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A woman in office wear at her desk in a Kuala Lumpur office, checking a printed progress claim against her laptop, hemmed in by tall stacks of bound invoice paperwork in late afternoon light

Can You Prove Every Progress Claim Above RM10,000 Has Its Own e-Invoice?

Insights 4 Min read September 10, 2026

The answer

Yes, and in almost every case it must. Since 1 January 2026, any single transaction above RM10,000 must be issued as an individual LHDN-validated e-Invoice. It cannot sit inside a monthly consolidated batch. Nearly every progress claim clears that threshold.

Why this rule catches property developers specifically

Consolidated e-Invoices exist for businesses with high volumes of low value transactions, typically retail. Property billing is the opposite shape. Low volume, high value.

A progress claim on a RM600,000 unit at a 20 percent certified stage is RM120,000. It was never eligible for consolidation. But many billing teams built their monthly workflow before the threshold existed, and have not revisited it since.

The risk is habit, not ignorance. A team that batches by default will batch a RM120,000 claim without anyone making a decision.

The Five Check Test

Run this against last month's submissions before the next batch goes out.

  1. Value check. Is the single transaction above RM10,000? The threshold applies per transaction, not to the cumulative total for one buyer, and not to your monthly revenue from that buyer.
  2. Batch check. Is it currently inside a consolidated submission? If so, it has to come out.
  3. Buyer check. Does the individual e-Invoice carry the purchaser's own details, rather than a general description?
  4. Validation check. Was it validated through MyInvois before issue, and can you retrieve the validation reference on demand?
  5. System check. Is the threshold enforced by your system, or by somebody remembering? Configure the rule so any transaction above RM10,000 routes to individual issuance automatically.

The fifth check is the only permanent one. The first four will pass this month and fail in March when a new admin joins.

What can and cannot be consolidated

Developer transactionTypical valueConsolidation allowed
Progress claim on a certified stageTens of thousands upwardNo. Individual e-Invoice required
Booking feeOften RM1,000 to RM10,000Only where the single transaction is not above RM10,000
Late payment interestVariesDepends on the value of the single transaction
Miscellaneous admin chargesSmallGenerally yes, subject to the same test

The operative wording sits in the LHDN e-Invoice Specific Guideline. Cite that rather than a software vendor summary. Secondary sources differ slightly on whether the threshold reads as above RM10,000 or RM10,000 and above. Treat RM10,000 itself as requiring an individual e-Invoice and you are on the safe side either way.

Frequently asked questions

Does the Phase 4 relaxation period cover this?

No. The relaxation period allows eligible businesses to use consolidated e-Invoices with general descriptions during the transition. The threshold rule for high value single transactions is excluded from that relief and remains in force throughout.

What if the purchaser never asks for an e-Invoice?

It makes no difference. The threshold applies regardless of whether the buyer requests one. Buyer preference does not override the requirement, and a developer cannot rely on the absence of a request to justify consolidation.

What are the penalties for getting this wrong?

Secondary sources report a range of RM200 to RM20,000 per non-compliant invoice under the Income Tax Act 1967, though they disagree on the applicable section. Confirm the current position against the guideline. The exposure is per invoice, not per batch.

Does this apply if we are still inside a relaxation period?

Yes. The rule applies to all mandated businesses regardless of implementation phase, and across business to business, business to consumer and business to government transactions. Phase does not change the threshold.

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