From Wave 1 to Wave 24: The Evolution of ZATCA's E-Invoicing Rollout

ZATCA's e-invoicing mandate didn't arrive all at once — it has expanded methodically, wave by wave, since its first phase went live in December 2021. Looking at how that rollout has progressed helps explain both where the mandate stands today and what businesses should expect as it continues.

The starting point: Phase 1

Phase 1, the Generation phase, required VAT-registered businesses to issue structured, QR-coded tax invoices instead of the informal paper and PDF invoices many had relied on. It didn't yet require direct integration with ZATCA's systems — that came next.

Phase 2 begins: the early, largest-taxpayer waves

Starting in January 2023, ZATCA began rolling out Phase 2 — the Integration phase — in waves defined by annual revenue. The earliest waves targeted only the very largest taxpayers, businesses with revenue well into the billions of riyals, giving both ZATCA and early adopters a chance to work through integration issues at a manageable scale before expanding further.

A steady march down the revenue scale

Each subsequent wave has lowered the qualifying revenue threshold, bringing progressively smaller businesses into scope. This has been a deliberate, incremental design choice: rather than mandating integration for the entire economy simultaneously, ZATCA has let the system mature wave by wave, refining requirements and support as adoption has grown.

Where things stand: Wave 24

The most recent wave, Wave 24, lowers the threshold to SAR 375,000 in annual revenue during 2022, 2023 or 2024 — by far the lowest threshold yet, and one that pulls thousands of small and mid-sized businesses into mandatory integration for the first time. The integration deadline for Wave 24 is 30 June 2026, which is also when ZATCA's penalty-waiver period ends and enforcement moves from educational to strict.

What the pattern suggests going forward

Given the consistency of ZATCA's approach so far, it's reasonable to expect further waves continuing to extend Integration Phase coverage even further down the revenue scale, eventually reaching the great majority of VAT-registered businesses in the Kingdom. Businesses not yet in scope should treat that as a matter of "when," not "if."

Conclusion

The path from Wave 1 to Wave 24 shows a regulator methodically scaling a Continuous Transaction Control system rather than forcing a disruptive big-bang rollout. For businesses watching from outside the current scope, the safest assumption is that their own wave is coming — and that preparing ahead of a formal announcement beats scrambling once one arrives.