05 February 2025

Saudi Arabia announces 20th wave of Phase 2 e-invoicing integration

  • Saudi Arabia's Zakat, Tax and Customs Authority has announced the criteria for taxpayers to be included in the 20th wave of Phase 2 e-invoicing integration.
  • Taxpayers resident in Saudi Arabia, with a taxable turnover exceeding SAR1.5m during the calendar year 2022 or 2023, should comply with the Phase 2 e-invoicing requirements no later than 31 October 2025.
 

Executive summary

On 31 January 2025, Saudi Arabia's Zakat, Tax and Customs Authority (ZATCA) announced on its website that taxpayers resident in Saudi Arabia, with a taxable turnover exceeding 1.5 million Saudi Riyal (SAR1.5m) during calendar year 2022 or 2023, will fall within the 20th wave of Phase 2 e-invoicing integration and should comply with the Phase 2 requirements. The ZATCA will notify the impacted taxpayers in preparation for linking and integrating their electronic invoicing systems with the ZATCA's e-invoicing platform (Fatoora).

Further, the ZATCA Governor issued Decision No. (941-99-1446) dated 21/07/1446 AH, which was published in the Official Gazette on 31 January 2025, and mentions that taxpayers coming under the 20th wave should comply with the Phase 2 e-invoicing requirements between 1 August 2025 and 31 October 2025, inclusive of both dates.

Detailed discussion

Background

On 4 December 2020, the ZATCA introduced e-invoicing in Saudi Arabia, releasing the E-Invoicing Regulations. E-invoicing in Saudi Arabia is being implemented in two phases:

  • Phase 1, effective from 4 December 2021, mandates generation of e-invoices and e-notes, including related processing and recordkeeping.
  • Phase 2, effective from 1 January 2023, mandates integration of a taxpayer's system with the ZATCA, along with the transmission of e-invoices and e-notes to the ZATCA. This phase is being implemented in waves. The criteria and timelines for the first 19 waves, which were previously announced, are:

Wave

Criteria

Timeline

11

Turnover of more than SAR3b during calendar year 2021

1 January 2023 to 30 June 2023

22

Turnover of more than SAR500m up to SAR3b during calendar year 2021

1 July 2023 to 31 December 2023

33

Turnover of more than SAR250m during calendar year 2021 or 2022

1 October 2023 to 31 January 2024

44

Turnover of more than SAR150m during calendar year 2021 or 2022

1 November 2023 to 29 February 2024

55

Turnover of more than SAR100m during calendar year 2021 or 2022

1 December 2023 to 31 March 2024

66

Turnover of more than SAR70m during calendar year 2021 or 2022

1 January 2024 to 30 April 2024

77

Turnover of more than SAR50m during calendar year 2021 or 2022

1 February 2024 to 31 May 2024

88

Turnover of more than SAR40m during calendar year 2021 or 2022

1 March 2024 to 30 June 2024

99

Turnover of more than SAR30m during calendar year 2021 or 2022

1 June 2024 to 30 September 2024

1010

Turnover of more than SAR25m during calendar year 2022 or 2023

1 October 2024 to 31 December 2024

1111

Turnover of more than SAR15m during calendar year 2022 or 2023

1 November 2024 to 31 January 2025

1212

Turnover of more than SAR10m during calendar year 2022 or 2023

1 December 2024 to 28 February 2025

1313

Turnover of more than SAR7m during calendar year 2022 or 2023

1 January 2025 to 31 March 2025

1414

Turnover of more than SAR5m during calendar year 2022 or 2023

1 February 2025 to 30 April 2025

1515

Turnover of more than SAR4m during calendar year 2022 or 2023

1 March 2025 to 31 May 2025

1616

Turnover of more than SAR3m during calendar year 2022 or 2023

1 April 2025 to 30 June 2025

1717

Turnover of more than SAR2.5m during calendar year 2022 or 2023

1 May 2025 to 31 July 2025

1818

Turnover of more than SAR2m during calendar year 2022 or 2023

1 June 2025 to 31 August 2025

1919

Turnover of more than SAR1.75m during calendar year 2022 or 2023

1 July 2025 to 3 0 September 2025

The ZATCA has already notified resident businesses falling under the above waves to comply with Phase 2 of e-invoicing as per their applicable timelines.

ZATCA announcement

Based on the latest announcements, the ZATCA will begin notifying taxpayers who fall within the 20th wave of Phase 2 e-invoicing integration, to go live within the period between 1 August 2025 and 31 October 2025, inclusive of both dates.

Implications

Resident businesses should comply with the obligations of Phase 2 e-invoicing integration based on the ZATCA notification and undertake the relevant steps in making the required changes in their information technology systems. Taxpayers should comply with the Phase 2 requirements in line with the e-invoicing regulation to preclude possible penalties.

Taxpayers who do not fall within the first waves of Phase 2 e-invoicing integration should monitor future announcements from the ZATCA on the integration timeline period applicable to them in subsequent waves.

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Endnotes

1 See EY Global Tax Alert, Saudi Arabia releases final e-invoicing regulations for Phase 2, dated 24 June 2022.

2 See EY Global Tax Alert, Saudi Arabia announces second wave of Phase 2 e-invoicing integration, dated 28 December 2022.

3 See EY Global Tax Alert, Saudi Arabia announces third wave of Phase 2 e-invoicing integration, dated 24 March 2023.

4 See EY Global Tax Alert, Saudi Arabia announces fourth wave of Phase 2 e-invoicing integration, dated 2 May 2023.

5 See EY Global Tax Alert, Saudi Arabia announces fifth wave of Phase 2 e-invoicing integration, dated 30 May 2023.

6 See EY Global Tax Alert, Saudi Arabia announces sixth wave of Phase 2 e-invoicing integration, dated 16 June 2023.

7 See EY Global Tax Alert, Saudi Arabia announces seventh wave of Phase 2 e-invoicing integration, dated 31 July 2023.

8 See EY Global Tax Alert, Saudi Arabia announces eighth wave of Phase 2 e-invoicing integration, dated 24 August 2023.

9 See EY Global Tax Alert, Saudi Arabia announces ninth wave of Phase 2 e-invoicing integration, dated 21 November 2023.

10 See EY Global Tax Alert, Saudi Arabia announces 10th wave of Phase 2 e-invoicing integration, dated 4 April 2024.

11 See EY Global Tax Alert, Saudi Arabia announces 11th wave of Phase 2 e-invoicing integration, dated 29 April 2024.

12 See EY Global Tax Alert, Saudi Arabia announces 12th wave of Phase 2 e-invoicing integration, dated 28 May 2024.

13 See EY Global Tax Alert, Saudi Arabia announces 13th wave of Phase 2 e-invoicing integration, dated 8 July 2024.

14 See EY Global Tax Alert, Saudi Arabia announces 14th wave of Phase 2 e-invoicing integration, dated 5 August 2024.

15 See EY Global Tax Alert, Saudi Arabia announces 15th wave of Phase 2 e-invoicing integration, dated 3 September 2024.

16 See EY Global Tax Alert, Saudi Arabia announces 16th wave of Phase 2 e-invoicing integration, dated 30 September 2024.

17 See EY Global Tax Alert, Saudi Arabia announces 17th wave of Phase 2 e-invoicing integration, dated 24 October 2024.

18 See EY Global Tax Alert, Saudi Arabia announces 18th wave of Phase 2 e-invoicing integration, dated 23 December 2024.

19 See EY Global Tax Alert, Saudi Arabia announces 19th wave of Phase 2 e-invoicing integration, dated 2 January 2025.

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Contact Information

For additional information concerning this Alert, please contact:

EY Consulting LLC, Dubai

Ernst & Young Professional Services (Professional LLC), Riyadh

Ernst & Young Professional Services (Professional LLC), Jeddah

Ernst & Young Professional Services (Professional LLC), Al Khobar

Ernst & Young LLP (United States), Middle East Tax Desk, New York

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-0403