The technical specifications and procedural rules for the implementation of E-invoicing regulations have been released

Key provisions of the Implementation Resolution and associated technical specifications

The E-invoicing resolution is applicable to persons who are subject to E-invoicing as per Article (3) of the E-invoicing Regulations. The resolution highlights the obligations for those persons to be able to generate, process, receive, transmit/integrate, store and keep electronic invoices (e-invoices) and electronic debit/credit notes (E-notes). The E-invoicing requirements are applicable to the following transactions:

Standard and zero-rated transactions;

Transactions to business-to-consumer (B2C) customers or below the simplified invoicing limit;

Domestic sales, export, nominal and intra-Gulf Cooperation Council (GCC) supplies, and advances received.

The E-invoicing resolution is not applicable to exempt supplies (and related advance payments), imports of goods, and import of services subject to the Reverse Charge Mechanism (RCM).

The annexes provide further detail on the technical requirements, the prohibited features of the E-invoicing solutions and the E-invoicing fields as per the respective phase. In summary, the following requirements are applicable per phase (amongst others):

Phase 1: 4 December 2021

Businesses are required to issue, process and receive e-invoices and E-notes;

No required e-invoice or e-note format is needed as long as the required data is present on the invoices and notes;

Meet the invoice fields mandated as per 4 December 2021, as well as the conditional fields in case applicable to the business (transaction), including requirements around allowable values;

Ensure export to an offline internal and external archive with the aim to keep a record of all generated e-invoices and E-notes;

For simplified e-invoices and notes, a Quick Response (QR) code of a Base64 format with up to 500 characters must be generated and printed on simplified e-invoices and E-notes. Additionally, controls/mechanisms should be implemented to avoid tampering of the e-invoices.

Phase 2: 1 June 2022 (dependent on the phased roll-out)

The second part of the E-invoicing implementation covering the integration between the taxpayer and GAZT will take place in a phased roll-out on 1 June 2022. More details are expected to be issued, but this second phase will include the following requirements amongst other:

The e-invoice and E-notes must be issued in Extensible Markup Language (XML) or PDF/A-3 (with embedded XML) format;

Meet all additional mandated invoice fields (e.g. seller-id), as well as the conditional fields in case applicable to the business (transaction) including requirements around allowable values;

Each e-invoice and e-note should generate an universally unique identifier (UUID), i.e. a 128-bit number, generated by an algorithm chosen to make it unlikely that the same identifier will be generated by anyone else in the known universe using the same algorithm;

For simplified e-invoices and E-notes, businesses will need to register with GAZT to obtain a Digital Certificate (DC) to request the Cryptographic Stamp Identifier (CSI) for its E-invoicing solution;

A cryptographic stamp will be generated via cryptographic algorithms and should be included on the e-invoice or e-note;

The QR code requirements are rolled out to all types of e-invoices and E-notes. The QR code should include the cryptographic stamp based on the respective public key for both the simplified and the standard e-invoices and E-notes;

The E-invoicing solution should be able to provide a secure digital fingerprint (Hash) for each e-invoice;

E-invoicing solutions should have a tamper-resistant counter for each e-invoice and e-note which will disallow the e-invoice sequence to be reset; and

Establish a connection with an external Application Programming Interface (API) between taxpayer’s E-invoicing solutions and GAZT to periodically upload simplified e-invoices and E-notes, as well as transmit e-invoices and E-notes to receive a response in real time. The GAZT will provide the details around timelines, targeted groups and implementation phases of the integration in subsequent resolutions.

The resolutions annexes also refer to the draft technical specifications such as Data Dictionary, XML Implementation Standard and Security Implementation Standards. It is expected that GAZT will provide further details about the approved external providers of E-invoice Generation Solutions and the potential
certification in this respect.

Next steps

Businesses who are required to issue (simplified) e-invoices and/or E-notes as per Article (3) of E-invoicing Regulations must take note of the phased requirements applicable to them by 4 December 2021 and 1 June 2022 respectively. In this respect, businesses should assess whether their current system (and/or external E-invoicing solution) and business processes will meet the draft resolution requirements, as well as the technical specifications.

In addition, GAZT announced a public consultation whereby comments can be submitted until 17 April 2021.This will allow taxpayers, E-invoicing service providers, advisors and other interested parties to provide input on the draft resolution, annexes and related technical specifications. 

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