Is Your Saudi Business in a ZATCA E-Invoicing Wave?

Short answer: which wave are you in, and when is it due?

Saudi e-invoicing Phase 2, called the integration phase, is rolled out in waves. Each wave is set by a revenue figure, and the reference years for that figure change from wave to wave. The integration phase started on 1 January 2023 under ZATCA's E-Invoicing Implementation Resolution, and later details, including timelines, are set by resolutions from the ZATCA Governor under Article 6 of the E-Invoicing Regulation. As of 23 October 2026, the wave most businesses need to check is Wave 25. Wave 24 and Wave 23 have already reached their deadlines, so if your business fell into one of them, your integration should already be live.

Do not rely on this page alone for your own wave number. Confirm it on ZATCA's Fatoora portal or in any notice ZATCA has sent you. Secondary guides agree on the thresholds for the recent waves, but they disagree on some dates, including when Wave 25 was announced.

How ZATCA works out your wave, step by step

The test is about revenue, not headcount or profit. Secondary guides describe it as a test of annual VAT-taxable revenue, taken from VAT returns for the reference years. You can work through it yourself in about an hour if your VAT returns are in order.

1. Collect your VAT-taxable sales for each calendar year from the VAT returns you filed. Sales that are exempt from VAT do not count toward the figure.
2. Write down the reference years for the wave you are testing. For Wave 24 these were 2022, 2023 and 2024. For Wave 25 they are 2022, 2023, 2024 and 2025.
3. Compare each year with the threshold. You do not need to be above the line in every year. One qualifying year is enough.
4. If any year is above the threshold, you are in that wave. Note the integration date from the wave notice or your Fatoora account.
5. Keep the year-by-year totals with your VAT working papers, so you can show how you reached the answer.

ZATCA notifies targeted taxpayers directly. One guide reports that ZATCA says it notifies each wave at least six months before the integration date. A missing letter is therefore not proof that you are out of scope, so run the test yourself.

A worked example with hypothetical figures

Consider a trading company with the following VAT-taxable sales. These numbers are invented for illustration and do not come from a real business: SAR 210,000 in 2022, SAR 300,000 in 2023, SAR 90,000 in 2024 and SAR 260,000 in 2025.

Start with Wave 24. Its threshold is SAR 375,000 in any of 2022, 2023 or 2024. The highest year in that window is SAR 300,000, so on these figures the company is not in Wave 24.

Next, test Wave 25. Its threshold is SAR 187,500 in any of 2022 to 2025. The 2022 figure of SAR 210,000 is above that line, so the company is in Wave 25 even though its 2024 sales were low. Because one qualifying year is enough, the company does not need the other years to pass. On this basis the integration date is 1 February 2027. The company should now confirm the date on its notice or in Fatoora, and check that its invoicing system can meet the Phase 2 technical requirements.

The table below summarises the recent waves as reported by secondary sources. Confirm each row on ZATCA's own pages.

Cases that change the answer

Residency matters. The integration phase applies to taxpayers resident in Saudi Arabia, as a 2025 alert on the 23rd wave states. If your business is not resident in the Kingdom, the wave test described here may not apply to you in the same way, so ask ZATCA or a Saudi-licensed adviser before you assume either way.

Exempt and reverse-charge supplies need a careful look. A 2021 commentary on the draft resolution listed exempt supplies, payments related to exempt supplies, reverse-charge supplies and imports as outside the e-invoicing scope. A draft is not the final text, so check the final resolution before you rely on that list.

Falling sales do not remove you. The test looks at the reference years, not at what you sell today. A business that was above the line in 2022 can still be in the wave even if its sales have since dropped, as one guide notes.

Wave 25 is the first wave to count 2025 revenue. A business that stayed under the Wave 24 threshold in 2022 to 2024 but grew in 2025 can therefore be pulled in now. The rule has no minimum period of trading and no cap on the number of businesses in a wave. One year over the threshold is what counts.

Common mistakes

The most frequent error is using bank receipts instead of VAT-taxable revenue. The wave test follows the sales reported for VAT, so a total from the bank statement can be the wrong figure, especially where some receipts relate to exempt sales or non-sales items.

Another mistake is checking only the latest year. Wave 24 and Wave 25 both look at several years. Checking only 2025 would miss the 2022 figure that places the example company in Wave 25.

Some owners assume the Wave 24 deadline is still ahead because it was on a vendor calendar. It has passed. One guide reports that the penalty waiver ended on the same day as the Wave 24 deadline and that full enforcement began on 1 July 2026. If your integration was not live by then, treat it as urgent.

Some owners also mix up the two phases. Phase 1, the generation phase, began on 4 December 2021 and requires electronic invoices for VAT taxpayers. Phase 2 is the integration phase, with the wave system described on this page. Having electronic invoices from Phase 1 does not mean you are finished with Phase 2.

Finally, do not treat a vendor's wave table as the rule. Secondary guides disagree on details, such as whether Wave 25 was announced on 24 July 2026 or in September 2026. Use ZATCA's notice and Fatoora account as the reference.

What to check with ZATCA or a tax adviser

Log in to the Fatoora portal and look for a wave notice. Write down the wave number, the reference years and the integration date.

Check your invoicing system against the Phase 2 requirements. One guide lists UBL 2.1 XML, cryptographic stamping, a UUID, a QR code, real-time clearance for standard invoices and reporting within 24 hours for simplified invoices. Ask your software provider to confirm in writing which of these it supports.

Ask a Saudi-licensed tax adviser or accountant to check your VAT-taxable figures for each reference year. This matters most if you have exempt sales, reverse-charge sales, imports, or a residency question.

Each year, finance teams repeat the same routine: pulling VAT totals, matching sales ledgers to filed returns, and flagging invoices that are missing required fields. Employers who want that routine off their staff can have AI workers gather the figures from accounting records, compare them with each wave threshold and list any gaps for a person to review. The person still decides, signs off and speaks to ZATCA.

This explains the rule in general terms; it is not legal or tax advice for your case.