolidate multiple payments into one invoice.
Why: Government procurement systems require per-payment audit trails.
4. High-Value or Regulated Goods/Services
Industries selling luxury or regulated goods must invoice each sale.
📌 Examples:
- A jeweler sells a diamond necklace (RM45,000)
- A machinery supplier delivers industrial equipment (RM250,000)
✅ Must issue e-Invoices per item sold.
❌ Cannot wait to consolidate monthly or bulk invoices.
Why: These sales often require valuation, insurance, or inspection documents.
5. Sectors With Specific Reporting Requirements
Certain industries are subject to financial regulations that mandate itemized reporting.
A. Financial Institutions
📌 Example: A bank charges a corporate client for multiple financial services (loan admin fee, forex fees, advisory).
✅ Must issue individual e-Invoices for each service.
❌ Cannot issue a monthly consolidated statement as a tax invoice.
B. Telecommunication Services
📌 Example: A telco issues mobile, broadband, and voice service charges to a business.
✅ Must split each billed line item on an e-Invoice.
❌ Cannot consolidate across multiple service types.
C. Healthcare Providers
📌 Example: A private hospital invoices for surgery, medications, and follow-up consultations.
✅ Each treatment or visit must be issued on separate or fully itemized e-Invoices.
❌ Cannot batch patient bills into one total invoice.
🧾 Summary Table
| Sector / Scenario | Consolidated Allowed? | Notes |
|---|---|---|
| B2C Retail (Low-value, cash sales) | ✅ Yes | Up to RM500 per invoice allowed |
| B2B Sales to registered companies | ❌ No | Per transaction required |
| Export Sales | ❌ No | Required for customs & tax trace |
| Government Transactions | ❌ No | Per transaction invoice needed |
| Banks / Insurance | ❌ No | Regulated, needs itemization |
| Telco / Utility Services | ❌ No | Must itemize usage |
| Hospitals / Clinics | ❌ No | Full medical billing required |
| Jewelers / Machinery Dealers | ❌ No | High-value goods |
| Food Stalls / Pasar Malam Vendors | ✅ Yes | Simplified invoice allowed under RM500/day |
✅ How NEBULA Can Help
Our IRBM-Compliant e-Invoice Module for Microsoft Dynamics 365 Business Central includes:
✔ Automated detection of industries/transactions that disallow consolidation
✔ Real-time IRBM submission and validation
✔ Configurable e-Invoice templates by document type (Sales Invoice, Credit Note, etc.)
✔ QR code integration and compliance formatting
✔ Flexible B2C/B2B handling and customer profiling
📩 Need a Demo or System Review?
Let us help you stay fully compliant. Contact us today at [hello@nebulaerpsolution.com] or connect with your NEBULA account consultant.
Stay compliant. Stay confident.
– NEBULA ERP Solution Team
Scalable Ideas. Vocational Solutions.