TAX, e-INVOICE & FINANCE COMPLIANCE
e-Invoice in Malaysia for a recruitment fee and an HRD Corp course: what you get, and what you keep
Two invoices, one desk, different rules. One turns on the supplier's turnover; the other is not addressed to you.
Usually yes for the agency's placement fee, and usually no for an HRD Corp claimable course fee. The e-Invoice duty sits on whoever is selling, decided by their own turnover, so a supplier under RM3 million issues an ordinary receipt that LHDN still accepts as proof of expense. On a claimable course the training provider bills HRD Corp, not you.
- The duty is the supplier's. Your turnover does not decide whether you receive an e-Invoice.
- RM3 million is the floor, raised 30 August 2026 — most agencies and trainers sit below it.
- An exempt supplier's receipt is still proof of expense. LHDN says so in writing.
- You have to ask. Say nothing and you get a normal receipt.
- On a claimable course the course-fee invoice is raised to HRD Corp, not to you. You claim your allowances.
The invoice-level half of our e-Invoice employer guide. The tax on the same two documents is in SST on agency fees and SST on training fees.
Whose duty it is
Does a recruitment agency have to issue me an e-Invoice?
If the agency is inside the mandate, yes. A placement fee is an ordinary business service with no carve-out: the agency is the Supplier, you are the Buyer, and the agency's turnover decides it — not the size of your invoice.
The e-Invoice Specific Guideline says what the document does for you: it “can be used as the Buyer's proof of expense, to substantiate a particular transaction for tax purposes.” One distinction catches people out: the fee that found the person is in scope, the salary you then pay is not — IRBM lists employment income among the items for which “an e-Invoice (including self-billed e-Invoice) is not required”. What the fee buys is in our guide to recruitment agency fees.
RM3 million, since 30 August 2026
What if the agency or trainer turns over less than RM3 million?
Then it is probably exempt and you will get no e-Invoice. Guideline version 4.8, published 30 August 2026, exempts “taxpayers with an annual turnover or revenue of less than RM3,000,000” from issuing. Their ordinary receipt is still your proof of expense.
It replaced a RM1 million threshold, and LHDN's chief executive restated it on 1 October 2026:
“Those with business turnover below RM3mil do not need to implement e-invoice”
— Datuk Dr Abu Tariq Jamaluddin, Chief Executive Officer, LHDN, 1 October 2026
It is not a free pass: the exemption falls away where the supplier has a non-individual shareholder, holding company, related company or joint venture turning over at least RM3,000,000, so a small agency inside a group is back in scope. Our employer guide and our exemptions and thresholds page both predate the August revision — RM3 million is today's figure. Turnover and shareholding are the supplier's own facts, so ask the supplier in writing whether it issues e-Invoices before the invoice is raised.
The trap in the word ‘agent’
Do I have to issue a self-billed e-Invoice instead?
For a Malaysian recruitment agency, no. The self-billed list opens with payments to “agents, dealers, distributors”, which looks like a match and is not one: IRBM means a commission-earning intermediary, and it puts the duty to self-bill on the Seller paying that commission, under section 83A of the Income Tax Act 1967.
The Specific Guideline defines those parties as a “third party / intermediary” that “will earn commission on the sale of products or provision of services to customers”. An agency selling you its own service is not in that position. One real case remains: engage a recruiter or trainer outside Malaysia that does not use MyInvois, and IRBM requires you to self-bill to document the expense.
Not addressed to you
Who gets the e-Invoice for an HRD Corp claimable course?
HRD Corp does, on the claimable-courses route. HRD Corp splits the claim: providers claim course fees, employers claim allowances. So the course-fee invoice is raised to HRD Corp. Where you pay and reclaim, the provider invoices you and you upload it.
HRD Corp's claimable-courses FAQ (September 2021, pre-e-Invoice and still its only published word on this) states that split, and its worked example on licensed materials makes the addressing explicit: the provider issues “two (2) separate invoices; one to HRD Corp for the course fees and another to the employer”. HRD Corp has itself been on e-Invoice since 1 January 2025. Which route you are on is set out in SBL versus SBL-Khas.
| The transaction | Who issues | Buyer | What you hold |
|---|---|---|---|
| Placement fee, agency in the mandate | The agency | You | A validated e-Invoice |
| Placement fee, agency under RM3m | The agency | You | Its ordinary receipt, as proof of expense |
| Course fee, claimable-courses route | The provider | HRD Corp | Grant and claim records, no course-fee e-Invoice |
| Course fee you pay and reclaim | The provider | You | The receipt and invoice you upload |
| Supplier abroad, not on MyInvois | You | You | Your own self-billed e-Invoice |
From the IRBM Guideline v4.8 and Specific Guideline v4.9, and HRD Corp's FAQ and claim helper.
Ask, then hand over four things
What do I give the agency or trainer so the e-Invoice is right?
Ask before the invoice is raised, then supply your buyer details. IRBM puts the request on you: a buyer that wants an e-Invoice “would need to make a request by informing the Supplier accordingly”. Say nothing and you get a normal receipt.
- Your registered name as it reads at SSM, and your TIN.
- Your business registration number — the new 12-digit SSM format.
- Your SST registration number, if registered.
- Your address, contact number and e-mail for the validated document.
Transactions where the buyer did not ask are swept into a monthly consolidated e-Invoice filed within seven calendar days after month end.
What survives a review
What do I keep for the HRD Corp claim and for LHDN?
Keep the document you were actually given, plus the claim trail. HRD Corp's claim helper asks for an official receipt and tax invoice against course fees. LHDN warns separately that its own database is not your record. The safe reading is to keep both the supplier's own document and your grant paperwork.
HRD Corp's stated service level is “within eight (8) working days, provided the documents submitted are complete”. Its claim helper holds that document list and predates e-Invoice. Our claim guide walks the submission, the levy calculator shows what you spend against, and LHDN audit readiness covers what a reviewer asks for.
72 hours, then never
What if the e-Invoice is wrong?
You have 72 hours from validation to request rejection in the MyInvois Portal. After that no cancellation is allowed and the only route is a new credit, debit or refund note. For errors already filed, the PKPS programme allows correction without financial penalties until 31 December 2027.
IRBM is explicit: a buyer that spots an error “is able to request rejection of the e-Invoice within 72 hours from the time of validation via the MyInvois Portal”, and once the window closes, “no cancellation would be allowed”. The penalty for never issuing falls on the supplier — the general FAQs put it at RM200 to RM20,000 or up to six months' imprisonment for each non-compliance.
Still have questions?
e-Invoice on recruitment and training — employer FAQ
Is a recruitment agency's placement fee exempt from e-Invoice?
Can I claim an HRD Corp course without a validated e-Invoice?
Do I need an e-Invoice for the salary of the person we hired?
Sources
- IRBM e-Invoice Guideline v4.8 (30 August 2026)
- IRBM Specific Guideline v4.9 (7 September 2026)
- IRBM e-Invoice General FAQs
- HRD Corp e-Invoice
- HRD Corp Claimable Courses FAQ v4 — predates e-Invoice, cited only for the claim structure and document list
- HRD Corp claim helper — same basis
- The Star, 1 October 2026
Reviewed 5 October 2026. General information, not legal or tax advice.
Not sure which document you should be holding?
Send Steph the invoice you were given. Carriera sits on both sides of this paperwork: Agensi Pekerjaan Carriera Talent Resources Sdn Bhd is the licensed recruitment agency (JTKSM 615), and Carriera Academy Sdn Bhd is the HRD Corp Approved Training Provider. The live course calendar shows what is dated and claimable.
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