ZATCA e-Invoicing Phase 2: Applicability, Requirements, Rules
Some changes arrive with fanfare, while others slip in quietly, yet they ultimately turn everything upside down. ZATCA Phase 2 falls into the second category. Saudi Arabia’s e-Invoicing wave didn’t stop with Phase 1. It was just the beginning. Now, with ZATCA Phase 2 rolling out in multiple stages, businesses in the Kingdom are feeling the heat. Trust me, this Phase 2 isn’t a gentle update; it’s a system overhaul. It changes everything, including how you invoice, track, store, and sync with the tax authority. In this situation, if your tools aren’t ready, your business could face serious roadblocks.
At Penieltech, we’ve been supporting businesses, primarily their finance teams, across Saudi Arabia during this transition. And based on that experience, today we’re here to help you understand everything about ZATCA e-Invoice Phase 2.
A Quick Recap: What Was Phase 1?
Let’s go back to December 2021, because it all started then. Known as the Generation Phase, this stage made it mandatory for VAT-registered businesses in Saudi Arabia to generate and store e-Invoices in a structured format. As per the rule, they must issue an e-invoice in XML files with QR codes and encrypted formats, not in PDF format. But Phase 1 didn’t require integration with ZATCA (yet). It was the warmup process.
Highlights of Phase 1:
- Transition from manual or PDF billing to structured digital records.
- Cryptographic data, QR codes, and anti‑tamper protections.
- Invoices didn’t have to be sent to ZATCA yet, but they had to meet format standards.
This was the groundwork that helped businesses get comfortable with digital invoicing. But the biggest shift came with the next phase.
Phase 2 Explained: Integration, Not Just Digitization
Now we’re in Phase 2, often referred to as the integration Phase, and that term really matters. Because it’s not enough to generate digital invoices, those invoices must now enter ZATCA’s system, live.
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In short, once you hit Phase 2, every invoice becomes a live coordination between your system and the tax authority.
Who Needs to Comply And When?
ZATCA Phase 2 isn’t implementing this for everyone at once. It’s happening in waves, based on revenue brackets and sectors.
Here’s how it’s moving:
Wave | Effective Date | Turnover Bracket |
1 | Jan 2023 | SAR 3 Billion+ |
2 | July 2023 | SAR 500 million to SAR 3 billion |
3 Onwards | Ongoing, continuing every few months | Gradually smaller turnovers |
So, if you haven’t received a wave notice yet, don’t assume you’re off the radar. Just stay alert, because ZATCA notifies eligible businesses at least 6 months in advance. Once noticed, you must comply within that period.
What’s New in Phase 2 That Wasn’t in Phase 1?
Here’s where Phase 2 becomes different from Phase 1.
- Integration with ZATCAA within the mentioned time period is a must. You need to send your invoice instantly to ZATCA for clearance. And for that, you should ensure that your accounting system is API-ready and certified.
- Each invoice you issue must have a Unified Identification number (UID) and a ZATCA-approved cryptographic stamp for authenticity.
- Clearance is a crucial part of this Phase 2 integration. For B2B invoices, you need the clearance before sharing with your clients. While B2C invoices can be shared immediately, it’s salient to report them within 24 hours of issuance.
Apart from these, there are some more requirements:
- Maintain a secure, timestamped archive of every invoice issued or cancelled.
- Obey strict sync standards: no manual uploads.
- Implement audit logs showing all invoice actions and responses.
Missing any of these steps can make you no longer compliant. In the end, remember, your finance software or ERP must be ZATCA-compliant.
Consequences of Ignoring Phase 2
This is the part nobody likes to hear, but everybody needs to know. If you’re selected for Phase 2 and don’t comply within the window, ZATCA penalties won’t be just reminders then.
So you can expect:
- Significant financial penalties for non-compliance.
- System block: inability to issue invoices.
- Delayed or blocked VAT refunds.
- Increased audit risk, with inspections likely.
- Potential blacklisting or permit suspension.
ZATCA’s automated systems are always active. Once the Phase 2 wave hits your business, there’s no grace period.
What Finance Teams Need to Know
This is more than IT getting a project. So your accounting and finance teams must lead:
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- Invoice creation must include tax code validation and compliance with structured data rules.
- Instant issuance & reporting means workflows must be seamless.
- Secure archiving of outputs and responses.
- QR generation, UUID assignment, and proper digital stamping.
- Error and exception handling in daily operations.
Your team must move beyond generating PDFs; they should own ZATCA-aware invoicing workflows, pulling consistent results and reliable data each day.
Why Businesses Shouldn’t Wait for the ZATCA Notice
Here, waiting equals risk. By the time you get the next wave, your window is short:
- You’ve got 6 months to prepare from the notification date.
- Actual implementation, testing, and go-live often take longer.
- Staff training and system validation need time with live data.
Rushed projects lead to mistakes, and those mistakes can cost weeks.
So, start early and you can control the pace, complete the setup, train your people, and ultimately, launch with confidence, well before the wave deadline.
Why Penieltech
At Penieltech, we bring both accounting insight and technical expertise to the table. That dual focus matters because Phase 2 isn’t just a software task; it’s a full-stack finance update.
Here’s what we provide:
- Full e‑invoicing Phase 2 deployment aligned with ZATCA rules
- Comprehensive user training for finance teams on live systems.
- Ongoing compliance support during new wave announcements or regulation tweaks
We don’t just sell modules; we install reliability and compliance in every invoice for your business issues.
Ongoing Technical Help
Enjoy 24/7 support for any e-invoicing issues, updates, or system errors.
FAQs
1. What’s the practical difference between B2B and B2C now?
B2B invoices need prior clearance before they reach clients. B2C just needs accurate logging. Both of them happen digitally.
2. Can we still use PDFs?
Nope. No manual uploads. All invoices must pass through certified systems connected to ZATCA.
3. What about cancellations or reissues?
Those, too, need UUIDs, stamps, and a sync with ZATCA.
4. What if our system fails?
You’ll have to fix errors fast or risk failed invoices. ZATCA rejects non-compliant entries.
5. Can we use cloud or local ERP?
Either, as long as it meets certified specs, and you manage API calls securely.