Does Your GP Clinic Need to Use MyInvois? A Plain-English Guide to Malaysia's e-Invoice Mandate

If you run a GP clinic in Malaysia, you have probably heard the term MyInvois thrown around at conferences, WhatsApp groups, and from your accountant. Most clinic owners either assume they are already compliant, or assume the mandate does not apply to them yet. Both assumptions are often wrong.

This guide cuts through the confusion. By the end, you will know exactly whether your clinic is obligated to comply, when your deadline is, and what the consequences are if you miss it.

What Is MyInvois?

MyInvois is Malaysia's national e-Invoicing system, operated by the Inland Revenue Board of Malaysia (LHDN / IRBM). Under this system, every invoice your clinic issues — for consultations, medications, procedures — must be submitted to LHDN's MyInvois platform for validation before it is considered legally issued.

This replaces the traditional process where you issue a paper receipt or PDF invoice directly to the patient. Under MyInvois, the invoice goes to LHDN first, gets validated and stamped with a Unique Invoice Number (UIN), and then goes to the patient.

The goal of the mandate is tax compliance and digital economic reporting. Malaysia is following a model used by Italy, Turkey, and several Latin American countries where the tax authority acts as a clearinghouse for all commercial invoices.

Does Your Clinic Need to Comply?

The answer depends on your clinic's annual revenue. LHDN has rolled out the mandate in phases based on turnover.

Most independent GP clinics in Malaysia fall into one of two categories:

Revenue above RM 1 million — You are in Phase 4. Your mandatory start date was 1 January 2026. You currently have a 6-month relaxation period, which means LHDN will not aggressively penalise you for non-compliance until 1 January 2027. But the obligation began in January 2026, and you should be working toward compliance now.

Revenue below RM 1 million — You are currently exempt. In December 2025, the Cabinet raised the exemption threshold from RM 500,000 to RM 1 million, providing relief to smaller clinics and micro-enterprises. Unless your revenue crosses RM 1 million in a given year, you do not need to implement MyInvois.

The Linked-Entity Exception — Read This Carefully

Here is where many clinic owners get caught out. Even if your individual clinic revenue is below RM 1 million, you may still be obligated to comply if:

• Your clinic is a subsidiary of a larger company or healthcare group

• You share ownership with other businesses whose combined revenue exceeds the threshold

• You operate as part of a joint venture with another entity above the threshold

LHDN assesses the obligation based on the total revenue of the enterprise structure, not just the individual entity. A clinic earning RM 400,000 per year that is owned by a group with total revenue of RM 3 million will be required to comply.

If you are unsure whether your structure triggers this rule, consult your accountant before assuming you are exempt.

What Revenue Figure Does LHDN Use?

LHDN uses your audited financial statements from FY2022 to determine your phase. This is a point of confusion for many clinic owners who are looking at their current year revenue.

If you crossed the RM 1 million threshold in a year after 2022, LHDN gives you a grace period. You will be required to implement e-invoicing from 1 January of the second year after the assessment year in which your total turnover crossed the threshold.

Example: If your clinic first exceeded RM 1 million in 2025, your mandatory start date would be 1 January 2027.

What Happens During the Relaxation Period?

LHDN has introduced a 6-month relaxation period for Phase 4 businesses (January 2026 – June 2026). During this window:

• You can issue consolidated e-invoices for B2C transactions instead of individual invoices per patient

• LHDN will not actively pursue penalties for technical non-compliance

• You are still expected to be making good-faith efforts to implement the system

After the relaxation period ends (full enforcement from January 2027), every invoice must be individually submitted and validated. Consolidated invoices will no longer be acceptable for B2B transactions.

What Are the Penalties for Non-Compliance?

Under Section 82C(1) of the Income Tax Act 1967, failure to issue a compliant e-invoice carries:

• Fine: RM 200 to RM 20,000 per invoice

• Imprisonment: Up to 6 months

• Or both

To put this in financial terms: a clinic issuing 50 invoices per day, at a minimum fine of RM 200 per invoice, faces potential daily exposure of RM 10,000. Over a month, that is RM 300,000 in potential fines. These are not theoretical numbers — they are the legal penalties on the books.

LHDN has signalled that enforcement will be proportionate and will focus first on larger businesses. But the legal liability is real, and the protection offered by the relaxation period is not unlimited.

5 Questions to Determine Your Clinic's Exact Obligation

Use this checklist to confirm your compliance status:

1. What was your clinic's annual revenue in FY2022? If above RM 1 million, you are in Phase 4 with a January 2026 start date.

2. Is your clinic owned by or connected to a larger business group? If yes, check whether the combined group revenue triggers the obligation regardless of your individual revenue.

3. If your revenue is below RM 1 million today, when did it first exceed this amount? Your mandatory start date may still be in the future.

4. Does your clinic management software support MyInvois API submission? If not, you will need to either upgrade your software or manually submit through the MyInvois portal.

5. Have you registered on the MyInvois portal? Registration is separate from compliance — you need an account before you can submit anything.

What You Need to Do Next

If your clinic is in Phase 4 (RM 1M – RM 5M revenue), here is the minimum you need to do before full enforcement begins in January 2027:

1. Register your business on the MyInvois portal at myinvois.hasil.gov.my

2. Confirm whether your clinic management software supports MyInvois API submission or only manual portal upload

3. Run a test submission to verify the process works end to end

4. Establish a process for storing UINs against each invoice

If you are exempt (below RM 1 million revenue, no linked-entity issues), still consider whether voluntary adoption makes sense. Clinics that adopt early have fewer teething issues and are better positioned if your revenue grows.

A Note on Panel Billing and MyInvois

One question we hear constantly from clinic owners: does MyInvois apply to panel billing claims submitted to HealthMetrics or MediExpress?

Yes — but it is more nuanced than a simple yes. The e-Invoice obligation applies to the transaction between your clinic and the patient (and the TPA as payer). The TPA claim is a separate administrative process. We cover this in detail in our article on panel billing and MyInvois working together.

Medinex handles MyInvois submission automatically as part of every consultation — no separate login, no manual upload. Every invoice is validated by LHDN and the UIN stored against the patient record.

→ Book a demo to see how it works in practice.