Does a UAE Company Selling Into Saudi Arabia Need ZATCA Fatoora Phase 2? What Is Confirmed, What Is Not and What to Ask

It is not confirmed that a UAE company with no Saudi presence must join ZATCA's Fatoora Phase 2. ZATCA's own overview says Phase 1 applies to all taxpayers except non-resident taxpayers, and it says nothing about non-residents in Phase 2. The wave 25 criteria, announced on 24 July 2026, are described for resident taxpayers. This page sets out what is known, as of November 2026, and what to ask ZATCA.

What does ZATCA say about non-residents and e-invoicing?

Three things are on ZATCA's pages. Phase 1 (generation) has applied since 4 December 2021 to all taxpayers except non-resident taxpayers. Phase 2 (integration) is enforceable from 1 January 2023, rolled out to targeted groups by wave. ZATCA says it notifies taxpayers of their wave at least six months in advance.

What is missing is a sentence either way on non-residents in Phase 2. EY's summary of wave 25 does not address non-resident taxpayers and applies the criteria to taxpayers resident in Saudi Arabia. Absence of a statement is not the same as an exemption. That is why the next sections split by how you actually sell.

Which situation are you in?

The first row rests on noon's help centre, which says UAE sellers on this lane do not need a KSA trade license or KSA VAT registration. The other rows are our reading of how the rules fit together. They are not ZATCA statements.

Do I need a Saudi VAT registration at all?

Often the Fatoora question comes second to the registration question. ZATCA's guideline says non-residents who must pay VAT on supplies they make or receive in Saudi Arabia must register for VAT, regardless of the value of the supplies. The standard rate is 15%.

Whether you owe Saudi VAT on a given sale depends on where title passes and who imports. That is covered in Saudi VAT for UAE companies. If you are not registered and not required to be, there is no Saudi VAT-subject revenue and no Fatoora wave to test.

How would I check whether a wave covers me?

If you are registered, or may be, work through this in order:

1. Write down whether you hold a Saudi VAT number, and whether you did so as a resident or as a non-resident.
2. Add up your Saudi VAT-subject revenue for each calendar year in the latest wave. Wave 25 uses 2022, 2023, 2024 and 2025 and a threshold of SAR 187,500.
3. Compare against the earlier waves in every ZATCA Phase 2 wave in one table. Passing a threshold in any named year puts a resident taxpayer in that wave.
4. Ask ZATCA, in writing, whether your registration status means you are in scope, and keep the answer.

What should I ask ZATCA or my Saudi adviser?

Send the questions in plain, short form:

• We are a UAE company registered for Saudi VAT as a non-resident (with or without a tax representative). Is Phase 2 integration required for us?
• If yes, which wave, and what is our integration date?
• If we sell only through a marketplace that issues the customer invoice, who must issue the e-invoice?
• Which invoice types must we issue, tax invoice or simplified tax invoice?

ZATCA describes the tax invoice as usually business to business and the simplified tax invoice as usually business to consumer. Marketplace models differ, and we have not confirmed from a marketplace page who issues what in Saudi Arabia.

What should I keep on file while the answer is open?

Keep a short folder: your Saudi VAT registration confirmation if you have one, the written ZATCA or adviser answer on e-invoicing, your revenue by calendar year for Saudi supplies, and a list of the invoice types and systems you use for Saudi customers. If ZATCA later puts you in a wave, the same folder tells your accounting vendor exactly what to configure. This is a practical suggestion, not a ZATCA requirement. If you are unsure whether you even made taxable supplies in Saudi Arabia, settle that first with the registration rules in Saudi VAT for UAE companies.

What about the UAE's own e-invoicing rules?

They are separate. The UAE system starts on 1 January 2027 for businesses with revenue of AED 50,000,000 or more and on 1 July 2027 for smaller ones, and B2C transactions are outside it for now. The ministerial decision we read does not address non-residents or exports. See UAE e-invoicing for online sellers and the side-by-side in UAE e-invoicing vs Saudi Fatoora.

What goes wrong for UAE sellers?

• Assuming a Saudi exemption from a vendor blog. Several vendor pages say non-residents never issue e-invoices. We did not find that stated for Phase 2 on ZATCA's pages we could read.
• Assuming you are in because you are registered. A registration alone does not tell you which wave applies.
• Forgetting that status can change. Opening a Saudi branch, hiring locally or forming a Saudi entity can turn you into a resident taxpayer.
• Mixing up the UAE and Saudi timelines. A UAE deadline does not satisfy ZATCA, and the reverse.

Worked example, illustrative: a Sharjah brand sells through the noon UAE-to-KSA lane only, with no Saudi VAT number. Per noon it needs no KSA registration, so it has no Saudi VAT-subject revenue to test against wave thresholds. Its own UAE e-invoicing duties depend on its UAE revenue and customers. The brand is invented; the noon rule is from noon's help centre.

FAQ

Do non-resident companies have to issue e-invoices in Saudi Arabia? ZATCA says Phase 1 applies to all taxpayers except non-resident taxpayers. Its overview does not say whether Phase 2 applies to non-residents, so a registered UAE company should ask ZATCA directly.

Is a UAE company in ZATCA wave 25? Not confirmed. The announcement summaries we read describe resident taxpayers with taxable turnover above SAR 187,500 in any of 2022 to 2025, and integration due by 1 February 2027.

Do I need Saudi VAT registration to sell on noon KSA from the UAE? noon's help centre says UAE sellers on its UAE-to-KSA lane do not need a KSA trade license or KSA VAT registration. Check the current terms before signing the KSA terms and conditions.

When must a non-resident register for Saudi VAT? ZATCA's guideline says non-residents who owe VAT on supplies made or received in Saudi Arabia must register regardless of value. The application is due within 30 days of the first such supply.

Will ZATCA warn me before a deadline? ZATCA says it notifies targeted taxpayers at least six months before their wave date. Whether a non-resident registrant gets such a notice is not stated, so ask rather than wait.

Does UAE e-invoicing cover my Saudi sales? The UAE decision we read is about the UAE system, and it does not mention Saudi sales or exports. Ask the Ministry of Finance about cross-border invoices.

What to do next

Decide first whether you hold, or must hold, a Saudi VAT registration; then put the written questions above to ZATCA or your Saudi adviser. Blooprint manages Amazon.ae and noon seller accounts through UAE marketplace management, and it does not give tax advice. For the wider Saudi route, read selling in Saudi Arabia from the UAE.