E-invoice 2025: Annual Turnover <RM150k Common Questions

Post title 'Can I Say No? (E-invoice Under 150K FAQ)' on green banner overlaying a thumbnail of Bispoint E-invoice 2025 trainer

Feeling pressured to issue e-invoices—even if your revenue is below RM150K? You’re not alone.

As Phase 2 of Malaysia’s e-Invoice implementation rolls out, more businesses—big and small—are feeling the pressure to comply, even when they technically fall below the RM150,000 annual revenue threshold.

Many small business owners are confused when customers insist on getting an e-invoice—especially when your turnover hasn’t even reached RM150K.

So, should you issue one anyway? Or are you allowed to say no?

In your day-to-day operations, you might be facing questions like:

📌 Some customers request only an e-invoice, but is it acceptable not to issue a consolidated e-invoice?

📌 You issue an e-invoice under “Deposit” instead of “Sales.” Will that cause any issues with LHDN?

📌 Your turnover is below RM150K, but a client still asks for an e-invoice. What’s the right move?

Jump ahead to the quick FAQ guide below to help clear the confusion and walk you through what you can and don’t have to do during this transition.

And if you’re curious about the broader impact of e-Invoicing under Phase 2, scroll down for details on our upcoming public workshop to learn everything you need to know to master e-invoicing.

LHDN-Compliant E-invoicing FAQ for <150K Businesses

1. My business earns less than RM150K. A customer is asking for an e-invoice—can I issue one without submitting a consolidated e-invoice later?

Technically, you’re not required to issue e-invoices if your annual turnover is below RM150K. But if you choose to start issuing them—even for just one customer—it’s advisable to go all in and follow through with the full e-invoicing process, including submitting a consolidated e-invoice (if applicable).

Switching between issuing and not issuing e-invoices can create unnecessary complications—and may even raise questions with LHDN later.

Since you’re not yet in the mandatory category, take time to consider your approach. Think carefully about whether you want to voluntarily adopt e-invoicing for your business. If you decide to go ahead, be consistent. You shouldn’t issue e-invoices for some customers and skip them for others.

2. When I issue an e-invoice, can I record it under a ‘Deposit’ account instead of a ‘Sales’ account?

It depends on the nature of the deposit:

Refundable deposits: No e-invoice is required, so recording it as a deposit is fine.
Non-refundable deposits: Even if you record it under “Deposit,” the nature of the payment makes it a sale. In this case, you must issue an e-invoice.

Always consider the substance of the transaction—not just the account label.

3. My vendor’s turnover is under RM150K. Do I still need to issue a self-billed e-invoice for the expense?

No. If your vendor’s annual revenue is below RM150K, they’re not required to issue e-invoices, and you don’t need to issue a self-billed e-invoice either.

For documentation, you can just collect a regular invoice, bill, or receipt from them, as allowed under LHDN’s guidelines.