ZATCA Phase 2 deadline: e-invoicing penalties if you do not integrate on time

There is no separate penalty law for e-invoicing. Article 4 of the E-Invoicing Regulation says electronic invoices and notes are tax invoices and credit and debit notes under the VAT Law. So the fines in chapter 16 of the VAT Law apply to them.

The 2023 implementation resolution adds one more step. It says VAT Law penalties apply to anyone who violates the e-invoicing rules "according to the violation's classifications" set in ZATCA board resolutions. The same resolution requires you to integrate your solution with ZATCA from the date ZATCA sets for your group.

This explains why you see different amounts online. Provider blogs and older press reports list fixed amounts per violation, but we could not find that table on zatca.gov.sa, so we do not repeat those numbers here. If you need the exact amount for your case, ask ZATCA on 19993 or check your ZATCA account.

What ZATCA does publish is a VAT penalties page. It is a summary table, and its amounts are maximums, not a price list for each e-invoicing mistake.

The table says violating any provision of the VAT Law or its regulations carries a fine of up to SAR 50,000. Failing to keep tax invoices, books, records and accounting documents also carries up to SAR 50,000. Issuing a tax invoice when you are not registered for VAT carries up to SAR 100,000. Failing to apply for VAT registration carries SAR 10,000.

The page adds a rule that matters for repeat mistakes. If the same violation is repeated within three years of ZATCA's final decision on it, the fine may be doubled. For a supplier, this means one late integration is a risk, but leaving the problem open for months is a bigger one. Every month you issue invoices outside the rules is another chance for a repeated violation.

ZATCA's Simplified Guide lists the things to avoid. For Phase 2, the key one is generating e-invoices with a solution that is not integrated with ZATCA. For both phases, it lists manual or handwritten invoices, invoices that miss the required fields, solutions that do not meet the requirements, and deleting e-invoices after you generate them.

The Detailed Guidelines add the daily rules. Tax invoices must be cleared before you share them with the buyer. Simplified invoices must be reported within 24 hours. An issued invoice cannot be edited or deleted; you cancel it with a credit note and a new invoice. You must keep your cryptographic stamp safe and not export its private key.

One more obligation is easy to miss. If an incident or a technical error stops your solution, you must notify ZATCA, notify it again on recovery, and then clear or report the waiting invoices. The table below turns these rules into a check you can run.

ZATCA notifies each Phase 2 group at least six months before its integration date. Wave 24, for VAT-subject revenue above SAR 375,000, had to integrate by 30 June 2026. Wave 25, for revenue above SAR 187,500 in any of 2022 to 2025, must integrate by 1 February 2027.

Many suppliers ask whether ZATCA's fines cancellation initiative helps here. The initiative was extended to 31 December 2026. Its official page lists fines for late registration, late payment and late filing of returns, plus VAT return correction fines. It excludes tax evasion fines, fines under Article 45 of the VAT Law, fines already paid, and fines tied to any return due after 30 June 2026.

The page does not mention e-invoicing fines. So do not assume an e-invoicing violation is cancelled. Ask ZATCA about your own case, and read our article on the fines initiative for its conditions.

ENTEK does not handle ZATCA penalties, does not file anything with ZATCA, and is not connected to Fatoora. It cannot tell you whether you are in a wave or whether a fine applies to you. For that, check with ZATCA.

What ENTEK does is keep your company facts and order papers in one place. Your verified company profile holds your CR and VAT numbers, certifications, key personnel and official stamp. For your orders on ENTEK, you can submit invoices and generate stamped commercial documents: quotation, proforma, commercial invoice, packing list, COA, MSDS/TDS and contracts.

Those documents help you organise each order, but they are commercial documents, not tax invoices, and they do not replace Phase 2 integration. Your tax invoices must come from the solution you onboard on the Fatoora portal before your date. Use a ZATCA-compliant e-invoicing solution for your tax invoices.