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 Wave 2 of ZATCA e-Invoicing: Scaling up Compliance

On January 1, 2023, Wave 2 of the Zakat, Tax, and Customs Authority e-invoicing was launched. It targets businesses with revenues above SAR 500,000,000. The compliance requirements that were introduced in Wave 1 were extended to a larger segment of medium-large businesses. The aim was to embed tax compliance, digitalization and transparency in the Saudi Arabian economic ecosystem. 

Target Groups and Focus

Wave 2 was for enterprises that generate substantial revenue but are smaller than those covered by Wave 1. The businesses should have a technological infrastructure that can adapt to the requirements of e-invoicing. This wave focused on enhancing digital readiness and preparing business for interoperability.

Mandatory Compliance Requirements

  • E-Invoice generation and structuring:
    • Businesses had to produce e-invoices, and documents related (credit/debit note) in formats such as XML, PDF/A-3 or embedded XML.
    • Include mandatory fields like VAT registration numbers and invoice dates. Line item details as well as tax amounts are also important.
  • QR Code Implementation:
    • Inclusion of QR codes in simplified invoices has become mandatory. This allows customers and ZATCA to verify the authenticity.
    • The QR code encodes key information such as VAT number, invoice dates, and tax amounts.
  • Data Integrity and security:
    • It was necessary to store e-invoices securely for future audits, in order to ensure data accuracy and access.

Introduction of Interoperability Standards

Wave 2 included a requirement that businesses integrate their E-invoicing systems with ZATCA Fatoora. This ensured the:

  • Easy submission of e-invoices: To submit and verify invoices in real time, businesses had to connect with ZATCA’s system.
  • Error detection and prevention: Integration enabled ZATCA’s database to check invoices, minimising non-compliance risk.

Digital Features Available

Wave 2 reinforced the use of digital signatures for invoice authentication and security. The invoices are now legally binding and tamper proof. 

Impact and Benefits

Wave 2 widened the compliance framework of ZATCA, covering a greater portion of the sector and contributing towards Vision 2030 for the Kingdom. Inclusion of medium-large businesses further streamlined the tax collection process and increased transparency.

This phase also prepared businesses to move on to wave 3  where revenue thresholds would be lowered and new industries targeted. Wave 2 consolidated the foundations for e-invoicing in Saudi Arabia by focusing on system readiness and interoperability.