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ZATCA e-Invoicing Phase 2: Applicability, Rules and Regulations in Saudi Arabia

Updated on :  

08 min read.

e-Invoicing was introduced in Saudi Arabia (SA) as an extension of the economic renaissance and digital transformation. This initiative is in line with achieving positive results of raising consumer protection and reducing hidden economy transactions.

Zakat, Tax and Customs Authority (ZATCA) or Authority issued the requirements, technical specifications, controls and procedural rules for implementing phase 2 of e-invoicing in SA. Also, it issued XML implementation standards, e-invoice security features implementation standard and a data dictionary for Phase 2 that are effective from 1st January 2023.

Phase 2 regulations are important for taxpayers to comply with phase 2 . i.e., the integration phase. Under phase 2, the businesses must integrate their POS/ accounting systems with the Authority’s system for 

  • Clearance of tax invoices and related Credit and Debit Notes (CDNs) and 
  • Reporting of simplified tax invoices and related CDNs.

23rd December 2022
ZATCA announced that the businesses in KSA with greater than SAR 500 million turnover falls under the second targeted group/ wave 2 under phase 2 of e-invoicing. They must complete integrating their ERP/POS with ZATCA’s Fatoorah portal between 1st July 2023 to 31st December 2023.

Visit the ZATCA portal for more information.

Phases of e-Invoicing in Saudi Arabia

ZATCA introduced e-invoicing in SA on 4th December 2021 by releasing the electronic invoicing regulation. Also, it planned to implement e-invoicing in two phases, .i.e, phase 1 and phase 2.

Phase 1 of Saudi e-Invoicing

Phase 1 is effective from 4th December 2021. This phase mandates taxpayers to generate and store tax invoices, simplified tax invoices and respective CDNs through compliant e-Invoicing Generation Solutions (EGS).

Phase 2 of Saudi e-Invoicing

Phase 2 will be implemented from 1st January 2023. This phase mandates integrating the taxpayer’s system with the ZATCA, transmitting e-invoices and related CDNs and sharing them with ZATCA. Phase 2 will be implemented by the ZATCA, notifying the criteria for the resident taxpayers and their effective date, the earliest being 1st January 2023.

Applicability of Phase 2 of ZATCA e-Invoicing

ZATCA planned the implementation of the integration phase in waves. Accordingly, ZATCA announced the targeted groups/waves under phase 2 of e-invoicing in Saudi Arabia as follows:

  1. Wave 1 under phase 2: Businesses registered under KSA VAT with more than SAR 3 billion turnover in 2021 fall under wave 1 and must implement phase 2 from 1st January 2023.
  2. Wave 2 under phase 2: VAT-registered businesses in KSA whose turnover is more than SAR 500 million in 2021 fall under wave 2 and generate phase 2 compliant e-invoices from 1st July 2023.

Also, ZATCA finalised the phase 2 regulations regarding operational and technical requirements. So, the applicable businesses in SA should start taking relevant actions to comply with phase 2.

e-Invoicing Phase 2 Regulations

ZATCA released the phase 2 regulations on 28th May 2021, containing phase 1 and phase 2 requirements. However, ZATCA mentioned that the requirements listed under phase 2 of e-invoicing would be reviewed and amended in due course. Accordingly, ZATCA amended and released the final phase 2 regulations on 24th June 2022.

Key Amendments in e-Invoicing Regulations

ZATCA has considered the taxpayers feedback who participated in the phase 2 e-invoicing pilot testing program while amending the Phase 2 regulations. Also, it reflected a few changes in ZATCA’s IT model.

Below are the few key changes made by the ZATCA in the XML implementation standards and the data dictionary:

  • Amended the data fields between mandatory, conditional and optional
  • Modified the business rules for validation of the XML invoices
  • Revised the process on authentication of the taxpayer’s EGS with ZATCA
  • Removed the categorisation of a Value Added Tax (VAT) identification number into a Group VAT number and individual VAT number

Authority started notifying the phase 2 regulations with taxpayers under the first wave of the phase 2 e-invoicing regime. Also, it is expected that ZATCA will notify the next waves based on the taxpayer’s turnover, along with phase 2 implementation dates.

Impact of Phase 2 of e-Invoicing on Businesses

VAT-registered businesses in Saudi Arabia having taxable supplies above SAR 3 billion during 2021 are required to implement Phase 2 of e-invoicing from 1st January 2023. Also, non-compliant businesses will be penalised as per the VAT legislation.

Applicable businesses should comply with obligations under the phase 2 regulations as per the ZATCA’s notification. Also, they need to take relevant steps in making the required changes in their business and information technology landscape.

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