ZATCA Phase 2 E-Invoicing (Saudi Arabia)
ZATCA Phase 2 (the "integration phase") requires Saudi VAT-registered businesses to connect their invoicing systems to the FATOORA platform in waves ordered by annual revenue, with thresholds now down to SAR 375,000 under Wave 24. Your wave, and therefore your deadline, is set by your taxable revenue, and ZATCA notifies each wave at least six months in advance. Non-integrated businesses face escalating fines and cannot issue legally valid tax invoices.
Fakten zuletzt geprüft: 2026-07-12
Fristen & Phasen
| Phase | Wer ist betroffen | Frist | Anforderung |
|---|---|---|---|
| Phase 1 — Generation | All resident VAT-registered businesses | Since 2021-12-04 | Generate & store compliant e-invoices; no ZATCA integration required |
| Phase 2 — Waves 1–9 | Revenue above SAR 3 billion down to SAR 30 million | 2023-01-01 to 2024 (completed) | FATOORA integration live: clearance (B2B/B2G) and 24-hour reporting (B2C) |
| Phase 2 — Wave 23 | Revenue above SAR 750,000 (2022–2024) | 2026-01-01 to 2026-03-31 (completed) | FATOORA integration required |
| Phase 2 — Wave 24 (lowest threshold to date) | Revenue above SAR 375,000 (2022–2024) | By 2026-06-30 (deadline passed) | FATOORA integration required — the current binding wave |
| Phase 2 — future waves | Revenue below SAR 375,000 | Not yet announced (as of July 2026) | ZATCA will notify each new wave at least six months ahead |
What Phase 2 actually requires
Phase 2 moves e-invoicing from standalone generation to real-time integration with ZATCA. Standard tax invoices (B2B and B2G) must be cleared by ZATCA before you hand them to the buyer: your system sends the UBL 2.1 XML invoice to FATOORA, ZATCA validates and cryptographically stamps it, and only then is it legally valid. Simplified (B2C) invoices are issued directly to the customer and reported to ZATCA within 24 hours.
Every e-invoice must be produced as UBL 2.1 XML — or PDF/A-3 with the XML embedded — and carry a Base64 QR code, a Cryptographic Stamp Identifier issued when you onboard your invoicing solution, a 36-character UUID, and a Previous Invoice Hash that chains each invoice to the one before it. That combination means spreadsheet invoicing and most legacy accounting systems cannot comply without an upgrade or a certified middleware layer.
How the waves work
ZATCA rolls Phase 2 out in waves defined by annual VAT-taxable revenue, starting with the largest businesses. Wave 1 (2023) covered taxpayers above SAR 3 billion; by Wave 23 the threshold had fallen to SAR 750,000 (deadline 31 March 2026), and Wave 24 — announced in September 2025 — brought it down to SAR 375,000, with a compliance deadline of 30 June 2026. Each wave is announced publicly, and ZATCA notifies affected taxpayers directly at least six months before their integration deadline.
As of Wave 24, most VAT-registered businesses with revenue above SAR 375,000 in 2022, 2023 or 2024 should already be integrated with FATOORA — no lower wave has been announced yet, but the trend points toward full coverage. If you have not been notified, check your revenue against the latest wave criteria on zatca.gov.sa rather than assuming you are exempt; the six-month runway is short for an ERP integration project.
Getting compliant: build, buy or integrate
There are three realistic paths: use accounting software that is already ZATCA-integrated, connect your existing ERP through a certified middleware layer, or build the integration into your custom system. The right choice depends on how customized your invoicing flow is — high-volume or industry-specific flows usually need the integration built into the system that owns the invoice data.
Dictode builds ZATCA-compliant invoicing into custom ERPs and its own accounting platform — XML generation, stamping, hash chains, FATOORA onboarding and the operational monitoring that keeps clearance running when ZATCA is slow or offline.
Penalties for non-compliance
ZATCA applies a warning-first policy: the first time a field inspection finds an e-invoicing violation, you typically get a warning and a correction window (30–60 days) rather than an immediate fine. Repeat or more serious violations carry financial penalties — non-issuance or non-archiving of e-invoices starts at SAR 5,000, incorrect amendment or cancellation of an e-invoice starts at SAR 10,000, and failing to integrate with FATOORA after notification starts at SAR 10,000 and climbs to SAR 50,000 for repeated breaches.
These e-invoicing penalties are separate from ZATCA's general tax fines-cancellation initiative (extended to 31 December 2026), which waives late-registration, late-payment and late-filing penalties but explicitly excludes e-invoicing and Phase 2 integration violations — so there is no current amnesty for missing your FATOORA deadline. Invoices issued outside the compliant flow are also not valid tax invoices, which puts your customers' input-VAT deduction at risk.
Compliance-Checkliste
- Confirm your wave: compare your 2022–2024 VAT-taxable revenue against the latest ZATCA wave criteria (Wave 24: SAR 375,000) on zatca.gov.sa
- Audit whether your invoicing system can produce UBL 2.1 XML with a QR code, cryptographic stamp, UUID and Previous Invoice Hash chain
- Onboard your e-invoicing solution unit(s) on the FATOORA portal to receive your Cryptographic Stamp Identifier
- Implement the clearance flow for B2B/B2G invoices and the 24-hour reporting flow for B2C invoices, including rejection and resubmission handling
- Run ZATCA's sandbox conformance tests before your notified go-live date
- Train finance staff on rejected-invoice handling, correction/credit notes, and the hash-chain implications of voided invoices
- Keep a compliance log — a warning from a field inspection is your one grace window before fines apply
Häufig gestellte Fragen
What is the difference between ZATCA Phase 1 and Phase 2?
Phase 1, mandatory since 4 December 2021, requires generating and storing compliant e-invoices with no ZATCA connection. Phase 2 (the integration phase, since 2023) adds real-time integration with ZATCA's FATOORA platform: B2B/B2G invoices must be cleared by ZATCA before issue, and B2C invoices reported within 24 hours.
How do I know which ZATCA wave I am in?
Waves are defined by your VAT-taxable revenue in 2022, 2023 or 2024. As of Wave 24 (deadline 30 June 2026), the threshold is SAR 375,000 — check the current wave criteria on zatca.gov.sa against your revenue; ZATCA also notifies targeted taxpayers directly at least six months ahead.
What format do ZATCA e-invoices use?
UBL 2.1-based XML, or PDF/A-3 with the XML embedded. Every invoice carries a Base64-encoded QR code, a Cryptographic Stamp Identifier, a 36-character UUID, and a Previous Invoice Hash linking it to the invoice before it.
What happens if I miss my integration deadline?
ZATCA typically issues a warning with a correction period on a first field-inspection finding, but fines follow for repeat or serious violations — from SAR 5,000 for non-issuance to SAR 50,000 for repeated failure to integrate with FATOORA. Invoices issued outside the compliant flow also are not valid tax invoices, risking your customers' input-VAT deduction.
Does the 2026 tax fines-cancellation initiative cover e-invoicing penalties?
No. That initiative (extended to 31 December 2026) waives late-registration, late-payment and late-filing penalties across tax laws, but ZATCA has confirmed it does not cover e-invoicing or FATOORA integration violations — there is no current amnesty for missing your Phase 2 deadline.
Can my existing ERP integrate with FATOORA?
Usually yes — either through a certified middleware layer or a direct integration built into the ERP's invoicing module. Highly customized or legacy systems typically need the integration built into the module that owns the invoice data.
Does Phase 2 apply to B2C sales?
Yes. Simplified (B2C) invoices don't need pre-clearance but must still be generated in the compliant XML format and reported to ZATCA within 24 hours of issue.
What was Wave 24 and does it affect my business?
Wave 24, announced in September 2025, is the largest and lowest-threshold wave so far: it covers every VAT-registered business with revenue above SAR 375,000 in 2022, 2023 or 2024, with a compliance deadline of 30 June 2026. If your revenue clears that bar and you have not integrated with FATOORA yet, you are already out of compliance.
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Offizielle Quellen
- ZATCA — E-Invoicing Roll-out Phases (official)
- ZATCA — FATOORA Portal (official)
- ZATCA — E-Invoicing Detailed Guidelines (technical & business rules)
- EY — Saudi Arabia announces 23rd wave of Phase 2 e-invoicing integration
- VATupdate — Wave 24: SAR 375,000 threshold, deadline 30 June 2026
- Wafeq — ZATCA e-invoicing fines and penalties explained
- ZATCA — Fines-cancellation initiative extended to 31 Dec 2026 (official)
Dieser Leitfaden ist eine allgemeine Information und keine Steuer- oder Rechtsberatung. Prüfen Sie die Anforderungen über die offiziellen Quellen unten oder Ihren Berater.