The e-Invoice Exemption Increased to RM3Million : What It Means For Your Hotel?

Malaysia has raised the e-Invoice exemption threshold from RM1 million to RM3 million (LHDN Guideline v4.8 & FAQs, effective 1 Sept 2026). If your hotel earns below RM3 million a year, you may now qualify to be exempt from issuing e-Invoices. Here's a clear, honest look at where you stand, and what's worth weighing before you switch anything off. 

For hotel owners, however, being below the RM3 million threshold doesn't automatically mean you should stop issuing e-Invoices. Before making any changes, there are two questions worth asking:

1. Does your hotel actually qualify for the exemption?
2. If it does, does stopping e-Invoice make sense for your business?

Let's look at both.

Check If Your Hotel Actually Qualifies?

Being under RM3 million isn't the whole test. There's an ownership check that catches more hotels than people expect.

Quick check: You are NOT exempt if any of these apply:

For e-Invoice exemption eligibility, check whether your hotel:

• Has a corporate shareholder earning RM3 million or more annually;
• Is a subsidiary of a holding company earning RM3 million or more annually; or
• Has a related company or joint venture earning RM3 million or more annually.

So a small property owned by a hotel group, or with a corporate shareholder, generally stays required, regardless of its own revenue. If you stand alone, owned by individuals, you likely qualify. And if you do qualify and want to stop, LHDN asks for no application or approval. You may simply discontinue (p/s: August 2026 submission is still required, because the effective date is from 1st Sept 2026).

If You're Exempt, Should You Stop Issuing e-Invoices?

You can. But whether you should is a different question. Here are four things worth considering. 

1. You May Need e-Invoice Again as Your Hotel Grows 

Once your revenue reaches RM3 million and you become mandated, the exemption can't be reclaimed even if revenue later dips. Growing hotels who stop now often face a full re-setup within a year or two, the stop-start costs more than staying steady.

2. Think About Your Corporate and Business Guests

Company bookings, MICE, and corporate travelers need a validated e-Invoice to claim their own tax deductions. A hotel that can issue one has an edge over a hotel that can't. This is about protecting bookings, not just compliance.

3. OTA Bookings Are Still Your Responsibility Anyway

Under the Principal-Agent rule, the hotel is the principal and issues the e-Invoice; the OTA is only the agent who sells on your behalf (depends on your arrangement & agreement with the OTAs). You can't pass this duty to the OTA, so being e-Invoice set up or remain simply keeps it smooth.

4. You've Already Done the Hard Part

For hotels that have already implemented e-Invoice, think about how much you have invested into getting there.

You may have already:

• Set up or integrated the necessary systems;
• Collected the required e-Invoice information from customers and suppliers;
• Trained your team;
• Established internal processes and SOPs; and
• Adjusted your daily accounting and operational workflows.

Keeping it on costs you lesser; turning it off saves little and reintroduces manual work later; but stop-and-restart later highly likely costs you more.

So, What Should Your Hotel Do?

If you're genuinely exempt and want a simpler setup, you're free to pause. But for most growing, corporate-serving, or group-linked hotels, staying on e-Invoice is the lower-risk, lower-cost path, and it keeps you ready for guests and rules alike. 
If you're weighing to stop or continue e-invoice decision, my one suggestion: don't let a threshold quietly set your ambition. Check whether you truly qualify, then decide based on where your businesses are going, not just where your business is  today.
Growth comes with responsibilities. I'd rather you carry them than avoid them.

Source: LHDN e-Invoice General FAQs (updated 4 September 2026) and e-Invoice Guideline v4.8 (30 August 2026).
Disclaimer: This article is general information to help you think through your options and is not tax advice. Every business's circumstances differ, please confirm your position with your licensed tax agent or advisor before deciding.