ZATCA Phase 2 waves: how to find out when yours starts
Waves are defined by annual revenue and announced progressively, with at least six months notice sent directly to the taxpayer. Here is how the mechanism works and how to check your own position.
4 min read
Phase 2 was never switched on for everyone at once. The Zakat, Tax and Customs Authority rolls it out inwaves, defined by annual taxable revenue and starting with the largest taxpayers.
How the mechanism works
- ZATCA announces a wave, defined by a revenue threshold for a specified reference year.
- Taxpayers whose revenue exceeded that threshold in the reference year fall into the wave.
- ZATCA notifies affected taxpayers directly, with at least six months' notice before the wave's integration date.
- From that date, the taxpayer's systems must be integrated — signing, hashing, clearing or reporting.
The pattern has been downward: the first wave covered the very largest taxpayers, and each subsequent wave lowered the threshold, drawing in progressively smaller businesses.
Why this article does not list the dates
Because a stale deadline is worse than no deadline. Wave announcements continue, thresholds move, and a blog post that confidently tells you "your wave is X" when it is not is actively harmful.
Where to get your actual date:
- TheFatoora portal — log in with your credentials and check your status
- Yourregistered correspondence with ZATCA — email and the contact details on your VAT registration
- Yourtax adviser or accountant, who tracks this for their clients
If you are not sure whether you have been notified, check that the contact details on your ZATCA registration are current. A notice sent to a former accountant's email is still a notice.
What to do with the six months
The notice period is not preparation time you should spend waiting. A realistic plan:
Month 1 — assess. Does your current POS support Phase 2 at all? Ask the vendor for it in writing: UBL 2.1, hash chaining, on-device or server signing, per-device onboarding, credit and debit notes.
Month 2 — decide. If the answer is no, or "it is on the roadmap", you are now shopping for a system. Better to know in month 2 than month 5.
Month 3 — pilot. Onboard one terminal in the sandbox. Issue every document type you actually use — simplified invoice, standard invoice, credit note, debit note — and confirm each validates.
Month 4 — data. Clean up what the invoice needs: your legal name matching your commercial registration, your VAT number, your address, correct VAT treatment per product, and customer records for B2B buyers.
Month 5 — train. Cashiers need to know how to mark a B2B sale, how to issue a credit note, and what to do during an outage. Fifteen minutes each, rehearsed.
Month 6 — go live and watch. Watch the acceptance dashboard daily for the first fortnight. Early rejections are usually configuration, and they are cheap to fix in week one and expensive in month six.
The trap: assuming Phase 1 compliance means Phase 2 readiness
Phase 1 required a structured invoice with a QR. Phase 2 requires cryptographic identity, a chained hash, and a live relationship with the authority. Systems that passed Phase 1 comfortably can fail Phase 2 completely, because the requirements are different in kind rather than in degree.
If your vendor's answer to "are you Phase 2 ready?" is "we have been compliant since 2021", ask again more precisely.
Questions to put to your vendor in writing
- Do you produce UBL 2.1 XML with the previous-invoice hash?
- Does signing happen on the device or on your server?
- Can I onboard a new terminal myself, and how long does it take?
- Do you handle credit and debit notes referencing the original invoice?
- Where do I see accepted, warned and rejected invoices?
- What happens to invoicing during an internet outage?
- What happens when a device certificate approaches expiry?
Answers in writing. A vendor who will only answer these verbally has told you something.
What Wameed does
Phase 2 is native: on-device signing, the hash chain, self-service per-device onboarding, credit and debit notes, a dashboard separating accepted from warned from rejected, and 24 hours of offline issuance. See theZATCA page and thecomplete Phase 2 guide.
Not tax or legal advice. Your wave and your obligations come from ZATCA, not from us.
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