ZATCA Wave 25 E-Invoicing: Who Must Integrate With Fatoora by 1 February 2027 and the SAR 187,500 Threshold Explained

ZATCA wave 25 requires resident taxpayers whose VAT-subject revenue exceeded SAR 187,500 in any of 2022, 2023, 2024 or 2025 to integrate their e-invoicing solution with the Fatoora platform by 1 February 2027. ZATCA announced the criteria on 24 July 2026. The threshold is half the SAR 375,000 used in wave 24. If you are a UAE-based seller, the open question is whether this wave reaches you at all; this page covers that too, as of November 2026.

What is ZATCA wave 25?

Wave 25 is the latest group of taxpayers ZATCA has told to move into Phase 2 (the integration phase) of e-invoicing. Phase 2 has been enforceable since 1 January 2023 and is rolled out wave by wave. Wave 25 halves the previous threshold from SAR 375,000 to SAR 187,500.

The EY alert is dated 10 August 2026 and cites a decision numbered 1448-99-238 published in the Official Gazette in July 2026. For all earlier waves, see every ZATCA Phase 2 wave in one table.

Who is in wave 25?

The criteria, in plain words:

• The taxpayer is a resident taxpayer with taxable turnover above SAR 187,500 (about USD 50,000).
• The turnover test is run on each of four calendar years, 2022 to 2025. Passing it in any one year is enough, even if your current revenue is lower.
• 2025 revenue is used for the first time. A business that started in 2025, or one that was under the threshold in 2022 to 2024 but over it in 2025, can be caught.

SAR 187,500 is half of the standard mandatory VAT registration threshold of SAR 375,000. So the wave reaches below the point at which registration is mandatory.

What is the wave 25 deadline?

Taxpayers should be ready to comply with the Phase 2 requirements by 1 February 2027, and the Decision says compliance starts from that date. ZATCA says it will contact the taxpayers that fall within the wave, and Grant Thornton adds that you do not need to wait for that notice to check your own eligibility.

ZATCA's general rule is notice of at least six months before a wave date. From the 24 July 2026 announcement to 1 February 2027 is just over six months, so the integration work is a short project.

What does integration with Fatoora involve?

Phase 2 means integrating your e-invoicing solution with Fatoora, issuing invoices in a specified format and adding extra invoice fields. An electronic invoice is a structured electronic tax invoice; a scanned or copied paper invoice does not count.

A typical path, in order:

1. Confirm you are in the wave: add up VAT-subject revenue for 2022, 2023, 2024 and 2025.
2. Ask your accounting or ERP vendor whether its Fatoora Phase 2 module is live and what it costs. ZATCA does not publish vendor prices.
3. Pick a solution. ZATCA keeps a directory of providers that passed its qualification, and says taxpayers may use any compliant provider, listed or not.
4. Test with your real invoice types: tax invoices to businesses, simplified invoices to consumers, credit and debit notes.
5. Complete the integration with Fatoora before 1 February 2027 and keep the evidence.

What should a seller keep ready for the integration?

ZATCA does not publish a single checklist for wave 25 in the sources we read, so this list is practical, not official. Have these ready before you brief a vendor: your Saudi VAT registration number, the revenue figures for 2022 to 2025, a list of invoice types you issue (tax invoice, simplified tax invoice, credit note, debit note), and the accounting system that produces them. ZATCA separates the tax invoice, usually issued business to business, from the simplified tax invoice, usually business to consumer.

Does wave 25 apply to a UAE company selling into Saudi?

Not clearly. The EY summary applies the criteria only to taxpayers resident in Saudi Arabia and does not address non-residents. ZATCA's own overview says Phase 1 covers all taxpayers except non-resident taxpayers, but says nothing about non-residents in Phase 2.

So the honest answer is that we found no ZATCA text putting a non-resident company without a Saudi presence into wave 25, and no ZATCA text excluding one from Phase 2. If you hold a Saudi VAT registration through a tax representative, ask ZATCA in writing. The longer reasoning is in does a UAE company selling into Saudi need Fatoora Phase 2, and the registration rules are in Saudi VAT for UAE companies.

What does wave 25 mean for UAE sellers using the noon KSA lane?

According to noon's help centre, a UAE seller on the noon UAE-to-KSA lane does not need a KSA trade license or KSA VAT registration. A business with no Saudi VAT registration has no Saudi VAT-subject revenue to test against the wave threshold. That is our reading, not a ZATCA statement. If you later register in Saudi Arabia, revisit this page. See selling in Saudi Arabia from the UAE.

What goes wrong when sellers prepare late?

• Testing only the current year. The wave tests four years. A business that dipped below SAR 187,500 in 2025 can still be caught by 2023 or 2024.
• Assuming a notice will arrive in time. ZATCA says it will notify, but the gap from announcement to deadline is just over six months. Vendors' Fatoora modules can have queues; ask for a written go-live date.
• Mixing up the two phases. Phase 1 (generating and storing e-invoices) is already in force for resident taxpayers. Wave 25 is about Phase 2, the connection to ZATCA.
• Trusting old threshold tables. Pages written before 24 July 2026 stop at wave 24 and SAR 375,000.

Worked example, illustrative: a Jeddah trading company had VAT-subject revenue of SAR 200,000 in 2024 and SAR 160,000 in 2025. It passed SAR 187,500 in 2024, so under the any-year rule it falls in wave 25 even though 2025 was lower. The figures are invented; the rule is from the announcement summaries above.

What are the penalties for missing the date?

EY says taxpayers should comply to avoid possible penalties, without stating amounts. Software vendor blogs quote specific SAR fine ranges; we did not confirm those from a ZATCA page, so we do not repeat them. Ask ZATCA or your adviser for the current penalty schedule.

FAQ

When is the ZATCA wave 25 deadline? Integration with the Fatoora platform is due by 1 February 2027. ZATCA announced the criteria on 24 July 2026 and says it will notify the taxpayers affected before they must link their systems.

What is the wave 25 threshold? Taxable turnover above SAR 187,500, roughly USD 50,000, in any of 2022, 2023, 2024 or 2025. It is half of wave 24's SAR 375,000.

Does wave 25 use 2025 revenue? Yes. EY notes it is the first wave to use calendar year 2025 revenue as a criterion, so businesses set up in 2025 may be caught.

Do I have to wait for a ZATCA notice? No. ZATCA will contact affected taxpayers, but you can check your own revenue against the criteria now, and you should plan early because the time to 1 February 2027 is short.

Is a UAE company with no Saudi branch in wave 25? Not confirmed. The announcements we read describe resident taxpayers and do not mention non-residents. Ask ZATCA in writing if you hold a Saudi VAT registration.

Will there be a wave 26? Not confirmed as of November 2026. No date or threshold has been published that we could find. EY says taxpayers outside the first 25 waves should watch for future ZATCA announcements.

What to do next

Check your VAT-subject revenue for 2022 to 2025 against SAR 187,500, then ask your accounting vendor for its Fatoora Phase 2 date. If you also sell in the UAE, compare the two regimes in UAE e-invoicing vs Saudi Fatoora. Blooprint can run the marketplace side through UAE marketplace management.