Kazakhstan Advances E-Invoicing and E-Reporting Mandate: Key Details for 2026 Implementation
Kazakhstan is preparing to overhaul its electronic invoicing and reporting framework with a draft law published on October 10, 2025, introducing sweeping changes to the Electronic Invoice System (EIS). If enacted, the new rules will take effect on January 1, 2026, marking a significant step in the country’s digital tax transformation. [kpmg.com]
Scope of Transactions
The e-invoicing and e-reporting mandate applies broadly to both domestic and cross-border transactions. It includes:
- B2B and B2C sales of goods and services.
- Services provided by nonresidents, where Kazakhstani buyers pay VAT on behalf of the supplier.
- Passenger transportation, freight forwarding, commission-based services, legal assistance, medical services, and sales of medicines and medical devices.
- Transactions involving end consumers, micro-entrepreneurs, and individuals, especially when performed by non-VAT taxpayers. [kpmg.com]
Taxable Persons in Scope
The obligation to issue e-invoices extends beyond traditional VAT taxpayers. It includes:
- All VAT-registered entities.
- Non-VAT taxpayers operating in specific sectors such as logistics, healthcare, law, and commission-based sales.
- Taxpayers under the simplified declaration regime.
- Foreign suppliers of digital products must register for VAT but are not required to issue VAT invoices. [kpmg.com]
Data Requirements and Format
E-invoices must contain:
- Buyer and seller identification.
- Detailed transaction data.
- VAT amounts.
- Personal data for transportation services.
The format is governed by the centralized EIS platform. While no specific XML or UBL format is mandated, biometric identification may be required for signing invoices flagged by risk indicators. [kpmg.com]
E-Invoices can only be issued if VAT is paid beforehand
Kazakhstan’s proposed amendments to its e-invoicing framework explicitly require that VAT must be paid before an e-invoice can be issued in certain cases.
According to the draft law published on October 10, 2025, and expected to take effect on January 1, 2026, the following rule applies:
- For services or works purchased from nonresidents, the Kazakhstani buyer must issue an e-invoice within five calendar days after paying VAT on behalf of the nonresident. This means the e-invoice is contingent on the prior payment of VAT, including cases of offset under Articles 122 and 123 of the Tax Code. [kpmg.com]
This requirement ensures that the tax authorities receive confirmation of VAT payment before the transaction is formally documented in the Electronic Invoice System (EIS). It reflects Kazakhstan’s broader effort to tighten compliance and traceability in cross-border transactions.
You can read the full KPMG TaxNewsFlash article here. [kpmg.com]
Submission Deadlines
Timely issuance is critical:
- E-invoices must be issued no earlier than the transaction date and no later than 15 calendar days after.
- For monthly invoicing, the deadline is the 20th of the following month.
- In emergencies, paper invoices must be entered into EIS within 30 calendar days after the emergency ends.
- For services from nonresidents, the buyer must issue an e-invoice within 5 calendar days of VAT payment. [kpmg.com]
Compliance and Penalties
The system introduces strict validation and confirmation rules:
- Corrected or additional invoices must be confirmed by VAT taxpayers to be valid.
- Non-VAT taxpayers may reject such invoices within 10 calendar days, after which they are deemed accepted.
- Revoked invoices follow the same confirmation and rejection protocol.
- Failure to issue timely invoices may result in denial of VAT credit and administrative penalties.
Kazakhstan’s tax authorities conduct regular audits based on risk indicators. Penalties for non-compliance include:
- 80% of understated tax liabilities.
- Up to 200% fines for concealed income.
- Interest penalties at 1.25 times the National Bank base rate per day of delay (base rate: 15.25% as of January 2024). [taxsummaries.pwc.com]
Pre-Filled VAT Returns
Kazakhstan supports pre-filled VAT returns. Taxpayers must mark VAT amounts as creditable in the EIS before submitting Form 300.00, the standard VAT return. [kpmg.com]
Additional Regulatory Context
- The current VAT rate is 12%, with 0% applied to exports and international transportation.
- E-invoices are mandatory for VAT payers and linked to the Virtual Warehouse (VW) module for traceability.
- Kazakhstan’s system supports cross-border data sharing with Eurasian Economic Union (EAEU) states.
- A pilot project for e-waybills is underway for import/export transactions.
- The so-called “Google Tax” applies to foreign digital service providers, who must register and remit VAT quarterly, though they are exempt from issuing invoices. [taxsummaries.pwc.com]
Sources
- KPMG TaxNewsFlash: Kazakhstan Proposed Amendments to E-Invoicing Rules [kpmg.com]
- PwC Kazakhstan Corporate Tax Administration Summary [taxsummaries.pwc.com]
- PwC Kazakhstan VAT and Other Taxes Overview [taxsummaries.pwc.com]
Official Resources
For further details and regulatory updates, the following official portals are recommended:
- State Revenue Committee of the Ministry of Finance
- Tax Applications and Forms
- Knowledge Base of the State Revenue Committee
- Ministry of Digital Development – Digitalisation Overview
- National Certification Authority of Kazakhstan
INDEPTH ANALYSIS
- Implementation Timeline:
- 2014: E-invoicing introduced on a voluntary basis for businesses (pilot phase). [digtechs.com]
- 2016: The national Electronic Invoicing Information System (EIIS) – also called “IS ESF” – became fully operational. [digtechs.com]
- Jan 2019: Mandatory e-invoicing for all VAT-registered taxpayers took effect. From this date, all VAT payers in Kazakhstan must issue invoices electronically via the EIIS for their sales of goods, works, or services. (Prior to this, electronic invoicing had been encouraged but not universally required.) [snitechnology.net] [snitechnology.net], [snitechnology.net]
- Apr 2018: Introduction of the “Virtual Warehouse” module (integrated with the e-invoicing system) to track movement of certain sensitive goods. This digital module, live since April 2018, ensures that sales of specific regulated goods are transparently recorded and traceable in real time. [roedl.com], [roedl.com]
- 2021–2024: Progressive refinements to e-invoicing rules. For example, new e-invoice statuses and data fields were added by a Ministry of Finance order effective 9 January 2024 to enhance the system’s functionality. By 2024, virtually all invoices in Kazakhstan’s economy were being issued and archived in the electronic system. [pwc.com], [pwc.com] [openenvoy.com], [openenvoy.com]
- Upcoming 2026 Change: Recent legislation (signed August 2025) further expands the scope from 1 January 2026. While e-invoicing is already compulsory for all registered VAT payers, the 2026 reform will require certain non–VAT-registered businesses to use e-invoices as well. This expansion targets specific sectors and situations previously outside the mandate (detailed below). In short, Kazakhstan is moving toward 100% electronic invoicing coverage for all businesses, with only minimal exceptions. [sovos.com], [sovos.com]
-
All VAT-registered entities: Since 2019, every VAT payer (whether a company or an individual entrepreneur) must issue VAT invoices electronically. This includes resident legal entities, non-resident companies operating via a branch in KZ, and individual entrepreneurs – all are obliged to use the EIIS platform for invoicing. In practice, any business that exceeds the VAT registration threshold (annual turnover above ~₸73.8 million, which is 20,000 Monthly Calculation Indexes) must register for VAT and hence falls under the e-invoice requirement. (VAT in Kazakhstan is 12%, and registration becomes compulsory once the threshold is crossed.) [snitechnology.net], [snitechnology.net] [snitechnology.net] [asistent.kz], [asistent.kz]
-
Non-VAT taxpayers (special cases): Even businesses not registered for VAT can be in-scope in certain scenarios. Over time, Kazakhstan’s Tax Code (see Article 412) identified categories of non-VAT taxpayers who must issue e-invoices for specific transactions. For example: [asistent.kz], [asistent.kz]
- Commission agents and freight forwarders who are not VAT payers are required to issue electronic invoices for their services. (Tax code Articles 415–416 mandate how commissionaires and freight operators must invoice on behalf of non-VAT principals.) [sovos.com], [asistent.kz]
- Sellers of imported goods: Any taxpayer (even if not VAT-registered) selling imported products must issue an e-invoice for those sales. This ties into customs controls – the electronic invoice ensures import VAT and obligations are properly accounted. [sovos.com], [asistent.kz]
- Businesses using the “Virtual Warehouse” system: If a non-VAT-registered business deals in goods that are tracked in the Virtual Warehouse module (typically excisable or otherwise controlled goods), they must issue e-invoices for those goods’ sale. (The law was updated in 2024 to expand the list of such goods, including certain fuel and chemical products.) [sovos.com], [asistent.kz] [asistent.kz]
- Large transactions by non-VAT persons: Since 2021, any non-VAT-registered business or individual making a high-value sale (exceeding 1,000 MCI, i.e. approx ₸3.69 million in 2024) via a civil contract must issue an electronic invoice for that transaction. This rule pulls larger enterprises (or single big deals) into the e-invoice system even if they’re normally outside VAT. (Notably, small businesses on simplified regimes are exempted when selling to certain buyers like patent-based entrepreneurs.) [asistent.kz], [asistent.kz] [asistent.kz]
- Other covered persons: The law also covers customs warehouse operators, temporary storage owners, and Authorized Economic Operators, who must e-invoice relevant services. International transport services require e-invoices as well (even for non-VAT carriers). And as of 2023, even taxpayers using the special retail tax regime must issue e-invoices if a business customer requests it (so the buyer can claim a deduction). [sovos.com], [asistent.kz] [asistent.kz], [asistent.kz]
In summary, virtually all businesses—VAT payers by default, and non-VAT businesses in most commercial contexts—are either already issuing e-invoices or will be required to imminently. A law adopted in 2025 explicitly mandates from 1 January 2026 that many previously exempt categories of non-VAT taxpayers must adopt e-invoicing. These include commission/forwarding agents, companies under simplified regimes, sellers of medicine and medical devices, law firms, state material reserve operators, among others. The only notable exemptions will be private individuals selling personal (non-business) property and certain small transactions handled entirely via cash registers or bank cards (see Exceptions below). [sovos.com], [sovos.com] [kpmg.com], [kpmg.com] -
Exceptions (limited): E-invoicing isn’t required in a few specific cases, generally where another document suffices or electronic reporting isn’t practical. For instance, retail sales to consumers where a fiscal cash register receipt is issued (with the buyer’s ID number if they request it) do not require a separate e-invoice. Likewise, if an individual pays utilities or telecom bills through banks/post offices, or buys train/air tickets, those transactions don’t need e-invoices. These carve-outs aim to avoid double-documentation for routine consumer purchases. Also, if the online system is down or no internet is available, businesses can issue paper invoices but must later register them in the EIIS within 15–30 days (the law gives 30 days after any officially declared technical outage or emergency to upload the invoices). Aside from such cases, any required invoice that is not electronic is considered non-compliance. [kpmg.com], [kpmg.com] [kpmg.com]
- Seller and buyer details: Tax identification numbers (BIN/IIN), names, addresses. (Note: an Order of 26 Dec 2023 introduced a requirement to include the foreign buyer’s ID code when issuing an invoice to a non-Eurasian Economic Union customer).) [pwc.com]
- Invoice particulars: Invoice date and number (the EIIS assigns a unique registration number upon acceptance), reference to any related contract or purchase order if applicable (e.g. a contract record number is now required for export invoices). [basware.com] [pwc.com]
- Line item details: Description of goods or services, quantities and units of measure, unit price, and line amount. Kazakhstan adheres to standardized unit codes for measure – the e-invoice form was recently updated to include separate fields for the unit of measurement code and quantity in that unit, to facilitate product traceability for certain goods. [pwc.com]
- Tax breakdown: The VAT amount calculated (at 12%), and any excise or other taxes if applicable. If an item is VAT exempt or zero-rated, that status is indicated.
- Digital signature: Every e-invoice must be electronically signed by the issuer’s authorized person using a digital certificate from the National Certification Center of KZ. The digital signature ensures authenticity and integrity of the invoice. (Businesses obtain these certificates and register with the EIIS before they can issue invoices.) [basware.com] [openenvoy.com], [openenvoy.com] [voxelgroup.net]
- Linked documents: The platform can link invoices with electronic waybills (e-SNT) for goods movement. Notably, new invoice status codes were added for cases where an invoice is canceled due to a linked e-waybill being rejected or revoked. This integration of invoices with shipping documents (via the “Virtual Warehouse” system) helps tax authorities monitor the supply chain. [pwc.com] [roedl.com]
- Failure to issue an e-invoice when required (i.e. not issuing any invoice, or issuing only paper, outside the allowed exceptions) is an offense.
- Late issuance (issuing the e-invoice after the 15-day legal window) is also an offense, though treated slightly more leniently than not issuing at all.
- For failure to issue required e-invoices (second offense in a year): a fine ranging from 40 to 150 MCI (≈ ₸147,000 to ₸554,000, approximately US$300–$1,100) can be imposed, with lower fines for small businesses and higher for larger entities. [asistent.kz]
- For issuing e-invoices late (beyond the allowed timeframe, second offense): a fine from 20 up to 100 MCI (≈ ₸74,000 to ₸369,000) may apply, again scaled by business size/category. [asistent.kz]
- Tax Code of Kazakhstan (2017, as amended), Art. 412-413 – Mandate for electronic invoices. [asistent.kz], [asistent.kz]
- KPMG Kazakhstan Tax NewsFlash – “Proposed amendments to e-invoicing rules” (Oct 2025). [kpmg.com], [kpmg.com]
- Sovos Tax Update – “E-Invoicing Mandatory for all VAT Payers and extended to Non-VAT Payers” (Aug 2025). [sovos.com], [sovos.com]
- Ministry of Finance Order No. 1321 (26 Dec 2023) – Updates to e-invoice issuance rules. [pwc.com], [pwc.com]
- State Revenue Committee (MinFin) – Electronic Invoices (EIIS) information page. [voxelgroup.net]
- Rödl & Partner – “E-invoicing and electronic document exchange in Kazakhstan” (May 2024). [roedl.com], [roedl.com]
- OpenEnvoy – “Kazakhstan’s e-invoicing regulations: B2G and B2B compliance” (2023). [openenvoy.com], [openenvoy.com]
- SNI Technology – “Kazakhstan e-Invoicing” (2021/2022). [snitechnology.net], [snitechnology.net]
- Asistent.kz (Kazakhstan tax portal) – Explanation of e-invoice obligations and penalties (May 2024). [asistent.kz], [asistent.kz]
- KGD.gov.kz – “Elektronnye scheta-faktury” official site (accessed 2025). [voxelgroup.net]
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
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