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e-Invoice Special Voluntary Disclosure Programme (SVDP) Malaysia: Fix past e-Invoice mistakes without penalties

LHDN will not review, penalise or prosecute e-Invoices you disclose in good faith under the SVDP by 31 December 2027, provided the SVDP submissions themselves comply. Here is how to fix them so the fix itself does not fail.
Reading Time: 16 minutes
LHDN e-Invoice SVDP = Special Voluntary Disclosure Programme (Program Khas Pengakuan Sukarela / PKPS e-Invois). In simple terms: a chance for businesses to fix missed or incorrect e-Invoices with protection from certain enforcement actions, subject to conditions. It runs from 7 July 2026 to 31 December 2027.
🔑Key Takeaways
  • The e-Invoice Special Voluntary Disclosure Programme (SVDP) runs from 7 July 2026 to 31 December 2027. E-Invoices disclosed under it face no compliance review, penalty or prosecution, subject to good faith and compliant SVDP submissions. (e-Invoice Specific Guideline v4.9, Sections 17.2 to 17.4)
  • Taxpayers already under, or notified of, an e-Invoice compliance review are still covered. The relief does not apply to fraud, wilful default or negligence, or to SVDP submissions that themselves fail the specifications. (Specific Guideline v4.9, Sections 17.1(d) and 17.4)
  • No registration is needed. Issue a credit note to reverse the wrong e-Invoice, then a new e-Invoice tagged SVDP 1.2 (without digital signature) or SVDP 1.3 (with digital signature). (Inland Revenue Board of Malaysia (LHDN) General FAQs, 4 September 2026, Q123 and Q127)
  • SVDP 1.2 and 1.3 submissions may carry a backdated Issuance Date and Time from your phased mandatory implementation date, for example 1 August 2024 onwards. Batch Upload users need the latest template. (MyInvois (LHDN’s e-Invoice system) Software Development Kit (SDK) release note, 8 July 2026)
  • Back-filed consolidated e-Invoices go one per month of transaction, never as a lump sum, and any single transaction exceeding RM10,000 (RM10,000.01 and above) still needs its own e-Invoice. (Specific Guideline v4.9, Section 17.6, Examples 23 and 24)
  • Appointing a vendor does not move the liability. Vendor-caused errors can be fixed under the SVDP, but responsibility stays with the taxpayer, and each group entity files its own disclosure. (LHDN General FAQs, Q30, Q132 and Q133)

The e-Invoice Special Voluntary Disclosure Programme (SVDP) is an amnesty window, open from 7 July 2026 to 31 December 2027, for taxpayers to regularise missed or wrong e-Invoices. LHDN (Lembaga Hasil Dalam Negeri Malaysia, the Inland Revenue Board of Malaysia, IRBM) will not undertake compliance reviews or enforcement action, including penalties and prosecution, on e-Invoices disclosed under it, provided the disclosure is made in good faith and the SVDP submissions themselves meet the specifications. (e-Invoice Specific Guideline v4.9, Sections 17.2 to 17.4)

There is no registration or application. You reverse the faulty e-Invoice with a credit note and submit a correct one under document version SVDP 1.2 or SVDP 1.3, and since 8 July 2026 you may enter the actual, backdated issuance date. This guide is for finance teams that have found gaps in their MyInvois record (MyInvois is LHDN’s e-Invoice validation system) and want to fix them once, correctly. It sits inside our complete guide to LHDN e-Invoicing in Malaysia.

Verified against the e-Invoice Specific Guideline v4.9 (7 September 2026), the e-Invoice General Guideline v4.8 (30 August 2026), the LHDN e-Invoice General FAQs (updated 4 September 2026) and the MyInvois SDK release note of 8 July 2026, on 20 October 2026.

What the e-Invoice SVDP covers, and what it does not

The SVDP covers four situations and excludes two. Coverage is wide on purpose: it reaches taxpayers that never issued a single e-Invoice, and taxpayers already facing a compliance review. The scope sits in Section 17 of the e-Invoice Specific Guideline.

Situation Position under the SVDP Source
Missed e-Invoices for any period since your mandatory implementation date Covered Section 17.1(a)
E-Invoices submitted with errors or information that does not meet the specifications Covered Section 17.1(b)
No e-Invoices submitted at all for any period or transaction since the mandatory date Covered Section 17.1(c)
Taxpayer currently undergoing, or notified of, an e-Invoice compliance review Covered Section 17.1(d)
SVDP submissions that do not themselves comply with the prescribed specifications Relief does not apply Section 17.4(a)
Disclosure involving fraud, wilful default or negligence Relief does not apply Section 17.4(b)

Two conditions sit on top of the table. Acceptance is subject to the taxpayer acting in good faith, and accuracy and proper submission remain the taxpayer’s responsibility (Section 17.2). The first exclusion, Section 17.4(a), therefore turns data quality into the real risk: a back-filing run that produces new validation failures can cost you the relief on exactly the e-Invoices you meant to protect.

Important: This article covers only the e-Invoice SVDP in Section 17 of the Specific Guideline. LHDN has run separate voluntary disclosure programmes for other taxes, including income tax and stamp duty, each with its own rules and dates. Do not apply their terms to e-Invoices, or the e-Invoice terms to them.

Which fix do I use? SVDP, cancel, credit note or exemption

Not every e-Invoice error needs the SVDP. Match the situation to the fix before you start.

Situation Fix SVDP version needed? Source
Error found within 72 hours of validation Cancel the e-Invoice and issue a new correct one Optional FAQ Q126
Error found after 72 hours, such as an incomplete buyer address or a wrong classification code Credit note e-Invoice reversing the original, then a new correct e-Invoice Yes, for the new e-Invoice FAQ Q127, Q128
E-Invoice never issued New e-Invoice carrying the actual transaction date as Issuance Date and Time Yes, backdating applies to SVDP versions only SDK release note, 8 July 2026
Transactions left out of a relaxation-period consolidated e-Invoice Credit-note the earlier consolidated e-Invoice and reissue it in full, or issue a separate consolidated e-Invoice for the omitted transactions Yes, within the SVDP window FAQ Q131
Already corrected before 7 July 2026 No cancellation or resubmission needed, if the earlier correction was in good faith and accurate No FAQ Q125
Mandated only under the former RM1 million threshold (revenue has never reached RM3 million) and the Section 1.6.10 criteria are met SVDP not required for omitted e-Invoices; you may stop issuing No FAQ Q19; General Guideline v4.8, Section 1.6.10

The 72-hour window runs from validation by LHDN. Inside it, e-Invoice cancellation is the simpler route, and our guide to how to amend or cancel an e-Invoice covers the mechanics. Once it closes, the credit note and reissue route in the second row applies, and the SVDP is the route that carries protection from penalties.

The last row is easy to misread. The exemption in Q19 applies only if the taxpayer meets the criteria in Section 1.6.10, including its related-company tests. A taxpayer whose revenue falls below RM3 million after being mandated at or above it stays mandated (FAQ Q104). Our e-Invoice SME exemption guide explains who qualifies, so check it before you conclude that you can stop.

How to regularise e-invoice compliance under the SVDP: step by step

The sequence below takes a finance team from reconciliation to a clean MyInvois record. Run it per legal entity, because each entity discloses separately.

Step 1: Reconcile your ledger against MyInvois

Compare your sales ledger or enterprise resource planning (ERP) invoice register with the validated documents in MyInvois, starting from your own mandatory implementation date. For example, Phase 1 started on 1 August 2024, Phase 2 on 1 January 2025, Phase 3 on 1 July 2025 and Phase 4 on 1 January 2026; businesses that commenced in 2023 to 2025 with revenue of RM3 million or more started on 1 July 2026 (General Guideline v4.8, Table 1.1 and Section 1.5).

Step 2: Classify each gap

Sort every difference into one of three buckets:

  • Missed: never issued.
  • Wrong: issued but non-compliant.
  • Omitted: left out of a consolidated e-Invoice.

The decision table above maps each bucket to its fix.

Step 3: Split by month and pull out transactions exceeding RM10,000

Group missed consolidated transactions by month of transaction, never across months (Section 17.6). Remove every single transaction exceeding RM10,000 (RM10,000.01 and above) and prepare it as its own e-Invoice. Our RM10,000 e-Invoice rule guide sets out the rule, and our guide to issuing a consolidated e-Invoice covers the monthly format.

Step 4: Issue credit notes for the wrong e-Invoices

Reverse each defective e-Invoice with a credit note e-Invoice (LHDN General FAQs, Q127). The MyInvois SDK publishes SVDP 1.2 and SVDP 1.3 versions of every document type, including credit, debit and refund notes and their self-billed equivalents (MyInvois SDK, Document Types page), so the whole correction can run on SVDP versions. LHDN’s FAQ does not say the credit note must carry one, so agree the rule with your tax adviser before you run it in bulk.

Step 5: Submit the new e-Invoices as SVDP 1.2 or SVDP 1.3

Use SVDP 1.2 if you submit without a digital signature and SVDP 1.3 if you sign (Section 17.5). Enter the actual, backdated Issuance Date and Time, as the MyInvois SDK release note of 8 July 2026 allows. The SDK release note tells integrators to update their integration and Batch Upload users to download the latest template first, and the note does not describe manual MyInvois Portal entry, so confirm that route with MyInvois before planning a portal-only fix. Never use these versions for normal, non-SVDP submissions (Section 17.5).

Step 6: Check the validation results and fix errors

Every SVDP e-Invoice submission still goes through e-Invoice validation, and a failure puts the relief at risk. Where an SVDP e-Invoice contains incorrect or incomplete information, correct it through a debit, credit or refund note e-Invoice (FAQ Q130).

Step 7: File further disclosures by 31 December 2027

If you find more gaps later, submit another disclosure inside the window (FAQ Q129). Our roundup of the latest Malaysia e-Invoicing FAQs tracks LHDN’s SVDP answers as they change. LHDN encourages disclosure as soon as a gap is identified (FAQ Q124), so there is no benefit in holding batches back.

Worked examples from LHDN

LHDN’s own examples show the rules in practice. Three are worth copying.

  • Four months, four consolidated e-Invoices. Starship Sdn Bhd failed to submit consolidated e-Invoices for January to April 2026. It must submit four separate consolidated e-Invoices, one per month, and may not aggregate them into one. (Specific Guideline v4.9, Example 23)
  • One large sale, its own e-Invoice. Nutrion Sdn Bhd missed February 2026: ten transactions below RM10,000 each, plus Transaction Z at RM12,000. Transaction Z needs its own transactional e-Invoice, and the other ten may be consolidated if no buyer requested an individual e-Invoice. (Specific Guideline v4.9, Example 24)
  • A wrong classification code across a whole product line. A bookstore had issued every e-Invoice under classification code 022 (Others) when book sales should have used 026 (subscription of books, journals, magazines, newspapers and other similar publications). It must credit-note the earlier e-Invoices and reissue them with the right code. (LHDN General FAQs, Q128)

The pattern is consistent: the SVDP corrects the record transaction by transaction and month by month, and it never relaxes the underlying rules.

Groups, vendors and the SDK: three traps for larger businesses

Three traps hit larger finance functions hardest.

  1. No group-wide disclosure. A group of companies cannot file one SVDP disclosure for all entities. Each taxpayer submits its own (FAQ Q132). Plan one reconciliation and one submission run per legal entity.
  2. A vendor’s fault is not a defence. You may use the SVDP where a third-party service provider or system vendor caused the non-compliance, but responsibility remains with the taxpayer (FAQ Q133). For a company, that responsibility rests with its director as defined in section 2 of the Income Tax Act 1967 (FAQ Q30).
  3. SVDP versions are narrow by design. SVDP 1.2 and 1.3 may be used only for SVDP disclosures and never for normal submissions (Section 17.5), and only until 31 December 2027. SVDP 1.2 keeps the Invoice v1.0 structure and SVDP 1.3 keeps v1.1, with no new fields (MyInvois SDK, Document Types page), and all existing validation rules still apply unless the SDK says otherwise (MyInvois SDK release note, 8 July 2026).

The third trap catches teams that treat the SVDP as a relaxation of data standards. The SVDP relaxes the consequence of past errors, not the validation rules your back-filed e-Invoices must pass.

What happens after 31 December 2027

The SVDP window closes on 31 December 2027, the same day the Phase 4 relaxation period ends for businesses with RM3 million to RM5 million in revenue, and for new businesses in that band. Penalty enforcement for that group starts on 1 January 2028 (Specific Guideline v4.9, Table 16.1; General Guideline v4.8, Section 1.6.1(e) for the RM3 million floor). The relaxation covers taxpayers with revenue of up to RM5 million only, so it does not describe the position of Phase 1 to 3 taxpayers.

Section 17 grants relief only for disclosures made within the window. A gap found after it closes falls back under the normal penalty provisions, covered in our guide to LHDN e-Invoice penalties. Businesses already in the relaxation track should read the Phase 4 extension to 2028 explainer alongside this one.

What your e-Invoicing system must support for the SVDP

A back-filing run fails or succeeds on system capability. Whether you submit through an ERP integration, middleware or Batch Upload, put these five questions to your provider in writing before you start, and ask JomeInvoice the same questions:

  • Can the system tag a submission as SVDP 1.2 or SVDP 1.3 and keep those tags out of normal submissions?
  • Can it send a backdated Issuance Date and Time from your mandatory implementation date?
  • Can it split missed consolidated transactions by month of transaction?
  • Can it flag every single transaction exceeding RM10,000 (RM10,000.01 and above) for its own e-Invoice?
  • Can it link each credit note to the e-Invoice it reverses?

JomeInvoice is e-Invoicing middleware that custom-integrates with your existing ERP, point-of-sale or accounting system through application programming interface (API) or secure file transfer protocol (SFTP), so your finance team does not carry the build. Built-in Tax Identification Number (TIN) verification helps keep buyer data clean before a back-filing run. For a multi-entity group, the JomeInvoice enterprise solution is the place to start a migration assessment of your current setup.

Frequently Asked Questions

Q: What is the e-Invoice SVDP?
A: The e-Invoice SVDP is LHDN’s Special Voluntary Disclosure Programme for missed or wrong e-Invoices, open 7 July 2026 to 31 December 2027. Disclosed e-Invoices face no compliance review, penalty or prosecution if disclosed in good faith and SVDP submissions meet the specifications. [Specific Guideline v4.9, Sections 17.1 to 17.4]

Q: When does the e-Invoice SVDP end?
A: 31 December 2027. Any voluntary disclosure intended for the SVDP must be submitted within the period of 7 July 2026 to 31 December 2027, including additional disclosures made after the first one. [FAQ Q123, Q129]

Q: Do I need to register or apply for the SVDP?
A: No. No separate registration or application is required. Issue a credit note e-Invoice to reverse the earlier e-Invoice, then a new e-Invoice with the correct information, using version SVDP 1.2 or SVDP 1.3. [FAQ Q123, Q127]

Q: What is the difference between SVDP 1.2 and SVDP 1.3?
A: SVDP 1.2 is for submissions without a digital signature and SVDP 1.3 is for submissions with one. SVDP 1.2 keeps the Invoice v1.0 structure and SVDP 1.3 keeps v1.1, with no new fields, and normal e-invoice validation rules still apply. [FAQ Q123; MyInvois SDK, Document Types page and release note]

Q: Can I backdate the issuance date of an SVDP e-Invoice?
A: Yes, on SVDP 1.2 or SVDP 1.3 submissions only. You may enter a backdated Issuance Date and Time from your applicable phased mandatory implementation date, for example 1 August 2024 onwards. [MyInvois SDK release note, 8 July 2026]

Q: Can I join the SVDP if I am already under an e-Invoice compliance review?
A: Yes. The SVDP expressly covers taxpayers currently undergoing, or notified that they will undergo, an e-Invoice compliance review. Relief still excludes fraud, wilful default or negligence. [Specific Guideline v4.9, Sections 17.1(d) and 17.4]

Q: Can I submit SVDP e-Invoices through the MyInvois Portal?
A: It depends. Batch Upload users must first download the latest Batch Upload template that supports SVDP 1.2 and SVDP 1.3. The release note does not describe single-document manual entry, so confirm that route with MyInvois before planning a portal-only fix. [MyInvois SDK release note, 8 July 2026]

Q: Can a group of companies file one SVDP disclosure?
A: No. Each taxpayer submits its own voluntary disclosure, so every entity in a group with e-Invoice non-compliance files separately. [FAQ Q132]

Q: My e-Invoicing vendor caused the error. Can I still use the SVDP?
A: Yes. You may participate, but responsibility for compliance stays with the taxpayer even though a vendor was appointed. For a company, that responsibility rests with its director. [FAQ Q133, Q30]

Fix the record while the window is open

The SVDP rewards taxpayers who disclose early, accurately and month by month, and it ends on 31 December 2027. Reconcile each entity, choose the right fix per gap, and treat the validation result of every SVDP submission as the real test.

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Disclaimer: This article is for general informational purposes only and does not constitute legal or tax advice. LHDN guidelines are subject to updates. Always refer to the latest official LHDN e-Invoice Guidelines at myinvois.hasil.gov.my and consult a qualified tax professional for advice specific to your business.

Last updated: 20 October 2026 | Written by Yinn Sheng Ng, Head of Marketing

References

To learn more about how JomeInvoice can transform your e-invoicing processes, check out JomeInvoice’s website or book a demo.

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