ZATCA Phase 2 for van sales: what to check in your app

What does ZATCA Phase 2 change for van sales?

Phase 2 connects the solution that issues your van invoices to ZATCA's Fatoora platform, so your invoices reach ZATCA instead of staying only in your own system. ZATCA runs e-invoicing in two stages. Phase 1, the Generation Phase, took effect on 4 December 2021 and requires invoices to come from a compliant electronic solution with additional fields. Phase 2, the Integration Phase, began on 1 January 2023 and rolls out in waves.

ZATCA's Wave 25 notice names the main additions: integrating with Fatoora, issuing e-invoices in a specific format, and including additional fields. The Detailed Guidelines give the format as XML or PDF/A-3 with embedded XML. ZATCA's How to Get Ready sheet adds that the solution must be able to connect to the internet.

The ZATCA documents we reviewed have no chapter on van sales. The rules attach to the invoice type and the solution, and applying them to a van is our reading, so check it with your adviser. The closest ZATCA example is an ice-cream truck selling at schools in remote areas, which we come back to below.

Does Phase 2 apply to your distribution business yet?

Phase 2 applies once ZATCA notifies you of your integration date, and Phase 1 requirements continue until then. The Detailed Guidelines say ZATCA notifies taxpayers at least six months in advance, through the official emails and SMS registered with it. They also allow an earlier voluntary start and recommend it, subject to ZATCA's roll-out strategy.

The newest wave notice we opened is dated 24 July 2026. It says Wave 25 covers taxpayers whose revenues subject to VAT exceeded SAR 187,500 during 2022, 2023, 2024 or 2025, and that ZATCA will notify them to integrate by no later than 1 February 2027. Check ZATCA's news page for anything published since, and go by the date in your own notification.

This guide is general information and does not replace tax or legal advice. Several ZATCA documents quoted here date from 2022 and 2023, and ZATCA states that the Arabic version of its resolution prevails over the English translation. Confirm your own obligations with ZATCA or a qualified adviser before you change how your vans invoice.

Does a van sale need clearance or reporting?

The answer depends on the invoice type: tax invoices go through clearance and simplified tax invoices go through reporting. ZATCA describes the tax invoice as issued for most B2B and B2G transactions, and the simplified tax invoice as issued mostly for B2C.

Van routes make the choice less obvious than the names suggest, because many stops are shops and a shop is a business. The Detailed Guidelines give suppliers the option of a simplified tax invoice on a B2B transaction only where the value of taxable supplies is under SAR 1,000. Above that, a sale to a shop points to a tax invoice and clearance. Your app therefore has to know who the customer is and what the sale is worth when the rep issues the invoice.

ZATCA also says tax invoices may be issued within 15 days of the month following the month of supply. Ask your adviser how that timing applies to a sale settled at the shop door.

Tax invoice: the solution submits XML to Fatoora through APIs before the buyer receives anything. Fatoora validates it, adds the cryptographic stamp and QR code, and returns the cleared invoice, which you share in XML or PDF/A-3 with embedded XML.
Simplified tax invoice: your solution stamps the XML using a ZATCA-issued cryptographic stamp identifier (CSID) and adds the QR code. The buyer gets a printed copy immediately, or an electronic copy if both sides agree. The XML must reach Fatoora within 24 hours of generation.
Credit and debit notes: these follow the type of the invoice they adjust, so a note against a tax invoice is cleared and a note against a simplified tax invoice is reported.

What happens when the van has no signal?

A simplified tax invoice can still be issued with no signal, and the 24-hour reporting limit still applies. ZATCA's resolution says that when the solution is offline, invoices and notes are queued, the solution stays operational, and they are reported after the connection returns. The Detailed Guidelines illustrate this with an ice-cream truck at schools in remote areas: the seller hands over the simplified invoice, has 24 hours to report it, and the device can send it automatically once the connection is restored.

If 24 hours pass without a connection, the same example has the seller notify ZATCA on a dedicated form on its website, notify ZATCA again when the connection returns, and report the transaction immediately.

Tax invoices are harder on a van because clearance comes before sharing. For no internet at the supplier, the guidelines list this action: report the failure to ZATCA, share the e-invoice, and resubmit once the issue is fixed. A footnote says the invoice is not fully compliant, counts as a VAT invoice until a fully compliant one is issued immediately after the connection is restored, and is not eligible for VAT deduction while uncleared. The seller should keep evidence of trying to clear it, such as an API log. ZATCA's worked example is an extended outage, so treat this as an exception path.

A broken device follows a different path. The guidelines describe notifying ZATCA immediately, contacting the solution provider, issuing the invoice manually, and generating the e-invoice with the transaction date once the device is fixed. A manual invoice is not eligible for VAT deduction, and ZATCA says it will investigate further a taxpayer who reports fixes frequently or for extended periods.

In practice, list the routes with poor coverage and the customers on them who need tax invoices. Those visits are the ones that need a written procedure.

Does every van device need to be registered?

Yes for devices that issue invoices: the Detailed Guidelines say every device issuing invoices under the same VAT number should be registered. Registration happens on the Fatoora portal, where you log in, choose to onboard a new solution unit or device, generate an OTP and enter it in the solution. The technical guidelines say the portal generates up to 100 OTPs per request and each one is valid for one hour, so plan fleet onboarding in batches.

Your app's design changes where the identifier sits. The technical guidelines describe POS devices that sign and send their own invoices, each needing its own CSID. They also describe dumb terminals that rely on a server, where the server stamps the invoice and applies the QR code before the customer sees it, and the terminal needs no CSID of its own. Both examples are about branch POS devices, so ask your provider which one your van app matches and how that fits the registration answer above. If stamping sits on a server, ask what happens on a route with no signal.

Each unit must also keep one unbroken chain. The resolution bars a unit from generating more than one sequence, the guidelines link invoices through the previous invoice hash, the counter cannot be reset, and the private stamping key cannot be exported. A lost or replaced phone therefore needs a procedure you have tested in advance.

What should a distributor check in its field app?

Test the app with your real invoice mix on a real route, because a compliance statement on a vendor's website cannot show you what happens at a shop with no coverage. Ask your provider to demonstrate each item in this list. Finance should also name the person who files ZATCA's failure form and decide where evidence such as API logs is kept, since that procedure belongs to your company whichever app you use.

Invoice type: does the app choose tax or simplified from the customer record and sale value, including the under SAR 1,000 B2B option?
Customer data: does it hold VAT numbers and additional buyer IDs? ZATCA says an invoice missing the additional buyer ID may be accepted with warnings, and recommends updating customer master data.
No-signal behavior: what can a rep issue for each invoice type, and where does stamping happen?
The 24-hour limit: can the office see which invoices are still queued on a device and how old they are?
Rejections and warnings: who sees them? ZATCA says a rejected invoice is corrected and submitted as a new document with its own counter and hash. It also says warnings are temporarily accepted, might become rejections, and will be investigated if continuous.
Returns: does each credit note carry the original invoice reference? ZATCA says a credit note without one violates Article 54 of the VAT regulations.
Corrections: can anyone edit or delete an issued invoice? ZATCA allows cancellation only through a credit note and a new invoice.
Access and logs: the app needs unique logins, no default passwords, a password reset on first use, and activity logs that users cannot change.
Device clock: ZATCA bars time changes that alter an invoice timestamp, so test what happens when a rep changes the phone's date.
Buyer copy: can the app print a simplified invoice on the spot and deliver a tax invoice in XML or PDF/A-3, with the visible content in Arabic?
Archive and audit: can finance export invoices and notes? The guidelines say taxpayers should give ZATCA auditors the archived files.
Provider evidence: the How to Get Ready sheet asks taxpayers to verify with their provider that the solution works correctly and generates compliant invoices.

How does Repzo handle this?

Repzo SFA issues invoices from the van and files them with ZATCA under Phase 2 through Fatoora. Reps carry stock, create sales orders or direct invoices at the customer's door, collect payments and print receipts on the spot. Every printout carries its QR code, and nobody re-enters invoices in a separate portal. The invoicing page has more detail.

These are Repzo's own product statements, and ZATCA's rules apply to you as the taxpayer whichever provider you use. Our published pages do not spell out every scenario in this guide, including how a tax invoice behaves on a route with no signal, so ask us to run those cases with your own invoice types. You can contact our sales team to arrange it.

Invoices carry the cryptographic stamp and QR code, with VAT calculated to Saudi rules and Arabic and English layouts.
Reps handle returns and credit notes in the field and record cash and cheque payments against the invoice.
Van sales run from on-hand stock with load reconciliation, and order taking and van sales work offline, syncing once the phone reconnects.
Invoices and payments sync to your accounting or ERP system.
Our Jeddah team imports your data, connects invoicing to Fatoora and trains your reps.

Frequently asked questions

Is there a ZATCA rule written specifically for van sales?

We did not find one in the ZATCA documents we reviewed. The rules depend on the invoice type and the solution, and ZATCA's closest example is an ice-cream truck selling in remote areas. Ask ZATCA or your adviser how the rules apply to your routes.

Can a rep hand over a printed invoice before it reaches ZATCA?

Yes for a simplified tax invoice, which ZATCA says must be presented to the buyer immediately after generation and reported within 24 hours. A tax invoice is different: it must be cleared before it is shared with the buyer.

What if a simplified invoice misses the 24-hour limit?

ZATCA's example has the seller notify ZATCA on a dedicated form on its website. The seller then notifies ZATCA again when the connection is restored and reports the transaction immediately.

Can we keep the invoicing solution we used for Phase 1?

You can if it is updated. ZATCA says a taxpayer can use the same solution by updating it to comply with Phase 2 requirements, so ask your provider whether that update also covers your van devices.

Can I rely on this guide for my compliance decisions?

No. This guide is general information based on ZATCA documents we opened, and some of them date from 2022 and 2023. Confirm your obligations with ZATCA or a qualified adviser.