LHDN has uploaded its updated e-Invoice Compliance Review Framework to its official portal effective 15 December 2025.

This confirms one thing clearly :

e-Invoice is no longer a “learning phase”. Honeymoon is over. Enforcement has started.

Key points SME owners should note:

• LHDN is actively checking e-Invoice compliance
• Selection is risk-based, using computer analysis – not random
• No surprise visits, but a formal 14-day Visit Notification Letter will be issued
• Reviews are on-site only, not desk reviews
• Officers will examine sales, purchases, bank records, debit/credit notes and supporting documents
• Messy records = wider scope of review

Important timeline many overlook :

• Review scope is usually up to 2 Years of Assessment
• BUT if non-compliance is found, under ITA s121(1) and PITA s59(1), LHDN can take legal action up to 12 years later

Other points to remember:

• You may request postponement if key staff are unavailable (with valid reasons)
• Overseas records for Malaysian transactions must be available locally
• Only registered tax agents can represent taxpayers
• Non-compliance is treated as a tax offence, not an admin issue

e-Invoice is now a director-level tax risk issue, not just accounting or IT work.

SMEs should prepare before the visit letter arrives.