You are not required to reissue or split the consolidated e-Invoice for the past transaction. Once a consolidated e-Invoice has been correctly issued in accordance with the e-Invoice rules, it is considered final and compliant.
Under the e-Invoice Guideline and FAQ, consolidated e-Invoices are allowed only where buyers did not request an e-Invoice at the time of transaction. If a consolidated e-Invoice was properly issued because no request was made, the supplier has already fulfilled their e-Invoice obligation for that period. The Guideline does not require suppliers to retrospectively cancel, amend, or reissue a consolidated e-Invoice simply because a customer makes a late request in a subsequent month.
What happens next (practical treatment):
✅ The consolidated e-Invoice for the past month remains valid
❌ You cannot cancel the consolidated e-Invoice if more than 72 hours have passed. However, you may use a credit note to effectively "split" or remove a transaction from it if you choose to accommodate the buyer.
❌ You are not required to issue one, but you can do so provided you first issue a credit note against the consolidated e-Invoice to avoid double-counting your income
✅ For future transactions, once the customer has requested an e-Invoice:
- You must issue individual e-Invoices going forward
- Consolidation is no longer allowed for that customer
Example:
- Sales to Customer A occurred in January
- Customer A did not request an e-Invoice in January
- Supplier issued a consolidated e-Invoice for January sales in early February
- In March, Customer A requests an e-Invoice for January
✅Correct treatment:
- January consolidated e-Invoice remains unchanged
- Use credit note to detach the transaction from consolidated e-Invoice
- Submit the credit note document to MyInvois portal
Key takeaway:
A buyer’s late request does not automatically invalidate a consolidated e-Invoice, and you are legally protected if you deny them. However, the credit note is the "bridge" that allows you to legally amend the past if you decide that keeping the customer happy is worth the extra paperwork
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