ZATCA e-invoicing Phase 1 and Phase 2: what each requires

Saudi e-invoicing (Fatoora) arrived in two phases. Every VAT-registered business has been in Phase 1 since December 2021; Phase 2 reaches businesses in waves, each called by ZATCA in writing at least six months ahead.

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Phase 1: generation (since 4 December 2021)

Invoices and credit and debit notes must be generated and kept electronically, by a compliant system. Handwritten invoices, and invoices typed into a word processor or spreadsheet, are no longer accepted.

  • A simplified tax invoice (business to consumer) carries a QR code with the seller's name, VAT number, the time of the invoice, the total with VAT and the VAT.
  • The system must not let an issued invoice be changed or deleted; a correction is a credit or debit note.
  • Every tax invoice carries the fields the VAT rules list, in Arabic (other languages may be added).

Phase 2: integration (in waves since 1 January 2023)

In Phase 2 the business's system connects to ZATCA's platform. Each invoice is an XML document (UBL 2.1) with a cryptographic stamp, a unique identifier and the hash of the invoice before it, so the chain cannot be altered unnoticed.

  • Standard tax invoices (business to business) are cleared: sent to ZATCA and approved before the buyer receives them.
  • Simplified tax invoices (business to consumer) are reported: given to the customer at once and sent to ZATCA within 24 hours.
  • Each device or system that issues invoices is onboarded once, with a one-time password from the Fatoora portal, to receive its cryptographic stamp identifier.

When your business enters Phase 2

ZATCA calls businesses in waves, by the VAT-taxable revenue of a reference year, and notifies each one at least six months before its date. Until that letter arrives, Phase 1 is what applies. Getting ready early does no harm: the same system can run Phase 1 today and switch to Phase 2 on the day.

How Aqid ERP handles it

A Saudi company in Aqid ERP issues Phase 1 invoices from day one, with the QR code, in Arabic and English. When ZATCA's letter comes, Upgrade to Phase 2 on the Compliance page onboards the company with the portal's one-time password; from then on every invoice is signed, chained, and cleared or reported, and the result is kept with the invoice.

Questions

Is Phase 2 mandatory for every business?

It is mandatory for each business from the date ZATCA gives it in its wave letter. Until then, Phase 1 applies.

What is the difference between clearance and reporting?

Clearance (B2B) means ZATCA approves the invoice before the buyer receives it. Reporting (B2C) means the invoice goes to the customer at once and to ZATCA within 24 hours.

Can I keep issuing PDF invoices?

Yes, as the copy the customer reads, alongside the XML. ZATCA also accepts a PDF/A-3 with the XML embedded in it as the invoice itself.

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