The implementation of e-Invoicing in Malaysia introduces a structured approach to invoice issuance for financial institutions while adhering to the Financial Services Act 2013 (FSA) and Islamic Financial Services Act 2013 (IFSA). Below is a summary of key considerations for financial institutions transitioning to e-Invoicing:

To comply with obligations under FSA and IFSA, financial institutions must obtain customers' consent before issuing individual e-Invoices. This ensures confidentiality and alignment with data protection standards.

For regulated industries, including financial institutions, it is not mandatory to disclose the statement or bill reference number in the "Description of Product or Service" field in consolidated e-Invoices. Institutions must input relevant and appropriate descriptions for this field.

Resident financial institutions conducting banking business must issue e-Invoices for income derived both within and outside Malaysia.

For income such as interest from fixed deposits, financial institutions must issue e-Invoices if requested by the customer. These e-Invoices can resemble periodic statements or bills, detailing amounts owed and payments or credits made.

Example: If a customer is requesting an e-invoice for all their monthly transactional charges (such as rebate, interest income on deposits etc.), Anusaar provides a custom solution by consolidating all their monthly transactions at customer-transactional level. Anusaar ensures that the generated e-invoice is aligned with the customer's expectations and delivers the required information accurately.

Financial institutions may issue consolidated e-Invoices for transactions where customers do not explicitly request an e-Invoice. Exceptions are outlined in Section 3.7 of the e-Invoice Specific Guideline.

While e-Invoices are required for interest charged on loans, they are not necessary for the repayment of loan principal amounts.

For interbank transactions, the lending bank must issue e-Invoices for interest charged to borrowing banks.

Premiums or upfront fees that are non-refundable require an e-Invoice to be issued.

For accounts with multiple account holders (e.g., joint, custodial, trust, or escrow accounts), one e-Invoice is typically issued for the principal account holder. Separate e-Invoices may be issued upon request by other account holders.

• Foreign Processors: Financial institutions must issue self-billed e-Invoices for charges paid.
• Local Processors:Local operators issue e-Invoices for fees received and may present them in XML or JSON format for visual representation.

Financial institutions must issue:

• Self-billed e-Invoices for fees paid to foreign agents.
• e-Invoices for fees charged to local recipients.

e-Invoices are required for non-refundable upfront payments. Refundable payments do not require an e-Invoice.

Cashbacks can be included in e-Invoices in XML or JSON format, detailing amounts owed and credits provided.

For reward points:

• Free points: No e-Invoice required.
• Redemption: e-Invoices are issued only for additional charges incurred beyond the redeemed value.

Financial institutions can include adjustments in subsequent e-Invoices rather than issuing separate credit, debit, or refund notes.

e-Invoices are not required for accounting adjustments such as:

• Realized or unrealized gains and losses.
• Amortization or accretion of premiums or fees.
• Foreign exchange gains or losses.

The e-Invoicing requirements for financial institutions ensure streamlined processes while upholding compliance with FSA and IFSA regulations. By adapting to these guidelines, institutions can maintain operational efficiency and transparency, fostering trust with customers and regulatory bodies alike.