ZATCA e-invoicing: the invoice a clinic must issue

ZATCA, the Zakat, Tax and Customs Authority in Saudi Arabia, runs e-invoicing in two phases. Phase 1, since December 2021, ended handwritten and unstructured invoices; Phase 2 integrates each taxpayer's invoicing system with the authority's platform in waves assigned by annual VAT-taxable revenue. Wave 24 covered businesses above the threshold set for 2022, 2023 or 2024, with integration due by 30 June 2026, and that wave reached private clinics. Every paid consultation, procedure and service at a private practice is a taxable transaction, so a clinic that bills patients from a diary and a receipt book is out of format.

What it requires

• Issue invoices and simplified invoices electronically, in the structured XML format the authority specifies, with a QR code on simplified invoices
• Include the mandatory fields: seller VAT number, invoice type, timestamp, unique identifier, a cryptographic stamp and a hash chain linking each invoice to the previous one
• Integrate the invoicing system with the authority's platform (clearance for standard invoices, reporting for simplified ones) once your wave is called
• Keep credit and debit notes linked to the invoice they correct
• Store invoices for the retention period the regulation sets, unaltered

What the system provides

• An invoicing module that produces invoices with the Phase 2 fields, the QR code and the hash chain, per visit and per service
• Credit notes linked to the original invoice; no invoice edited after issue
• Receipts sent to the patient on WhatsApp, with the invoice attached
• An end-of-shift report per receptionist and export to your accountant or e-invoicing tool

What we do not claim yet

• Integration with the authority's platform is buildable against the published specification, but it is built and tested per clinic, and no certification is claimed until a clinic's integration is live
• Your wave, your VAT registration and your mix of simplified and standard invoices are confirmed with your accountant, not assumed

Sources

• EY tax alert: ZATCA Phase 2 integration waves
• LogioLegion: practice management software with NPHIES, Nafath and ZATCA

These pages are engineering notes, not legal advice. Confirm your obligations with the regulator or a licensed adviser before you rely on them.