Saudi Arabia announces 24th wave of Phase 2 e-invoicing integration

Executive summary

On 26 September 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 375,000 Saudi Riyal (SAR375,000, approximately US$100,000) during calendar year 2022, 2023 or 2024 will fall within the 24th wave of Phase 2 e-invoicing integration and should comply with the Phase 2 requirements. The ZATCA will notify affected 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. (287-99-1447) dated 10/03/1447 AH, which was published in the Official Gazette on 26 September 2025, and mentions that taxpayers coming under the 24th wave should comply with the Phase 2 e-invoicing requirements between 1 April 2026 and 30 June 2026, 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 record keeping.
• 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 23 waves, which were previously announced, are:

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 24th wave of Phase 2 e-invoicing integration, to go live within the period between 1 April 2026 and 30 June 2026, 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 Regulations to preclude possible penalties.

Taxpayers who do not fall within the first 24 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.

For additional information concerning this Alert, please contact:

EY Consulting LLC, Dubai

• Aamer Bhatti, Indirect Tax 

Ernst & Young Professional Services (Professional LLC), Riyadh

• Mohammed Bilal Akram, MENA Indirect Tax Leader 
• Peter Dylewski, Indirect Tax 
• Juan Swanepoel, Indirect Tax 
• Satish Bansidhar, Indirect Tax
• Omar Hisham, Indirect Tax

Ernst & Young Professional Services (Professional LLC), Jeddah

• Mohammed Bilal Akram, Indirect Tax
• Dorwin Nyaga, Indirect Tax

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

• Ali Almahroos, Indirect Tax 
• Shane Durran, Indirect Tax 
• Anandhram Vasudevan, Indirect Tax

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

• Yuriy Melnyk 

For a full listing of contacts and email addresses, please click on the Tax News Update: Global Edition (GTNU) version of this Alert.

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