Kingdom of Saudi Arabia updates to VAT implementing regulations and e-invoicing


Kingdom of Saudi Arabia ("KSA") Updates to VAT Implementing Regulations and Penalties Related to E-Invoicing


The KSA Zakat, Tax and Customs Authority (ZATCA) approved the amendments to the VAT Implementing Regulations and announced the violations and penalties related to the e-invoicing in KSA.

E-invoicing Phase 1 Go-live date:

04 December 2021

Amendments Related to E-Invoicing

The Following Articles of the KSA VAT Implementing Regulations were amended:

Article 53 - Tax Invoices

  • Grants Power to ZATCA Governor to:
    • Suspend/ cancel applications of e-invoicing regulations
    • Amend required details on the e-invoices

Article 54 - Credit and Debit Notes

  • Allows the issuances of Debit and Credit Notes in cases other than those mentioned in Article 40 of the VAT Implementing Regulations

Article 66 - Record-Keeping Requirements

  • Added clauses on Storing of e-invoices and e-notes per the e-invoicing regulations.

Violations and Penalties Related to E-Invoicing

ZATCA announced the following violations and penalties related to e-Invoicing:


Penalties (SAR)

Non-issuance/ Non-archiving of e-Invoices

5,000 – 50,000

Failure to include QR Code in the simplified tax invoices


Initial Warning.

Maximum Penalty – 50,000.

Failure to inform ZATCA of any Malfunction that hinder the issuance of e-Invoices

Failure to include the buyer VAT registration number on the e-Invoices, when required

Deletion or amendment of e-Invoices after issuance

10,000 – 50,000

Note: The amendment and the announcement of violation and penalties were published in Arabic. The Official English Version is not yet available.

How Crowe can Help

  • Assessment of the compliance of invoicing system with the e-invoicing regulations.
  • Assistance in the implementation of e-invoicing regulations to avoid violations and penalties.

Contact Us

Markus Susilo
Markus Susilo
Partner- Payroll and Indirect Tax
Michel Ruitenberg
  Partner DIFC - Indirect Taxes