Do we need an e-Invoice for a donation, or is our LHDN receipt still enough?

This isn't a general impression or something DonorCARE has inferred from the wider e-Invoice rollout — LHDN published a document specifically about this question: Implementation of e-Invoice in Malaysia: Frequently Asked Questions (FAQs) for Donations or Contributions, dated 7 July 2025 ^[1]. As of today (28 September 2026), that specific FAQ is still current: the e-Invoice Guideline (Version 4.8, 30 August 2026) cites it by question number as the source for the donations carve-out ^[2], and the newest e-Invoice Specific Guideline (Version 4.9, 7 September 2026) lists it again as a live reference ^[3]. So this FAQ itself hasn't been superseded — but the guideline documents around it are revised often, which is why this article carries a three-month review cadence rather than an annual one.

The rule, in plain terms

LHDN's default position is that e-Invoices — either an individual one or a monthly consolidated one — are required for donations or contributions received. The FAQ then carves out two exceptions ^[1]:

1. Religious institutions or organisations established exclusively for religious worship or the advancement of religion. A temple, mosque, church or similar body that only does that is exempt from e-Invoicing donations. LHDN notes explicitly that this exemption "will be reviewed and updated from time to time" ^[1] — it is not a permanent guarantee.
2. Anyone else receiving donations that are not tax-exempt under the Income Tax Act 1967. If your organisation isn't approved for tax-exempt status at all, there's no e-Invoice requirement for those donations either ^[1].

There's an important carve-back into exception 1, though. If your religious institution is also an approved institution/organisation/fund (an "IOF" in LHDN's own shorthand) — under subsection 44(6), 44(6B), 44(11B), 44(11C) or 44(11D) of the Income Tax Act — or you manage a charity or community project approved under paragraph 34(6)(h), the religious exemption stops applying to you. You're back to being required to issue e-Invoices on donations, the same as any other approved charity ^[1] — subject to the general turnover exemption below.

Two more plain-language points the FAQ settles directly: donations in kind (goods, not money) never need an e-Invoice, regardless of who receives them ^[1]. And donors are never required to self-bill an e-Invoice for a donation made to an organisation that isn't tax-exempt-approved ^[1]. That carve-out is narrow, though — it covers donors, and only for the donation itself. It does not touch your own organisation's separate self-billing duties: any person, religious institution or not, and regardless of its donation exemption, must still self-bill an e-Invoice for goods imported from outside Malaysia or services acquired from a foreign supplier, wherever LHDN's rules require it ^[1].

Selling goods or services alongside your donations

Many temples, dharma centres and religious bodies do more than collect donations — ancestral tablets, ceremony bookings, vegetarian meals, books, hall rentals. The worship-only donation exemption above covers donations and contributions only. LHDN's own FAQ is explicit that it stops there: an institution managing a place of worship that also sells goods or provides services is not required to issue e-Invoices for the donations it receives, but is required to issue e-Invoices for any goods sold or services it renders — even while the donation side stays exempt ^[1]. If your organisation sells anything, that sale sits under the ordinary e-Invoice rules (subject to your own turnover exemption, below) — it's a separate question from how you treat a donation, and the two don't share one answer.

If you're an approved organisation: receipt, e-Invoice, or both?

For organisations that do have to issue e-Invoices on donations (a non-exempt-religious approved IOF, or a religious body that also runs an approved charity project — and whose own turnover is at or above the RM3,000,000 general exemption threshold below), LHDN spells out exactly how the pre-printed official receipt and the e-Invoice interact ^[1]. LHDN's own s44(6) Guideline for approved IOTs (LHDN.600-1/7/3, 23 October 2025) sets out the identical mechanism, in more operational detail, for organisations approved under subsection 44(6) specifically ^[7]:

• If the donor asks for an e-Invoice: issue an individual e-Invoice. You no longer need to also issue the pre-printed official receipt for that donation — the e-Invoice itself is what substantiates the gift for the donor's tax purposes. No separate approval from LHDN is needed to do this, as long as the e-Invoice meets the standard requirements ^[7]. If your organisation's turnover is under RM5,000,000, this isn't mandatory yet, even on donor request: the interim relaxation period (see "The general small-taxpayer exemption" below) lets you decline and issue a consolidated e-Invoice instead, until 31 December 2027 — with no prosecution action under section 120 of the Income Tax Act 1967 during that period ^[3].
• If the donor doesn't ask for one: keep issuing the pre-printed official receipt exactly as you do now. On top of that, you must also file a consolidated e-Invoice within seven calendar days after month-end, aggregating the receipt numbers of every donation that didn't get an individual e-Invoice that month. That seven-day timing is unchanged under the current e-Invoice Specific Guideline (Version 4.9, 7 September 2026) ^[3], and matches the s44(6) Guideline's own wording exactly ^[7].

Three further details the s44(6) Guideline spells out, that the donations FAQ doesn't ^[7]:

• Incomplete donor particulars default you to consolidated filing. If a donor doesn't supply complete information about themselves, treat that donation the same as one where no e-Invoice was requested — fold it into the monthly consolidated e-Invoice rather than issuing an individual one.
• Your receipt's approval wording carries over into the e-Invoice. The fixed footer your pre-printed receipt already carries — "Potongan Di Bawah Subseksyen 44(6) Akta Cukai Pendapatan 1967", your approval reference number and its validity period — must also be entered into the e-Invoice's "Keterangan Produk atau Perkhidmatan" (Description of Product or Service) field, matching the receipt exactly, whether the e-Invoice is individual or consolidated.
• From 1 January 2026, a donation over RM10,000 in a single transaction is meant to carry the donor's complete information and an individual e-Invoice — but whether that bites you today depends on your turnover, and LHDN's two documents don't say the same thing plainly. The s44(6) Guideline's own words: "Mulai 1 Januari 2026, bagi penerimaan derma atau hadiah wang melebihi RM10,000 dalam satu transaksi, penderma wajib mengemukakan maklumat lengkap seperti yang dinyatakan dalam Lampiran 1, Garis Panduan e-Invois untuk tujuan pelaksanaan e-Invois." ("From 1 January 2026, for a donation or monetary gift received exceeding RM10,000 in a single transaction, the donor must supply complete information as set out in Appendix 1 of the e-Invoice Guideline, for e-Invoice implementation purposes.") ^{[7, §4.10(e) Note iii]} Read alone, that sounds like a settled floor. But the e-Invoice Specific Guideline (Version 4.9, 7 September 2026) puts this exact transaction size on its own list of activities where consolidation is not allowed from 1 January 2026 — "All industries — Any single transaction with a value exceeding RM10,000... effective starting 1 January 2026" ^{[3, §3.7.2 item 7]} — while that same guideline's interim relaxation (§16.1–16.2(a)) lets a taxpayer with turnover up to RM5,000,000 keep issuing consolidated e-Invoices for every transaction, including everything on that §3.7 list, until 31 December 2027, with no prosecution under Income Tax Act s120 in the meantime provided the relaxation's own conditions are met ^{[3, §16.1–16.3]}. A taxpayer above RM5,000,000 and up to RM25,000,000 had that relaxation end on 31 December 2025 ^{[3, §16.1]}. The s44(6) Guideline's Note (iii) says nothing about this relaxation either way ^[7]. So: from 1 January 2026, the rules expect an over-RM10,000 donation to carry the donor's details and an individual e-Invoice; an organisation with turnover up to RM5,000,000 may still fold it into the monthly consolidated e-Invoice until 31 December 2027; an organisation already above that band cannot rely on consolidation for a transaction this size. Confirm your own turnover band and relaxation status with LHDN or your advisor before treating either document as the whole answer — if your turnover is RM5,000,000 or below, you are still inside the relaxation.

In other words, for most donors who never ask about e-Invoices, nothing changes about the receipt they receive — the new filing obligation runs quietly in the background, to LHDN, once a month.

If your organisation wants to use some other electronic receipt format instead of a compliant e-Invoice, that needs LHDN's separate sign-off ^[1][7] — and the monthly consolidated e-Invoice filing is still required regardless ^[1].

Getting set up: BRN, TIN and the free MyInvois Portal

If your organisation does need to issue e-Invoices, LHDN's donations FAQ also settles the registration mechanics ^[1]:

• Registered bodies (registered with ROS, SSM or BHEUU) use that registration number as their Business Registration Number (BRN) for e-Invoice purposes.
• Non-registered bodies use the stamp certificate number of their governing document (constitution, charter, trust deed and so on), as stamped by LHDN — not the adjudication number, a different reference on the same paperwork and the easier of the two to reach for by mistake.
• Branches may issue e-Invoices under their head office's TIN and BRN, or register their own if they operate independently, using their own separately stamped governing document.
• You don't need to buy anything to start: LHDN provides the MyInvois Portal free of charge for issuing e-Invoices ^[1].

The general small-taxpayer exemption — and why it may cover you too

Separately from the donation-specific rules above, LHDN exempts taxpayers below a turnover threshold from e-Invoicing altogether — and this exemption is not limited to ordinary businesses. As of today, the current e-Invoice Guideline (Version 4.8, 30 August 2026), §1.6.1(e), sets that threshold at RM3,000,000 of annual turnover or revenue, and §1.6.10 states explicitly that it "applies to all categories of taxpayers" ^[2]. LHDN's e-Invoice implementation timeline page, last updated the same day, states the same RM3,000,000 figure directly ^[4].

This wasn't always RM3,000,000. An earlier version of the same guideline — Version 4.6, updated by LHDN/IRBM on 7 December 2025 — set the threshold at RM1,000,000, itself a rise from an earlier RM500,000 ^[5]. Version 4.8 supersedes Version 4.6: same issuer, same numbered guideline series, nine months later. If you've seen RM1 million or RM500,000 quoted elsewhere — including in earlier drafts of DonorCARE's own material — that's the superseded figure. RM3,000,000 is current as of today, 28 September 2026.

If you're a 44(6)-approved IOT, you may also see RM500,000 quoted in LHDN's own s44(6) Guideline (23 October 2025), which restates this same exemption purely by cross-reference to "perenggan 1.6, Garis Panduan e-Invois" (paragraph 1.6 of the e-Invoice Guideline) — that RM500,000 is simply a snapshot of what paragraph 1.6 said on the s44(6) Guideline's publication date, superseded by the same RM1,000,000-then-RM3,000,000 rises described above, so RM3,000,000 is what the cross-reference resolves to today ^[7].

The only carve-outs from this RM3,000,000 exemption are group-ownership tests, not entity type: a taxpayer with a non-individual shareholder whose own turnover is RM3,000,000 or more, a taxpayer that's a subsidiary of a holding company with turnover of RM3,000,000 or more, or a taxpayer with a related company or joint-venture arrangement above the threshold ^[2]. There is no separate carve-out, and no separate exception, for NPOs, IOFs or religious institutions as such — the general turnover exemption sits on top of, and independently of, the donation-specific rules earlier in this article.

One more limit worth knowing: even an organisation with turnover above RM3,000,000 but under RM5,000,000 currently has an interim relaxation period running until 31 December 2027 ^[6].

None of this tells you your own organisation's e-Invoice implementation date on its own — that depends on your actual turnover in a specific past year, and once LHDN has fixed your date, later changes to your turnover don't move it ^[2]. Confirm your own turnover and status directly with LHDN or your advisor; don't rely on a ringgit figure from this article, or anywhere else, without checking the guideline version and date attached to it — this one has moved twice in nine months.

What this means for you

• Work out which category you're in, then check your turnover. Religious-worship-only with no separate approved charity project, or everyone else — that decides whether the donation-specific rules apply to you at all. Then check your own turnover against the RM3,000,000 exemption above, independently of that answer.
• If you sell goods or provide services — tablets, meals, hall bookings, ceremonies — those need e-Invoices under the ordinary rules regardless of the donation exemption — though your own turnover exemption still applies.
• If you're exempt today, don't assume you'll stay exempt. LHDN has said the donation carve-out is reviewed periodically, and the turnover threshold itself has changed twice in nine months — both times upward (RM500,000 → RM1,000,000 → RM3,000,000). Put a reminder against this article's three-month review cycle, or your own compliance calendar.
• If you're required to e-Invoice, decide your default: will staff always offer donors the individual e-Invoice, or wait for a request and rely on the monthly consolidated filing? Either is compliant; it's an operational choice, not a legal one. And if your turnover is under RM5,000,000, you are not required to issue an individual e-Invoice even when a donor asks — the interim relaxation runs to 31 December 2027, with no prosecution under s120 in the meantime ^[6]. Consolidated filing is enough until then.
• In-kind gifts stay exactly as they are. No e-Invoice question applies to them at all.
• Confirm any ringgit figure on the day you need it. RM3,000,000 is current as of today, but check LHDN's guideline version and date before you act on it — don't rely on a number from this article or anywhere else that isn't dated today.
• This is not a ruling on your organisation specifically. Whether your NPO counts as "established exclusively for religious worship," whether a particular activity counts as an "approved charity or community project," and what your own turnover-based exemption status is, are facts-and-circumstances questions. Confirm your own position with LHDN or a tax advisor before changing what you issue to donors.

If your organisation does need to issue e-Invoices for donations, DonorCARE's e-Invoicing feature is built to automate the split LHDN describes above: it issues an individual e-Invoice, using the donor's TIN on file, when the donor has requested one, and rolls everything else into the monthly consolidated filing automatically. LHDN's free MyInvois Portal covers the same requirement manually, if you'd rather not automate it.