Who is in scope
ZATCA’s Wave 25 criteria cover taxpayers whose revenues subject to VAT exceeded SAR 187,500 during 2022, 2023, 2024, or 2025. Targeted taxpayers are to be notified by ZATCA and must integrate their electronic-invoicing solutions with the Fatoora platform no later than February 1, 2027.
The revenue test is especially relevant to smaller companies that may not view themselves as large businesses. A company that exceeded the threshold in only one historical year may still be selected. Businesses should therefore review historical VAT-subject revenue rather than relying only on current-year turnover.
Integration is more than creating a PDF
Saudi Arabia’s Integration Phase requires a technical connection between the taxpayer’s invoicing solution and ZATCA’s Fatoora platform. It also requires invoices to be issued in the prescribed format and to include additional required fields. A PDF emailed to a customer is not, by itself, a substitute for a compliant electronic-invoicing solution.
The implementation builds on Phase One, which required taxpayers to stop generating handwritten invoices and invoices produced through ordinary word-processing or spreadsheet tools where those methods do not meet the electronic-invoicing requirements.
A practical preparation sequence
1. Confirm historical scope
Pull VAT-subject revenue for each of the four relevant years. Preserve the calculation and the source reports used to determine whether the SAR 187,500 threshold was exceeded.
2. Check the solution
Ask the software provider whether the system supports the required Fatoora integration, invoice format, fields, identifiers, security controls, and archival requirements. Obtain written confirmation rather than relying on a sales presentation.
3. Clean master data
Review customer tax identification numbers, addresses, VAT registration information, product classifications, units of measure, prices, discounts, and tax codes. Poor master data can cause rejection or inaccurate reporting.
4. Test the full transaction lifecycle
Test issuance, credit notes, cancellations, corrections, connectivity interruptions, returns, exports, and access for tax audits. Include both B2B and B2C scenarios where relevant.
5. Establish governance
Assign responsibility for monitoring ZATCA notices, maintaining the system, approving changes, and preserving evidence of testing. Keep copies of implementation plans and sign-offs.
Example
A Saudi consulting company had VAT-subject revenue of SAR 220,000 in 2023 but only SAR 150,000 in 2025. It should not assume that the lower 2025 revenue removes it from consideration. The historical threshold test means it should verify whether it is selected for Wave 25 and prepare for the February 1, 2027 integration deadline.