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Briefing document & Podcast: E-Invoicing and E-Reporting in Burkina Faso

SUMMARY

1. Executive Summary:

Burkina Faso has implemented a mandatory certified electronic invoicing system (“Facture Électronique Certifiée,” FEC) to modernize VAT administration and combat fraud. The legal basis for this mandate was introduced in the 2025 Finance Law and further detailed by a Ministerial Order in late 2025. The mandate requires large and medium VAT-registered businesses (“régime normal”) to issue all invoices electronically through a tax-certified system, transmitting invoice data to the tax authorities in real time. The system officially launched on January 6, 2026, with mandatory compliance starting July 1, 2026. Non-compliance carries significant penalties.

2. Background and Rationale:

The e-invoicing mandate replaces the previous “facture normalisée” paper invoice system, which had limited success in combating fraud. The goal is to improve VAT compliance and transparency through real-time data capture of all relevant transactions. The system is based on a “continuous transaction control (CTC) model” where invoices are effectively reported to the tax authority at the time of issuance.

3. Scope of Mandate:

  • Taxpayers: Initially, the mandate applies to VAT-registered businesses classified under the Large Taxpayers and Medium Taxpayers offices, specifically those under the “régime normal” with annual turnover of ≥ 50 million CFA francs. Smaller businesses are not yet obligated.
  • Transactions: The mandate covers all B2B and B2C sales of goods or services within Burkina Faso by in-scope taxpayers, including export transactions. Imports are excluded.
  • Geographic Scope: The requirement currently focuses on domestic businesses. Foreign or non-established entities without a Burkina Faso tax registration are not directly subject to the rules, unless they operate in Burkina Faso through a local VAT registration.

4. Timeline and Implementation:

  • 2025: Transitional period for system implementation and taxpayer preparation.
  • January 6, 2026: Official launch of the FEC system.
  • Early 2026: Taxpayer outreach, software certification, and onboarding.
  • July 1, 2026: Mandatory compliance date for in-scope taxpayers. A grace period existed up to this date allowing the use of traditional paper invoices. After this date, “electronic invoicing becomes obligatory, and paper invoices (unless system downtime contingencies apply) are no longer accepted as valid for those taxpayers.”
  • Future phases may extend the obligation to smaller taxpayers, but no dates have been announced.

5. Technical Setup and Invoice Format:

  • Clearance Model: Burkina Faso uses a clearance model with certified billing devices or software.
  • Two Compliance Options:Large/IT-equipped companies: Use existing billing software integrated with a hardware module (“Module de Contrôle de Facturation,” MCF) provided by the tax authority.
  • Businesses without computerized invoicing: Use a dedicated all-in-one electronic cash register (“Unité de Facturation,” UF).
  • Certified System: All invoices must be generated through an approved “Système Électronique Certifié de Facturation” (SECeF).
  • Invoice Format: The law doesn’t prescribe a specific electronic data format (like UBL or XML). Invoices (paper with QR code or electronic PDF) must include an embedded unique code and QR code for verification.
  • Data Transmission: Invoice data is automatically transmitted to the tax authority’s server via the cellular network (GSM mobile internet).

6. Required Invoice Data Fields:

The content of each e-invoice mirrors traditional invoice requirements with added digital signatures:

  • Seller details: Full name or business name, address, and unique taxpayer ID (IFU).
  • Buyer details: Full name or business name and address (and taxpayer ID if applicable).
  • Invoice specifics: Date of issuance and sequential invoice number.
  • Transaction details: Description of goods/services, quantity, and scope of service.
  • Amounts: Unit price, total price for each item, taxable/non-taxable amounts, and export identification.
  • VAT breakdown: VAT rate and amount for each taxable item.
  • Totals: Total invoice amount, total VAT charged, and other taxes/fees (separately indicated).
  • Certified invoice identifiers: SECeF identification number, unique transaction code, and QR code. The QR code allows tax officers to verify the invoice’s registration and validity.

7. Data Transmission to Tax Authorities:

  • Real-time Transmission: “The e-invoicing framework is designed so that invoice data flows to the tax authority in real time, at the moment of transaction.”
  • Contingency Plans: The system allows for short grace periods for transmitting data that was not captured in real-time due to system downtime:
  • 48 hours to regularize invoices after a system malfunction.
  • 7 days from notification by authorities to issue missing invoices discovered during an audit.
  • The Dirección General de Impuestos (DGI) supports companies by providing technical support and training.

8. Penalties for Non-Compliance:

“Burkina Faso has enacted strict penalties to enforce e-invoicing compliance.” Penalties are outlined in Article 798-2 of the Tax Code and include:

  • Failure to issue e-invoices: Fine equal to 5 times the VAT due on the transaction (minimum 500,000 CFA francs) for the first offense, doubling to 10 times the VAT (minimum 1,000,000 CFA) for repeat offenses. Potential business closure and ban on foreign managers.
  • Tampering with the system: Similar fines apply.
  • Using uncertified software: Fine of 1,000,000 CFA (rising to 2,000,000 CFA for repeat cases).
  • Issuing fake e-invoices: Fine of 2,000,000 CFA per invoice, plus criminal charges for fraud.

9. Archiving Requirements and Retention Period:

  • Businesses must archive and retain certified e-invoices.
  • The retention period is generally 10 years, aligning with UEMOA regional practice.
  • “Invoices issued must include security elements that guarantee their integrity over time.”
  • Businesses must maintain backups to prevent data loss.

10. Availability of Pre-Filled VAT Returns:

  • “At present, Burkina Faso does not provide pre-filled VAT returns to taxpayers based on the e-invoicing data.”
  • Taxpayers must continue to file their periodic VAT declarations.
  • The e-invoicing system will be used by the tax authority to cross-verify VAT returns.

11. Sources:

  • 2025 Finance Law and Article 564 of the Tax Code
  • Ministerial Arrêté of December 2025
  • Public communications by the DGI and Ministry of Finance during the official launch in January 2026.
  • News articles and newsletters from sources like Ecofin Agency, Faso7, Sikafinance, and VATupdate.

12. Key Takeaways:

  • Burkina Faso is committed to enforcing e-invoicing compliance.
  • Businesses need to comply by July 1, 2026.
  • The penalties for non-compliance are significant.
  • Real-time data transmission is crucial for the system’s success.

INDEPTH ANALYSIS

E-Invoicing Mandate Introduction (Burkina Faso) – Burkina Faso has recently established a certified electronic invoicing system (“Facture Électronique Certifiée”, FEC) as a new requirement to modernize its VAT administration and combat fraud. The legal basis was introduced in the 2025 Finance Law (amending the General Tax Code) and further detailed by a Ministerial Order in late 2025. In essence, large and medium taxpayers must issue all their invoices electronically through a tax-certified system, with invoice data transmitted to the tax authorities in real time. The rollout is phased, with full mandatory use starting July 1, 2026 for in-scope businesses. Key aspects of the framework include: [financesao.com], [sikafinance.com] [fr.linkedin.com], [salesdatac…roller.com]

  • Scope of Mandate – Who and What is Covered: Initially, the mandate applies to VAT-registered businesses classified under the Large Taxpayers and Medium Taxpayers offices of the tax administration. In practice, these are established companies above the VAT registration threshold (annual turnover ≥ 50 million CFA francs) – essentially “régime normal” VAT taxpayers in Burkina Faso. Smaller businesses (those under simplified regimes or below the VAT threshold) are not yet obligated to use electronic invoicing, as the government is taking a progressive implementation approach. The mandate covers all B2B and B2C sales of goods or services within Burkina Faso by in-scope taxpayers, and even export transactions by these taxpayers are encompassed. In other words, for every transaction that an in-scope company carries out, a certified electronic invoice must be issued. (Imports themselves do not require an invoice from the importer, so they fall outside the invoicing mandate; import VAT continues to be handled by customs.) Notably, the requirement currently focuses on domestic businesses – foreign or non-established entities without a Burkina Faso tax registration are not directly subject to the e-invoicing rules. (If a non-established company does operate in Burkina Faso through a local VAT registration, it would need to comply just like a resident taxpayer.) [fr.linkedin.com], [fr.linkedin.com] [fr.linkedin.com], [sikafinance.com] [fr.linkedin.com] [salesdatac…roller.com]
  • Timeline & Implementation Phases: Burkina Faso’s Direction Générale des Impôts (DGI) launched the FEC system officially on January 6, 2026 after conducting pilot efforts and preparatory trainings through 2025. During 2025, although the law formally took effect (for large/medium taxpayers from January 1, 2025), the tax authorities treated 2025 as a transitional period to get systems in place. A dedicated agenda was set: early 2026 was devoted to taxpayer outreach, software certification, and onboarding of businesses onto the new platform. Mandatory compliance kicks in on July 1, 2026 – from that date, all in-scope taxpayers (the “régime normal” companies) must issue invoices exclusively in electronic certified form. This effectively provided a grace period up to mid-2026 for companies to adapt. During the grace period, businesses could continue using traditional paper invoices (the previously “normalised” invoices with security stickers) without penalties, until the e-invoicing system became fully operational. After July 1, 2026, no further general grace period is foreseen – electronic invoicing becomes obligatory, and paper invoices (unless system downtime contingencies apply) are no longer accepted as valid for those taxpayers. The rollout is progressive: at first it targets large and medium firms; the tax authority may extend the obligation to smaller taxpayers in later phases once the system stabilizes, though no dates for that have been announced yet. (In 2017, Burkina Faso had introduced “facture normalisée” paper invoices as a fraud-fighting measure; the 2025–2026 e-invoicing reform replaces that with a digital solution after the paper system’s limited success.) [financesao.com] [dgi.bf] [fr.linkedin.com], [fr.linkedin.com] [digitalmagazine.bf] [financesao.com], [sikafinance.com] [fr.linkedin.com] [sikafinance.com]
  • Transactions Subject to E-Invoicing vs. E-Reporting: The certified e-invoicing system in Burkina Faso follows a continuous transaction control (CTC) model – meaning each invoice is effectively reported to the tax authority at the time of issuance. All invoices for sales made by obligated taxpayers (whether business-to-business, business-to-government, or business-to-consumer, including export invoices) must be issued through an approved electronic system and thus are automatically “reported” to the tax administration in real-time. There is no separate periodic e-reporting regime for those transactions, since the invoicing process itself transmits the data continuously. (For transactions or taxpayers not yet covered by the e-invoice mandate, there is currently no new e-reporting requirement – they simply continue to use standard invoices and file VAT returns as before.) In summary, Burkina Faso’s approach is to require live e-invoices for in-scope transactions rather than a post-transaction reporting model. Each certified e-invoice’s details are sent to the central DGI database instantly via the invoicing system, providing tax authorities with up-to-date sales data. This real-time capture of invoice data fulfills the objective of “e-reporting” by centralizing transaction information without needing a separate report submission (unlike, for example, the French system where non-e-invoiced transactions must be reported within a set time). If the certified system is fully functional, data transmission is immediate upon invoice issuance. There is essentially no delay (“X days”) allowed for transmitting invoice data under normal operation – it’s designed to be instantaneous. However, the regulations do account for exceptional cases (e.g. technical issues): if a company’s certified invoicing device or system experiences a malfunction or connectivity outage, the company must still record the sale and then regularize the invoice within 48 hours of the system coming back online. Moreover, if during an audit the tax authority discovers sales that were not invoiced properly, the company has 7 days from notification to issue the missing certified invoices as a correction. These rules act as a limited “grace” for individual invoice reporting delays in case of system downtime, but apart from such scenarios, all invoices are expected to be transmitted in real-time. (Thus, e-reporting as a separate concept mainly comes into play only if/when some transactions remain outside the e-invoice scope; at present, Burkina Faso’s focus is on bringing all significant taxpayers’ transactions into the e-invoicing system rather than creating a parallel reporting mechanism.) [sikafinance.com], [sikafinance.com] [sikafinance.com] [salesdatac…roller.com]
  • Technical Setup and Invoice Format: Burkina Faso’s e-invoicing system uses a clearance model with certified billing devices or software. Taxpayers can comply in one of two ways, depending on their setup: Large or IT-equipped companies will use their existing billing software integrated with a small hardware module (Module de Contrôle de Facturation, MCF) provided by the tax authority – this module attaches to the company’s system and automatically certifies each invoice with the required security features and transmits the data. Businesses that do not use computerized invoicing will be given a dedicated all-in-one electronic cash register (Unité de Facturation, UF) which generates and prints certified invoices (serving as a combined POS and printer). Regardless of the method, each invoice must be generated through an approved “Système Électronique Certifié de Facturation” (SECeF) and include the mandated content and security elements. The law does not prescribe a specific electronic data format like UBL or XML for the invoice, but rather focuses on the output containing certain information and seals. In practice, the certified systems will produce invoices (which can be on paper with a QR code or in electronic PDF format, etc.) that carry an embedded unique code and QR code for verification. The tax authority’s server receives the invoice data automatically via the cellular network (the MCF/UF devices use GSM mobile internet to send data) and logs a timestamp and unique ID for each invoice. The DGI has made it clear that only invoices issued through these certified systems will be recognized as legally valid – any invoice not coming from a certified device will not count for tax purposes. This ensures that the format and integrity of e-invoices are standardized and tamper-proof. The content of each e-invoice is defined by law and essentially mirrors the requirements of a traditional invoice with added digital signatures. Required data fields include: [sikafinance.com], [sikafinance.com] [salesdatac…roller.com] [sikafinance.com] [fr.linkedin.com], [fr.linkedin.com]
    • Seller details: full name or business name, exact address, and the unique taxpayer ID (IFU) of the seller. [fr.linkedin.com]
    • Buyer details: full name or business name and address of the customer (and their taxpayer ID IFU if they are a taxable person). [fr.linkedin.com]
    • Invoice specifics: the date of issuance and a sequential invoice number (series number). [fr.linkedin.com]
    • Transaction details: a description of the goods delivered or services rendered, and the quantity (for goods) or scope of service. [fr.linkedin.com]
    • Amounts: the unit price and total price for each item or service line (distinguishing taxable amounts from any non-taxable or exempt amounts, with proper justification for any non-taxable items). Any exports should be identified as such, with values recorded (exports are zero-rated but still must appear on the invoice). [fr.linkedin.com]
    • VAT breakdown: the VAT rate applied to each taxable item and the corresponding VAT amount in currency. If multiple VAT rates apply to different items, each should be detailed. [fr.linkedin.com]
    • Totals: the total amount of the invoice including all taxes (grand total), as well as the total amount of VAT charged. If other taxes or fees apply, those amounts must be indicated separately as well. [fr.linkedin.com]
    • Certified invoice identifiers: the identification number of the certified invoicing system (SECeF) used to issue the invoice, and the unique transaction code generated by that system, plus a QR code printed on the invoice for verification. These latter elements are the digital security features that guarantee the invoice’s authenticity (the QR code or a code string allows tax officers or customers to verify via the tax authority database that the invoice is registered and valid). [fr.linkedin.com]
    All these details are automatically included when using the certified solutions. For example, once an invoice is generated on the system, it will print with the QR code and unique reference. According to the DGI’s definitions, a “facture électronique certifiée” is any invoice issued in any format (paper or electronic file) through a certified system and containing all the mandatory information and security elements required by law. Note that electronic signatures or similar may be inherent in the certified system’s process, but from the user perspective the key visible security is the unique codes/QR provided by the system. There is no requirement for businesses to use a specific international format (like EDIFACT or XML) to exchange invoices – using the approved software/hardware which is homologated by the tax authority is sufficient. Data is captured by the system and forwarded to the tax authority’s central database automatically. [salesdatac…roller.com]
  • Data Transmission to Tax Authorities: The e-invoicing framework is designed so that invoice data flows to the tax authority in real time, at the moment of transaction. The certified devices must be connected (via GSM mobile network or internet) to DGI’s servers. Each time an invoice is issued, the system transmits the invoice information instantaneously to the central platform managed by the tax authority. This continuous transmission allows the DGI to monitor sales virtually live, enabling them to cross-check VAT declarations and combat under-reporting. In practical terms, a business using an SECeF device will issue an invoice, and within moments the DGI has a record of that invoice (with all the details listed above). The timeline for sending data is essentially immediate, with the law requiring systematic and continuous issuance of e-invoices for each sale via the system. If the system is down (e.g., technical failure or no connectivity), the business is allowed to continue operations and later input the pending invoices once the system is restored – the rules mandate that any such “offline” invoices be regularized within 48 hours by issuing them through the system to ensure they reach the tax authority’s database promptly once connectivity is back. Similarly, if an audit or verification uncovers that a taxpayer failed to issue a certified invoice for a taxable sale (whether due to negligence or system issues), the taxpayer must issue the missing invoice through the system within 7 days of being notified by the authorities. These provisions effectively set short grace windows for transmitting data that was not captured in real time. Other than these exceptional cases, there is no general lag allowed between invoice issuance and transmission – it’s meant to be instantaneous. (To facilitate compliance, the DGI is also providing technical support, training, and has authorized distributors via the Chamber of Commerce to supply the certified devices to taxpayers, so that businesses can set up the systems correctly and maintain connectivity. Every in-scope business is required to ensure their device is active, maintained, and has network access at all times, including installing the device in a spot with good mobile signal and promptly reporting any device issues to authorized service providers.) In summary, the data gets to the authorities essentially in “T+0” real-time; if not, it must within 2 days (if a device fails) or 7 days (post-audit correction) under explicit rules. There is currently no separate “e-reporting” form or batch submission required besides the automatic transmission via the invoice system – the electronic invoices themselves are the reports. [salesdatac…roller.com] [sikafinance.com] [ecofinagency.com], [ecofinagency.com] [horonyafinance.com], [horonyafinance.com]
  • Penalties for Non-Compliance: Burkina Faso has enacted strict penalties to enforce e-invoicing compliance, as outlined in Article 798-2 of the Tax Code (added in the Finance Law 2025). Key sanctions include: Monetary fines tied to the undeclared VAT – if a taxpayer obliged to issue certified e-invoices sells goods or services without issuing a compliant e-invoice, they face a fine equal to 5 times the amount of VAT that would have been due on that transaction, with a minimum penalty of 500,000 CFA francs (approximately $800) per infraction. On a repeat offense, the fine doubles to 10 times the VAT (minimum 1,000,000 CFA), and the tax administration may also order a business closure for 10 days or more as an administrative sanction. These penalties are severe to deter any attempt to bypass the system. Moreover, if the offending business’s managers are of foreign nationality, the law even allows banning those individuals from residing in Burkina Faso in addition to the financial penalties. Aside from failure to issue invoices, other infractions are covered as well: tampering with or causing malfunctions in the certified invoicing system is likewise penalized – any person who intentionally disrupts the SECeF device to avoid proper invoicing can incur the same level of fines (5x/10x the VAT). Software providers are also held accountable: offering or using an uncertified billing software without getting it approved (homologated) by the tax authority can draw a fine of 1,000,000 CFA (around $1,600) per instance, rising to 2,000,000 CFA for repeat cases. Similarly, if a company builds its own in-house billing system, it must have it officially homologated; using a self-developed system without approval carries the same fines. Furthermore, issuing fake e-invoices or using someone else’s device credentials fraudulently is punishable by a fine of 2,000,000 CFA per invoice falsified, on top of any criminal charges for fraud. Notably, these fines are in addition to the recovery of any evaded VAT and any other general tax penalties – and they do not preclude potential criminal prosecution for tax evasion. In summary, non-compliance is met with heavy, potentially business-ending penalties, underlining the government’s commitment to making the e-invoicing system effective. There is no “light-touch” penalty phase indicated after July 2026 – the expectation is that companies will be ready, given the advance notice and support, and failing to issue the required e-invoice is treated as a serious offense. [fr.linkedin.com]
  • Archiving Requirements and Retention Period: The introduction of electronic invoicing does not eliminate the general obligation to archive and retain invoices for tax purposes. In fact, one of the objectives of the new system is to improve record-keeping. Businesses must ensure that their certified e-invoices are stored safely and remain accessible to both the taxpayer and the tax authority for the required retention period. Burkina Faso’s tax code and accounting regulations generally require keeping books and records (including invoices) for 10 years – this aligns with common practice in the West African Economic and Monetary Union (UEMOA) region. We can reasonably expect that electronic invoices should also be preserved for at least a decade. The Ministerial Order on e-invoicing emphasizes that invoices issued must include security elements that guarantee their integrity over time, implying that digitally signed invoices should be stored in a way that they cannot be altered. While specific new rules on e-invoice archiving formats have not been heavily detailed publicly, it is likely that taxpayers will either rely on the certified system’s internal memory/portal or export the e-invoices for long-term storage. The law already required paper invoices to be kept and produced on request, and this continues with electronic invoices – businesses should be able to reproduce a legible copy of any invoice for the duration of the retention period. In short, invoices must be archived for at least the statutory period (likely 10 years) in a secure manner. The electronic format does not change the retention timeline; it only changes the medium of storage. Taxpayers are also expected to safeguard backup copies to prevent loss of data (just as they must prevent loss or destruction of paper records). The DGI’s system will have a record of all invoices as well, but the onus remains on the company to maintain its own archives. (Burkina Faso already facilitates electronic filing of tax returns via its eSINTAX portal, reflecting a broader move to digitalization; the hope is that e-invoicing data will simplify auditing and record-keeping for both sides.) [edicomgroup.com] [e-docucent….uemoa.int] [salesdatac…roller.com]
  • Availability of Pre-Filled VAT Returns: At present, Burkina Faso does not provide pre-filled VAT returns to taxpayers based on the e-invoicing data. Taxable persons must continue to file their periodic VAT declarations, stating sales and tax due, through the usual channels (e.g. via the eSINTAX online portal or paper filing). The e-invoicing system will, however, give the tax authority a complete dataset of sales, which can be used to cross-verify the VAT returns submitted. It’s conceivable that in the future, the DGI might leverage the real-time invoice data to pre-compute VAT liabilities or at least flag discrepancies, but as of the latest information, the implementation is focused on data collection and control, not on auto-filing returns for the taxpayer. Taxpayers should therefore not expect the tax authority to send them a pre-filled VAT return – they must compile their VAT figures (output tax, input tax credits, etc.) and file as before, ensuring consistency with the invoice data. The primary benefit of the e-invoicing data, for now, is to improve accuracy and compliance (for example, the DGI can detect if a taxpayer’s VAT return omits sales that have invoice records). In summary, no pre-populated VAT return system is in place yet in Burkina Faso’s e-invoicing framework, and businesses should continue to prepare and submit their VAT returns manually (though electronically via eSINTAX). Any future move toward pre-filled returns would likely require additional developments and possibly new legal provisions; currently the focus is on ensuring all invoices are reported and archived rather than changing the filing process for VAT. [edicomgroup.com]
Sources: This overview is based on the most recent available information from late-2025 and early-2026, including official Burkinabè regulatory texts and government statements, as well as analyses by tax news services. Key references include the 2025 Finance Law and Article 564 of the Tax Code as amended (which instituted the certified e-invoice requirement), the Ministerial Arrêté of December 2025 which sets out technical conditions for e-invoicing (e.g. system definitions, obligations, and deadlines), and public communications by the DGI and Ministry of Finance during the official launch in January 2026. Additionally, news articles and newsletters from sources like Ecofin Agency, Faso7, Sikafinance, and VATupdate have been used to confirm the timeline and objectives of the reform. These sources corroborate the enforcement date (July 2026) and the scope of the mandate, as well as the rationale behind it (increasing VAT compliance and transparency). For further details, readers may consult the Burkina Faso General Tax Code (especially articles on invoicing obligations and penalties) and the DGI’s official guidelines once published. Links to a few relevant documents and news releases are provided in the citations for reference. [fr.linkedin.com], [fr.linkedin.com] [salesdatac…roller.com], [salesdatac…roller.com] [financesao.com], [digitalmagazine.bf] [ecofinagency.com], [sikafinance.com] [fr.linkedin.com], [salesdatac…roller.com]

 


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