The deadline for Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) Phase 2 e-invoicing Wave 24 was June 30, 2026. For businesses that were included in this wave but have not completed integration, the priority now is to establish their compliance position, address any technical gaps, and avoid allowing the delay to continue.
Missing a regulatory deadline can create uncertainty, but delaying action further is rarely the best response. Businesses should confirm whether Wave 24 applies to them, review how invoices are currently issued, and work with their tax adviser and technology provider to implement the required integration with ZATCA’s FATOORA platform.
Who Was Included in Wave 24?
Wave 24 covered taxpayers whose revenue subject to VAT exceeded SAR 375,000 in any one of the years 2022, 2023, or 2024. ZATCA implements Phase 2 in waves and notifies targeted taxpayers of their integration requirements. If you believe your business falls within the criteria, review the official notification and your revenue records rather than relying on assumptions.
Phase 2 builds on the Generation Phase. It requires an electronic invoicing solution to integrate with ZATCA’s systems, generate invoices in the required format, and follow the applicable clearance or reporting process. A system that simply creates a PDF or sends invoices by email should not be assumed to meet Phase 2 requirements.
What Happens If You Missed the Deadline?
The exact consequences depend on the requirements that apply to the taxpayer and the nature of any non-compliance. Missing an integration date should be treated as a compliance issue that needs prompt attention, but it is important not to assume that every business automatically receives the same fine solely because the date has passed.
ZATCA publishes penalties for e-invoicing and VAT-related violations. Depending on the facts, exposure may relate to failures such as not issuing or storing invoices electronically as required, using a non-compliant process, or other violations of the applicable rules. The authority’s published penalty framework considers the type of violation and repetition. Businesses should verify the current rules and their specific position directly with ZATCA or a qualified Saudi tax adviser.
A separate point to check is whether any penalty-exemption initiative applies. ZATCA announced an exemption initiative that ran through June 30, 2026. Because that published period has passed, businesses should not assume that the initiative remains available or that it automatically covers a missed Wave 24 integration date. Confirm any current relief, eligibility conditions, and deadlines through official ZATCA channels.
What Your Business Should Do Now
- 1. Confirm your status — Check the ZATCA notification, VAT-subject revenue for 2022–2024, and the applicable integration date. If you are unsure whether you were targeted, seek clarification through official ZATCA channels.
- 2. Assess your current invoicing system — Ask your ERP, accounting, point-of-sale, or e-invoicing provider whether the solution supports the required Phase 2 functionality and the relevant FATOORA integration process.
- 3. Identify the gaps — Document missing configuration, invoice fields, certificate or onboarding steps, connectivity issues, and any failures in clearance or reporting workflows.
- 4. Prioritize production readiness — Create an implementation plan with owners and dates. Complete the necessary configuration, testing, and onboarding steps, then verify the system is operating in the required production environment.
- 5. Review invoices and records — Work with your tax adviser to determine whether any invoices or records need review, correction, or other action under applicable rules. Preserve records and do not delete or alter issued invoices outside permitted procedures.
- 6. Keep evidence — Retain relevant correspondence, implementation records, test results, support tickets, system logs, and the steps taken to address the delay.
- 7. Confirm the next action with ZATCA or an adviser — Ask what is required in your circumstances and whether any notification, remediation, or penalty process applies. Do not rely on informal assurances alone.
Can You Keep Using Your Existing Accounting Software?
Not necessarily every business needs to replace its entire accounting or ERP platform. In some cases, the existing system may be capable of supporting compliant integration through a suitable update, connector, or implementation. In other cases, additional software or process changes may be required. The right answer depends on the system, transaction types, and applicable technical requirements.
Ask the provider to explain how the solution handles the relevant invoice types, required data and formats, integration and onboarding, exception handling, and ongoing support. ZATCA maintains an indicative directory of solution providers, but it states that taxpayers may use any solution that complies with the requirements; directory inclusion should not be treated as a blanket guarantee of compliance.
Why Acting Quickly Matters
An unresolved integration gap can affect invoice workflows, customer operations, financial controls, and the reliability of tax records. It can also create avoidable pressure for finance, IT, and operations teams. A clear remediation plan helps the business move from uncertainty to documented action.
The goal should be more than switching on a technical connection. The business should establish a repeatable process that produces compliant invoices, handles exceptions, maintains records, and assigns responsibility for monitoring the system.
A Practical 7-Day Recovery Plan
- Day 1: Confirm whether Wave 24 applies and collect the ZATCA notification and system details.
- Days 2–3: Meet with the tax adviser and technology provider; document the compliance and technical gaps.
- Days 3–5: Agree a prioritized remediation plan, owners, milestones, and testing approach.
- Days 5–7: Progress onboarding and configuration, test relevant invoice workflows, and document issues and next steps.
This is a suggested internal recovery sequence, not a ZATCA-approved deadline or a guarantee that integration can be completed within seven days. Actual timing depends on the system, access, readiness, and the steps required by ZATCA.
How PakAmGlobal Can Help
PakAmGlobal helps organizations connect business priorities with the people, processes, technology, and AI-enabled capabilities needed to move forward. For a post-deadline compliance effort, that can mean helping stakeholders organize the work, clarify ownership, coordinate technology and business teams, and establish a practical implementation roadmap.
Regulatory interpretation and formal tax advice should come from a qualified Saudi tax professional or ZATCA. PakAmGlobal can support the business and technology coordination around the effort, helping teams move from uncertainty to an actionable plan.
Need a clear plan for your next steps?
Connect with PakAmGlobal to discuss your digital transformation and operational readiness priorities.
Email: info@pakamglobal.com
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Frequently Asked Questions
What was the Wave 24 deadline?
The integration deadline was June 30, 2026.
Which businesses were targeted?
Wave 24 covered taxpayers whose VAT-subject revenue exceeded SAR 375,000 in any of 2022, 2023, or 2024, subject to ZATCA’s targeting and notification process.
Will every business that missed the date automatically receive the same fine?
Do not assume that. Penalties depend on the applicable violation and circumstances. Confirm the position against current official rules and obtain qualified advice.
Does missing the deadline mean we must replace our software?
Not always. An existing system may be extendable or integrable, but its suitability must be assessed against the applicable Phase 2 requirements.
Where can we confirm our obligations?
Use ZATCA’s official e-invoicing pages, technical guidance, and support channels, and consult a qualified Saudi tax adviser for advice specific to your business.
Resources and Official References
- ZATCA — E-Invoicing (FATOORA) overview — Official overview, technical resources, and preparation guidance.
- ZATCA — Roll-out phases — Explains Phase 1 and Phase 2 and the wave-based rollout.
- ZATCA — What is E-Invoicing? — Definitions and an overview of how FATOORA e-invoicing works.
- ZATCA — E-Invoicing FAQs — Frequently asked questions on enforcement dates and requirements.
- ZATCA — E-Invoicing solution providers directory — Indicative directory of providers and explanation of its status.
- ZATCA — E-invoicing violations and fines announcement — Official announcement describing selected violations and penalty principles.
- ZATCA — VAT violations and fines — Official VAT penalty information.
- ZATCA — Fine exemption initiative announcement (January 2026) — Official information on the initiative announced to run through June 30, 2026.
Editorial Note
This article is for general informational purposes and is not legal or tax advice. Requirements, penalty treatment, and available relief can change. Readers should verify current information directly with ZATCA and consult a qualified Saudi tax professional about their specific circumstances. Wave 24 dates and criteria are based on publicly available ZATCA materials and published references available at the time of drafting.
