On 24 July 2026 the Zakat, Tax and Customs Authority (ZATCA) set the criteria for the twenty-fifth wave of the e-invoicing “Integration Phase”. The headline is simple: the revenue threshold has been halved again. Wave 24 reached businesses with VAT-subject revenue above SAR 375,000. Wave 25 reaches businesses above SAR 187,500, and they must integrate their invoicing with ZATCA’s Fatoora platform by no later than 1 February 2027.
For the logistics trade this is the wave that matters. A small clearing agent, a two-truck transport company or a forwarder running a handful of import jobs a month can pass SAR 187,500 in a single year without noticing. Many of these businesses have been issuing Phase 1 e-invoices since 2021 and assumed integration was a problem for larger companies. From February it is their problem too.
Are you in Wave 25?
ZATCA’s wording is that Wave 25 includes all taxpayers whose revenues subject to VAT exceeded SAR 187,500 during 2022, 2023, 2024 or 2025. Three points are easy to get wrong:
- Any one year is enough. It is not an average and it is not your latest year. If 2023 was a good year and 2025 was quiet, 2023 still puts you in.
- It is revenue subject to VAT, not profit. A forwarder re-billing large freight costs to customers can have thin margins and still cross the threshold comfortably.
- Earlier waves still apply. If an earlier, higher threshold already caught you and you have not integrated, Wave 25 is not a new deadline for you; you are already late.
The practical test is to take your filed VAT returns for each of the four years and add up the supplies you declared. If any year is above SAR 187,500, plan as if you are in. If you are unsure which lines count, settle it with your tax adviser now rather than in January. ZATCA also notifies targeted taxpayers directly, so check the email address and portal account registered with ZATCA, and make sure the notice is not sitting unread in a mailbox nobody watches.
What “integration” adds to what you already do
Phase 1, the Generation Phase, started on 4 December 2021. It required invoices to be produced electronically, with a QR code on simplified invoices, and it banned handwritten invoices and invoices typed up in a word processor. Most businesses met it by using accounting or invoicing software.
Phase 2, the Integration Phase, goes further. ZATCA describes it as integrating your e-invoicing solution with the Fatoora platform, issuing invoices in a specified format and adding extra fields. In practice that means:
- A structured electronic file for every invoice and note, not just a PDF, carrying a unique identifier and a cryptographic stamp.
- Clearance for standard tax invoices. An invoice to a business customer is sent to Fatoora and stamped before you share it with the buyer. If it is rejected, it is not a valid invoice yet.
- Reporting for simplified tax invoices. Invoices to consumers are reported to Fatoora within 24 hours of being issued.
- Onboarding every invoicing point. Each system or device that issues invoices has to be registered and linked before it can send them. A branch office, a second billing system or a mobile device used by drivers each counts.
The change in daily work is less about technology than about timing and discipline. Under Phase 1 an invoice existed the moment you saved it. Under Phase 2 a business invoice only exists once ZATCA has accepted it, and once accepted it cannot be quietly edited.
A timeline from now to 1 February
As of the end of September 2026 there are about four months left. A realistic plan for a small or mid-size logistics business:
- October — confirm scope and owner. Check the four years of revenue, look for ZATCA’s notification, and name one person who owns the project. In a small company this is usually the finance lead, not IT.
- October to November — choose your route. Ask whoever supplies your invoicing system, in writing, whether it supports Phase 2 clearance and reporting today, not “soon”. Ask how credit notes, debit notes, foreign-currency invoices and multiple branches are handled.
- November — list every place an invoice is produced. Head office, branches, a separate courier or warehouse billing tool, anything a driver or counter clerk uses. Each one either gets onboarded or stops issuing invoices.
- December — test with real cases. Use ZATCA’s testing arrangements and push through your awkward invoices: a USD freight invoice, a mixed invoice with zero-rated and standard-rated lines, a credit note for a rate reduction, a walk-in customer.
- January — go live early. Switch over before the deadline so that any rejected invoices surface while there is still time to fix them, not on 1 February with a month-end batch waiting.
Where logistics businesses usually trip
Rate changes after the invoice has gone
Freight is full of late changes: a carrier surcharge arrives after the invoice, a customer disputes waiting time, a container is re-weighed. Under Phase 2 you do not edit or reissue the original. You raise a credit note or a debit note that refers to it, and that note goes through clearance or reporting like any invoice. ZATCA’s published schedule of e-invoicing violations treats deleting or amending an e-invoice after issue as a serious offence, with fines starting at SAR 10,000 and rising with repetition. Build the habit now: nobody “fixes” an issued invoice.
Standard or simplified?
Most forwarding and transport invoices go to VAT-registered businesses and are standard tax invoices, so they must be cleared before you send them. But many logistics companies also serve individuals: someone shipping personal effects, a cash courier customer, a walk-in at a branch. Those are usually simplified invoices and follow the 24-hour reporting route. Decide the rule for each customer type in advance, and make sure business customers’ VAT numbers are on file, because a standard invoice needs the buyer’s details.
Invoices in US dollars
Freight is often priced in dollars, and a tax invoice may be issued in a foreign currency. ZATCA’s invoicing guidance, however, requires the VAT amount to be shown in Saudi riyals, converted at the rate published by the Saudi Central Bank for the date the tax becomes due. Check that your system can show both, and that the rate it uses is the published one rather than a rate someone typed in.
Mixed lines and re-billed charges
A single job can contain international freight, which is generally zero-rated, a local delivery leg inside the Kingdom, which is generally standard-rated at 15%, and charges you paid on the customer’s behalf such as duty or port fees. Each line needs the right tax category, because the e-invoice carries that category line by line. Costs you paid strictly as the customer’s agent may be treated differently from costs that form part of your own service. Agree the treatment of your common charge types with your adviser once, then set them up so the person raising the invoice is choosing a charge, not deciding the tax law.
Two systems, one company
It is common for a transport company to bill trips from one tool and everything else from its accounting package, or for a branch to keep its own invoice book. Phase 2 makes this visible. Every invoicing point has to be onboarded, and invoice numbering and records have to hold together. If you are going to consolidate how you invoice, doing it before February is cheaper than doing it twice.
What it costs to be late
ZATCA’s violations schedule for e-invoicing is progressive. Some failings start with a warning; others, such as not issuing electronic invoices, start with a fine and increase with each repetition. Beyond fines, the bigger practical risk is commercial: large customers increasingly expect cleared invoices, and an invoice that has not been accepted by Fatoora is not one their accounts team can rely on.
The deadline is fixed and the requirements are published. For most small forwarders and transporters the work is a few weeks of careful setup, not a major project, provided it starts in October rather than in January.
This article is general information as of 30 September 2026 and is not legal or tax advice. Thresholds, dates and requirements can change. Confirm how the rules apply to your business with your tax adviser or directly with ZATCA.