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Saudi Arabia continues with announcements of additional waves as part of the country’s tax and electronic invoicing mandates. Discover the new waves, as well as the country’s existing mandates.
Since its initial announcement in 2020, Saudi Arabia's journey towards a fully digital tax system has been marked by a phased implementation, with businesses progressively adapting to the new electronic invoicing requirements. Understanding both the foundational mandates and the ongoing expansions is crucial for compliance.
Saudi Arabia’s existing mandates - Phase 1
In December 2020, Saudi Arabia’s tax authority (Zakat, Tax and Customs Authority - ZATCA) announced new electronic invoicing regulations via a two-phase approach.
The first phase, called the “Generation Phase”, stated that businesses must be able to issue and receive electronic invoices by December 2021. From December 2021, businesses were not able to use manual invoices and could only use a compatible e-invoicing system that had the ability to store and archive all invoices.
Existing and new mandates - Phase 2
The second phase of Saudi Arabia’s regulations, known as the “Integration Phase”, launched on 1 January 2023 in a staggered approach. Within this phase, businesses must integrate their compatible e-invoicing system to ZATCA’s platform FATOORA, using ZATCA’s own API. This particular phase has several waves in itself, all based on the company’s taxable turnover in past years (2021, 2022, 2023 and most recently 2024, depending on the wave). Taxpayers with turnover exceeding 1.75 million SAR in 2022 or 2023 (Waves 1-19) are already in scope in the “Integration Phase”, with the latest wave having taken effect on 30 September 2025. The next waves of obligation, with their final deadlines for implementation, are as follows:
Wave 20 - 31 October 2025 - For taxpayers with annual revenues subject to VAT exceeding 1.5 million SAR (for year 2022 or 2023)
Wave 21 - 30 November 2025 - Exceeding 1.25 million SAR (for year 2022, 2023 or 2024)
Wave 22 - 31 December 2025 - Exceeding 1 million SAR (for year 2022, 2023 or 2024)
Wave 23 - 31 March 2026 - Exceeding 750 k SAR (for year 2022, 2023 or 2024)
Wave 24 - 30 June 2026 - Exceeding 375 k SAR (for year 2022, 2023 or 2024)
Within Saudi Arabia’s regulations, all tax invoices are part of the clearance model, meaning the invoice must be cleared before it can be submitted to the end recipient. Within this phase, businesses must only generate electronic invoices in an XML or PDF/A-3 format.
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