ZATCA e-invoicing: phase, wave, or group? What you are actually asking about

People search for "ZATCA phase 3", "phase 4" and "phase 5" every month, and none of them exists under the names the Zakat, Tax and Customs Authority uses. Saudi e-invoicing has exactly two phases: the generation phase, in force since 4 December 2021, and the integration phase, in force since 1 January 2023. What gets called "phase 3" or "phase 5" is in fact a wave (ZATCA's Arabic pages say "group", المجموعة) inside Phase 2. Twenty-five waves have been announced so far; the latest, Wave 25, has a date of 1 February 2027.

Zakat, Tax and Customs Authority, E-invoicing roll-out phases, checked 5 September 2026.

Last verified against ZATCA’s published pages on 5 September 2026.

Three reasons. ZATCA describes Phase 2 as enforceable "in waves", and each new wave lands with a new number and a new date, which is what a new phase would look like. The Arabic and English pages use different words, المجموعة (group) and "wave", so the same thing has two names, and vendors add a third by translating "wave" back into Arabic as الموجة. And the numbers are large: "Wave 25" does not sound like something that fits inside a single phase. It does.

Zakat, Tax and Customs Authority, What is e-invoicing?, checked 5 September 2026.

Phase 1 — generation. Enforceable from 4 December 2021 for all taxpayers subject to the E-Invoicing Regulation, and for any third party issuing invoices on a taxpayer's behalf. ZATCA's roll-out page excludes non-resident taxpayers. The requirement is to generate and store tax invoices and notes electronically through a compliant solution, instead of on paper or as scanned files. There is no connection to ZATCA's systems in this phase and there are no waves; it started for everyone on one day.

Zakat, Tax and Customs Authority, E-invoicing roll-out phases, checked 5 September 2026.

Phase 2 — integration. Enforceable from 1 January 2023 "in waves". The solution must integrate with the Fatoora platform and invoices must be generated in the required format, and ZATCA commits to notifying taxpayers of their wave at least six months in advance. What changes technically (the stamp, the hash chain, clearance and reporting) is set out field by field in what ZATCA Phase 2 e-invoicing integration actually requires.

Zakat, Tax and Customs Authority, E-invoicing roll-out phases, checked 5 September 2026.

A wave is a batch of taxpayers that ZATCA obliges to integrate by a given date. Every wave is defined by one criterion and one only: a threshold of revenue subject to VAT, in named years. Sector, legal form and branch count play no part. Wave 1 was businesses whose VAT-taxable revenue exceeded SAR 3 billion in 2021; the threshold then fell wave by wave to SAR 187,500 in any of 2022 to 2025 for Wave 25, announced on 24 July 2026.

Thresholds and dates: each wave's own ZATCA announcement, as recorded in the ZATCA integration waves dataset, verified 3 September 2026.

The whole picture in a few lines, in place of a diagram:

• Phase 1 — generation · 4 December 2021 · everyone on one day, no waves.
• Phase 2 — integration · from 1 January 2023 · in waves, each with a revenue threshold, years and a date:
• ↳ Wave 1 · revenue above SAR 3,000,000,000 in 2021 · integration from 1 January 2023.
• ↳ Wave 17 · revenue above SAR 2,500,000 in 2022 or 2023 · by no later than 31 July 2025.
• ↳ Wave 25 · revenue above SAR 187,500 in any of 2022–2025 · by no later than 1 February 2027.
• ↳ Wave 26 · no criteria published by ZATCA as of the verification date above.

Thresholds and dates: each wave's own ZATCA announcement, as recorded in the ZATCA integration waves dataset, verified 3 September 2026.

So when you type "phase 3" or "phase 5" into a search box, the question you actually mean is: which wave am I in, and what is my date? That one has a precise answer.

Take your revenue subject to VAT, as filed in your returns, for each year from 2021 to 2025 and compare it with the wave thresholds in order. Your wave is the first one whose threshold you exceeded in one of its years; a business already caught by an earlier wave is not moved to a later date by Wave 25. The ZATCA wave lookup runs that comparison on your own figures, in the browser, without sending a single number to us. If your revenue was above SAR 187,500 in any of the four years and you were not caught earlier, the detail of your date is in ZATCA Wave 25: who is in it and what is required by 1 February 2027.

Zakat, Tax and Customs Authority, Wave 25 selection criteria, 24 July 2026.

This is where the confusion costs money. The announcements for Waves 1 to 16 give the date on which integration starts: "will begin on 1st of January 2023" for Wave 1, "from 1 April 2025" for Wave 16. ZATCA's roll-out table, meanwhile, shows a different date for each of those waves: the end of the integration window. Wave 16, for example, appears in the table with 30 June 2025, three months after the date in its own announcement. Read the announcement alone and you think you have three more months; read the table alone and you do not know when integration opens for you.

Zakat, Tax and Customs Authority, Wave 16 selection criteria, 27 September 2024.

From Wave 17, announced on 1 November 2024, ZATCA changed the wording to "by no later than 31 July 2025", and from then on the announcement date and the table date are the same date with the same meaning: the last day, not the first. Wave 25's English announcement says "by no later than February 1, 2027"; its Arabic text says «ابتداءً من ١ فبراير ٢٠٢٧» ("starting from"), and the table shows the same date. The only safe reading is to be integrated, and issuing in the required format, before that day.

Zakat, Tax and Customs Authority, Wave 17 selection criteria, 1 November 2024.

Every wave (threshold, years, announcement date, deadline, which kind of deadline wording it uses) with a link to its own ZATCA announcement is in the ZATCA integration waves dataset. Read it on the page or download it as a file; every row is re-verified against its page on zatca.gov.sa. And once you know you are in a wave, the next question is not "when" but "what changes in my invoices", starting with the route each invoice takes, clearance for a standard tax invoice and reporting for a simplified one, in simplified vs standard tax invoice: which you issue, and why they travel differently.

Thresholds and dates: each wave's own ZATCA announcement, as recorded in the ZATCA integration waves dataset, verified 3 September 2026.

ZATCA states that Phase 1 applies to all taxpayers subject to the E-Invoicing Regulation and to anyone issuing invoices on a taxpayer's behalf, and its roll-out page names one explicit exclusion: non-resident taxpayers. Phase 2 obliges nobody until their wave is announced, and the criterion is VAT-taxable revenue. On the pages we verified there is no list of sectors or entities "exempt" from e-invoicing; if someone tells you your activity is exempt, ask for the ZATCA link. Where the pages are silent, so are we.

Zakat, Tax and Customs Authority, E-invoicing roll-out phases, checked 5 September 2026.

If you know your wave now but not what has to change in your system before its date, that is the systems integration work we do. Ten minutes on WhatsApp will tell you whether this fits: tell us your wave and what you invoice from today.

1. ZATCA — E-invoicing roll-out phases — checked 5 September 2026
2. ZATCA — What is e-invoicing? — checked 5 September 2026
3. ZATCA — Phase Two (Integration Phase): first wave criteria (24 June 2022) — checked 5 September 2026
4. ZATCA — Wave 16 selection criteria (27 September 2024) — checked 5 September 2026
5. ZATCA — Wave 17 selection criteria (1 November 2024) — checked 5 September 2026
6. ZATCA — Wave 25 selection criteria (24 July 2026) — checked 5 September 2026
7. ZATCA integration waves dataset (every row linked to its announcement) — checked 3 September 2026

Primary ZATCA pages only, each checked on the date shown.