There are a hundred articles explaining what ZATCA Phase 2 is. This one is about what it does to the way a freight forwarder actually bills — because the requirement that breaks the most operational habits is not the XML or the QR code. It is one word: clearance.
If you invoice in Saudi Arabia and your revenue is above SAR 375,000, you are in scope during 2026. The question is no longer whether, but what has to change in the week before your wave lands.
The deadline that applies to you
Phase 2 — the Integration Phase — is being rolled out in waves, and ZATCA notifies each group directly, normally around six months ahead.
- Wave 23 — 31 March 2026. Businesses with annual VATable revenue above SAR 750,000 (assessed across 2022–2024).
- Wave 24 — 30 June 2026. The threshold drops to SAR 375,000, which brings most remaining SMEs into scope.
At SAR 375,000 of annual revenue, a single-office forwarder handling a few shipments a week is in scope. There is effectively no longer a size below which this does not apply.
Clearance versus reporting, and why a forwarder should care
Phase 2 treats two kinds of invoice completely differently, and most forwarders issue both.
A standard tax invoice (B2B and B2G) must be CLEARED before you send it. The invoice goes to ZATCA's Fatoora platform in XML, ZATCA validates it and applies its cryptographic stamp, and only then may you give it to your customer. An invoice your customer has that ZATCA has not stamped is not a valid tax invoice.
A simplified tax invoice (B2C) is REPORTED within 24 hours of issue. You can hand it over immediately — it carries a QR code the customer can validate — but it must reach ZATCA inside a day.
For a forwarder running both a corporate book and a courier or e-commerce operation, that is two different pipelines with two different clocks, and the second one has a 24-hour deadline that a monthly billing run cannot satisfy.
The habit this breaks
Here is the change that matters most, and it is entirely operational.
Forwarding invoices move after they are issued. The carrier re-weighs the shipment and bills 63.80 against the 37.40 you quoted. The customs debit note arrives three weeks later with duty, a declaration fee and import VAT that nobody could have known at the time. A demurrage charge lands after the invoice went out. The standard response — adjust the invoice, resend it — is how a great many forwarding desks work.
Under clearance you cannot do that. The invoice your customer holds carries ZATCA's stamp. Changing it is not an edit; it is a credit or debit note, which must itself be cleared through Fatoora before it goes out.
That is not a worse process. It is a stricter one, and it rewards getting the cost onto the invoice before it is issued rather than after. Practically, it means the operational habits that used to be untidy now have a deadline attached:
- Costs have to reach the invoice before issue. If your carrier reconciliation runs a fortnight behind your billing, every re-weigh becomes a cleared debit note rather than a line you quietly corrected.
- Customs recharges need a treatment decided up front. Duty, import VAT and the declaration fee take different VAT positions, and once an invoice is stamped you are amending a cleared document rather than fixing a draft. We wrote about that distinction separately in recharging customs duty to your customer.
- Credit notes stop being a back-office tidy-up. Each one is a cleared document in its own right, with its own reference to the invoice it corrects.
What your system actually has to produce
Every invoice needs to carry, in a form ZATCA can validate:
- UBL 2.1 XML in ZATCA's implementation standard — the invoice as structured data, not as a PDF.
- PDF/A-3 with the XML embedded, for the human-readable copy.
- A UUID unique to each invoice.
- An invoice hash and an invoice counter value, chaining each document to the one before it.
- A cryptographic stamp and digital signature.
- A QR code carrying seller name, VAT number, timestamp, total with VAT, the VAT amount, the hash and the UUID.
And the system needs to talk to Fatoora: onboarding to obtain a cryptographic stamp identifier, REST API integration for submission, and in many setups the server IP registered with ZATCA.
The invoice counter and hash chain are the part worth understanding, because they change what your numbering means. Each invoice references the previous one, so the sequence is not merely tidy — it is verifiable. A gap is visible to ZATCA.
Four things that catch freight businesses specifically
You bill in dollars but you report in riyals. Cross-border freight is frequently quoted and invoiced in USD or AED. The document has to carry the tax in SAR, at the rate on the date of supply — not the rate on the day somebody ran the billing.
Zero-rated is not the same as out of scope, and the XML records which one you chose. International transport and its related services are zero-rated; a disbursement recharged at exact cost is outside the scope of VAT. Both print 0.00 on the page. In a structured invoice they are different codes, and the return is built from the codes.
Your courier arm and your forwarding arm are on different clocks. Simplified invoices reported within 24 hours cannot wait for a month-end run, whatever the corporate side does.
An accredited provider is a procurement lead time, not a switch. Whichever route you take to Fatoora, contracting and onboarding take weeks. A wave deadline is the date integration must be working, not the date you start.
What to do now
If you have not been notified yet, you are still in the useful window. In order:
1. Find out which wave you are in. Check your VATable revenue against the thresholds above. If you are over SAR 375,000, assume 2026.
2. Establish whether your system can produce cleared XML at all — not whether it can print a compliant-looking PDF. These are different capabilities, and a template with a QR code on it is not the second one.
3. Close the gap between cost and invoice. This is the work that has nothing to do with software procurement and takes the longest: getting carrier charges, customs recharges and re-weighs onto the invoice before it is issued, because afterwards each one is a cleared credit note.
4. Start the provider conversation early, for the lead-time reason above.
The businesses that will find this painful are not the ones with the oldest systems. They are the ones whose invoices routinely change after issue — which, in freight, is most of them.
Sources: ZATCA e-invoicing Phase 2 (Integration Phase) requirements and published wave thresholds and dates. Wave dates and thresholds are announced by ZATCA and can be extended or amended — confirm your own wave against the notification ZATCA sends you.
This article describes the general position and is not tax or legal advice. Your obligations depend on your registration and turnover; confirm them with your tax adviser or directly with ZATCA.