ZATCA Violations

This page is to track all violations and discrepancies highlighted by ZATCA to taxpayers. It contains details of the violations and how to respond/handle them to avoid them in the future.

More about ZATCA e-Invoicing discrepancies/violations

Topic of the discrepancy	Why could you get this intimation from ZATCA?	Which ZATCA regulation does it refer to?	How can you check and respond?	How to resolve it permanently?
Missing or incorrect ‘Commercial Registration number’	‘Commercial Registration number’ of buyer or seller is either omitted or incorrect in invoices where it is expected. ZATCA is comparing the CRs used during e-Invoice generation with the complete list of active CRs.	According to E-invoicing implementation resolution , Additional seller IDs. One of the following IDs must be entered: 1. Commercial Registration (CR) 2. MOMRA License 3. MLSD License 4. SAGIA License 5. Other ID of the seller. It consists of: 1. Type of ID 2. ID Number Note: If the CR is chosen and in case of multiple commercial registrations, the seller should fill the commercial registration of the branch in respect of which the Tax Invoice is being issued. In case multiple IDs exist then one of the above must be entered following the sequence specified above. Additional buyer ID if the buyer is not VAT registered. One of the following IDs has to be provided: 1. Tax Identification Number (TIN) 2. CR 3. MOMRA License 4. MLSD License 5. 700 Number 6. SAGIA License 7. National ID 8. GCC ID 9. Iqama Number 10. Passport ID of the buyer. It consists of: 1. Type of ID 2. ID Number In case multiple IDs exist then one of the above must be entered following the sequence specified above.	Audit a few sample invoice xmls to check if correct buyer/seller CRs are present in the invoice data Check whether the CRNs for the respective branches have been sent to ZATCA Verify for all the invoices by checking the downloading the e-Invoice reports	Ensure that all your active CRs are correctly used during e-Invoice generation Ensure that the CR used during e-Invoice generation matches the address from which the sale happens The buyer CR should also be correctly provided during e-Invoice generation. Take this info from the buyer and add it in the master data
Failure to share invoices (B2C) with the Authority within 24 hours after issuance	This notice is sent if ZATCA comes across invoices where the reporting time is more than 24 hours after the issue time of the invoice. ZATCA is analyzing your e-Invoice data to identify invoices that are reported after 24 hours of issuance.	According to E-invoicing implementation resolution ,Simplified Tax Invoices and their associated Electronic Notes must be reported to the Authority within a period which must not exceed 24 hours from its generation	Check your e-Invoice reports and calculate the time difference between submission time and issue time. Identify the instances wherever this difference is greater than 24 hours. The times and time difference can be directly obtained in ClearTax reports. You can request ZATCA to share sample instances of violation to identify patterns and fix.	Ensure that no backdated invoices are raised - process changes to business Fix technical glitches that lead to failures in e-Invoice submission to ZATCA
Duplicate in one of the technical identifiers (UUID, Hash, IRN, ICV, QR)	The same technical identifier(s) has been used in multiple invoices submitted to ZATCA. It could be duplicates in one or more of the technical identifiers in the invoice xmls.	Invoice identifier IRN- A unique identification of the Invoice. Invoice Reference Number (IRN) Invoice UUID - Universally Unique Invoice Identifier in UUID format. Invoice Hash - The base64 encoded SHA256 hash of the invoice. This hash will be computed from the business payload of the invoice. ICV - Invoice counter value. Invoice tamper-resistant counter value	Download reports of e-Invoices to check the technical identifiers Alternatively run queries on your invoices to identify duplicates in unique technical identifiers	Identify the root cause of the reason for duplicate technical identifiers in e-Invoices and fix it in the code Implement a strong logic of uniqueness for all the technical identifiers part of the e-Invoice Test the logic implemented on a large volume of data
Failure to add the correct buyer or seller address in the invoice	The values given as address of buyer/seller is incorrect and contains generic characters. The address fields don’t contain genuine address values.	According to the E-invoicing implementation resolution, Buyer/ Seller Name & Address should be as per the provision mentioned in Article 53(5) of the VAT Implementing Regulation.	Check e-Invoice reports to identify if any address fields have been passed as ‘NA’, special characters or generic values Perform the check on both buyer and seller addresses Request ZATCA to share a few samples of wrong address to identify patterns	Clean-up the master data to contain valid address values for both seller and buyer Ensure that correct address of each branch making a sale is configured in e-Invoice Collect accurate address data from buyers and include it in the e-Invoice
Incorrect details in CSR during device onboarding	This discrepancy is highlighted if the fields used during onboarding devices are wrong with random values which are not the right information as per the location and business.	As per Onboarding Developers Guide, the CSR contains information the ZATCA authority will use to create CSID. These inputs contain fields relating to Common Name, Organisation unit name , Organisation Name , Country Name etc.	Check whether all the mandatory , conditional & optional fields are available in your EGS during registration Verify the sample xmls used in compliance check Check whether the details provided during CSR Generation belong to the branch/Organisation for which device is being onboarded.	Pass the exact information in all the fields of CSR during device registration. Don’t pass any random values like ‘NA’ or special characters Send valid xmls during compliance checks to ZATCA
Non-compliance with the implementation of phase 2 e-invoicing	ZATCA expects taxpayers to start submitting phase 2 e-Invoices as per the timeline prescribed for an enterprise. If you are not generating compliant phase 2 invoices by that timeline or are not continuously generating phase 2 e-Invoices then this discrepancy is highlighted by ZATCA.	As per Detailed Guidelines for E-invoicing , the taxpayer must generate a Tax Invoice including additional data fields prescribed in the Annex 2 of E-Invoicing Resolution in an electronic format using a compliant E-Invoice Generation Solution (EGS) which is Onboarded .Phase 2 (Integration Phase) Tax Invoices must be generated in XML format or a PDF/A-3 (with embedded XML).	Check whether you have started integrating your e-invoices within the timelines prescribed by ZATCA. Check that there are no breaks in e-Invoice generation and submission after go-live with phase 2 Check whether you are fulfilling the visibility conditions on the visual representation as mentioned in the annexure 2 of the e-invoice implementation resolution.	Plan phase 2 go-live as per ZATCA prescribed timelines Ensure that you generate and submit e-Invoices for all transactions Flag any technical glitches or breakdowns impacting e-Invoice generation to ZATCA

If you’ve already received a notice or are facing issues with ZATCA e-invoicing compliance, write to us at [e-mail].