Briefing Document & Podcast: E-Invoicing and E-Reporting in Gambia

1. Scope of the Mandate

2. Taxable Persons in Scope

3. Implementation Timeline

• July 2025: E-invoicing platform inaugurated (system available; draft regulations under consultation). [edicomgroup.com], [standard.gm]
• Late 2025: Pilot/voluntary usage by early adopters; 2026 Budget Speech proposes mandate – awaiting law. [vatcalc.com], [vatupdate.com]
• 2026: Parliament expected to approve the e-invoicing mandate. Detailed rules (formats, dates, etc.) and technical guidelines to be issued by GRA thereafter. Phased mandatory rollout likely begins (large taxpayers possibly by end of 2026). [vatupdate.com] [comarch.com]
• 2027 and beyond: Expansion of mandate to remaining taxpayers (medium, then small) over one or more phases until all VAT-registered businesses are included. Grace periods and onboarding support to continue during these phases.
• Grace/Transition: Initial months of each phase will focus on education and compliance support rather than penalties, per officials’ statements. [voicegambia.com]

4. Technical & Functional Requirements

5. Transmission & Workflow

• Via a Web Portal/User Interface: GRA will provide an online portal or application where businesses can log in and input invoice details (or upload invoice data). This is useful for small businesses or those with low invoice volume. At the launch event, it was noted that the system is intended to simplify invoicing for users, implying a user-friendly interface will be available. A business can manually create an invoice on this portal; the system will automatically send the data to GRA’s servers, validate it, and store it. The user can then download or print the invoice with any official validation markings. [standard.gm]
• Via API/Integration: Larger businesses or those using accounting software will likely integrate their systems via APIs to the GRA platform. The goal is to allow invoices generated from a company’s ERP or point-of-sale system to be transmitted electronically to GRA in the background. The agreement with the tech provider and mention of reducing manual processes suggests that an integration layer is part of the design. So accredited software or in-house systems can call GRA’s e-invoice API to submit invoice data and receive responses (approval, errors, etc.). This mode would enable high-volume taxpayers to comply without re-entering data on a portal. [standard.gm]

1. Invoice Creation: The supplier generates an invoice (either by filling out the form on GRA’s e-invoice portal or via their own software). This includes all line items, taxes, etc., as usual.
2. Transmission to GRA: The invoice data is transmitted to the GRA e-invoicing platform the moment it’s created. If using the portal, saving the invoice will do this automatically. If using an API, the company’s software will send a request to GRA’s server with the invoice details.
3. Validation & Approval: The GRA system checks the invoice. If everything is in order, it registers the invoice and likely returns a response (which may include a unique Invoice Reference Number, a clearance signature or QR code, and a timestamp of approval). This all happens within seconds. If there’s an error (missing field, arithmetic issue, etc.), the system will reject the submission and send back an error message so the taxpayer can correct it before re-submitting.
4. Invoice Issuance to Buyer: Once approved by GRA, the supplier can deliver the invoice to the buyer. This might be done by printing the GRA-approved invoice or emailing a PDF that includes proof of clearance. In many systems, the buyer’s version of the invoice contains a barcode or code that the buyer (and auditors) can use to verify the invoice in the tax authority’s database. Gambia’s system will likely implement something similar, given the emphasis on verifiability. [standard.gm]
5. Real-Time Recording: Simultaneously, GRA now has the invoice logged against the supplier’s tax profile (and possibly noted for the buyer’s profile if the buyer is also a taxpayer). The sale is instantly reflected in GRA’s records.
6. Storage & Use of Data: The seller must keep their copy (electronically archived), and the transaction will be used by GRA for compliance monitoring (e.g. cross-checking with VAT returns).

6. Self-Billing

7. Triangulation & Special Scenarios

• Informal Sector Sales: There is a large informal economy in Gambia. The mandate is aimed at formalizing that (bringing more businesses into compliance). However, truly informal (unregistered) operators won’t be on the system by definition. For small cash sales by registered businesses (like a corner shop that is big enough to be VAT-registered), each sale ideally should be captured. If they use a cash register, it should interface with the e-invoice system or issue e-receipts. GRA might consider simplified e-receipts for B2C, but they haven’t announced a separate regime. They’ve implied even those will be in real-time. [edicomgroup.com]
• Tourism sector (hotels, travel agents): Tourism services to foreign visitors might be zero-rated as exports of service (depending on law). Those invoices would be e-invoices showing 0%. No special scheme like EU’s travel agent margin scheme exists in Gambia, so normal invoicing applies.
• Agriculture and small traders: Many are below thresholds or exempt, but those who are registered (e.g., large agribusiness) must comply. The system may need offline mode in rural areas (as noted earlier). [igrowventure.com]
• Government transactions (B2G): Government agencies as customers likely will insist on suppliers providing e-invoices (especially once mandatory). Gambia already had to implement e-invoicing for public procurement in line with broader digital reforms (though not explicitly stated, B2G is included). Government entities will probably be given access to download invoices issued to them from the platform.

8. Archiving & Retention

• Maintain a secure backup of all e-invoices (for example, download monthly archives from the portal).
• Ensure that backup is stored for at least 6 years, and protected from alteration.
• Test periodically that older invoices can still be opened and read (guard against software obsolescence).
• Possibly store duplicate archives in two formats (XML and human-readable PDF) to be safe.
• Control access to archives so they aren’t accidentally deleted.

9. Penalties & Enforcement

• Monetary fines for each infraction or per period of infraction (e.g., per invoice not issued or per day invoices are unreported).
• Percentage-based penalties on tax underpaid due to non-reporting or misreporting (commonly 10% to 100% of the tax, depending on gravity; current law uses 5% per month up to 25% for late payment, but intentional evasion can lead to higher). [pwc.co.za]
• Interest on any VAT that was not timely declared due to missing invoices – at Central Bank rate + 5% as per existing rules for late payment. [pwc.co.za]
• In serious cases, legal prosecution: The GRA Act and VAT Act likely have offenses for tax evasion which can include fines and imprisonment. Issuing fake invoices or failing to issue invoices to evade tax would fall under that.
• Administrative sanctions: GRA could publish the names of non-compliant taxpayers (naming and shaming), or recommend withdrawal of tax clearance certificates, etc., which might affect the business’s ability to get government contracts or operate freely.

• Financial penalties for failing to issue e-invoices or delaying their issuance (based on existing penalty rates for VAT offenses). [pwc.co.za]
• Penalties for incorrect or falsified data, up to treating it as fraud if intentional.
• Penalties for not maintaining e-invoice records, which fall under failure to keep records (a fine or other sanction could apply).
• All backed by legal provisions in the new regulation and existing tax law (once available, references like specific articles will be provided by GRA – e.g., “Article X of Electronic Invoicing Regulations 2025 imposes a fine of D___ for each invoice not reported”).
• Official guidance will include references to these penalties, and GRA is expected to publish these on their portal or Gazette alongside the mandate’s text. [vatupdate.com]

10. Pre-Filled VAT Returns

• Total sales amount and total VAT by tax rate (standard 15%, zero, exempt) from the e-invoices submitted by the taxpayer.
• Possibly total purchase/input VAT from e-invoices submitted by suppliers (this requires cross-matching invoices – seeing what invoices were issued to the taxpayer, which GRA can do since it has all B2B invoices in the database).

• Total taxable sales amount in domestic market.
• VAT on those sales (output VAT).
• Total zero-rated sales (exports) amount.
• Total exempt sales amount (if any, though typically fully exempt businesses might not file VAT at all, but partial exemption cases might have both).
• Possibly, total input VAT from domestic purchase invoices (where suppliers have e-invoiced you).

• Input VAT on imports of goods (GRA would not know unless customs data is integrated).
• VAT on imported services (reverse charge) which wouldn’t be in e-invoice data.
• Any adjustments, credit notes issued late in the period, etc., if not already captured.
• If any invoices weren’t recorded in time (e.g., an invoice issued right at month’s end but only cleared just after cutoff), the taxpayer might have to add it if GRA’s pre-fill missed it.

• Do pre-filled VAT returns exist? No, not at this time. Gambia does not currently issue pre-populated VAT returns to taxpayers. Each taxpayer must prepare their own return based on their records. (No source explicitly says “no pre-filling” but the fact that electronic filing is not widely available indicates the process is still manual.) [pwc.co.za]
• Are they planned? Likely in the future, but not officially launched yet. The move to e-invoicing sets the stage for possible pre-filling. Government officials have implied a desire to streamline return filing using digital data, but there’s no official start date for pre-filled returns. Once e-invoicing is stable, GRA may introduce this as part of continued digital reforms. [standard.gm]
• Dependence on e-invoicing data: Yes, any future pre-filled returns would heavily rely on the e-invoicing (and other e-reporting) data. The system would draw on the invoices reported to populate sales figures, etc. Without the e-invoice data, pre-filling wouldn’t be possible. In fact, in 2026 as the system rolls out, GRA might internally start checking declared VAT against e-invoice totals to ensure consistency, even before doing formal pre-fills.
• Prefilled fields vs taxpayer input fields: When implemented, prefilled data would probably cover sales/output. Input VAT might be partially prefilled (for domestic purchases that have been e-invoiced), but the taxpayer might need to add import VAT or any purchases from non-electronic scenarios. Fields like adjustments, or any sector-specific details (if any) would be added by the taxpayer. If the system doesn’t capture some data (like perhaps certain exempt input proportions), those remain manual.

11. Impact on SMEs and Startups

• The GRA’s training and outreach: Officials have promised ongoing training, workshops and technical support to ensure even small businesses understand and can use the system. We saw stakeholder workshops in 2025 that included business representatives of various sizes. We expect continued engagement via chambers of commerce, tax seminars, etc., focusing on SMEs as their turn to onboard comes. [voicegambia.com] [standard.gm]
• Pilot first with large taxpayers: It’s been suggested to pilot with large VAT-registered businesses first, then allow SMEs a grace period of 2-3 years before mandating them. This recommendation, echoed by local commentators, is likely influencing GRA’s plan. So small businesses might not be forced on Day 1, but rather gradually brought in. During that additional time, they can see the system in action and even optionally join early if they wish (some might do so to reap benefits like easier record-keeping). [igrowventure.com]
• Regional phasing: There was even a suggestion to start in urban areas (Greater Banjul, West Coast) and later roll out upcountry, acknowledging connectivity and support infrastructure is stronger in cities. Not sure if GRA will literally phase by region, but it’s a consideration for equitable implementation. [igrowventure.com]
• SME-specific guidance: The GRA might produce simplified guides or even set up helpdesks to assist SMEs. Possibly, they could partner with business associations to ensure SMEs get the message and know how to comply.

• Technology acquisition: Businesses may need to get a computer, tablet, or smartphone if they don’t have one, plus a reliable internet connection, to use the e-invoicing portal. As noted in a local analysis, “digital systems may involve costs, such as buying a smartphone, paying for internet access”. For a small shop used to pen-and-paper, this is a new expense. However, the cost of a basic smartphone or data plan is coming down, and GRA may highlight that as a necessary business investment akin to buying a receipt book previously. [igrowventure.com]
• Software / ERP changes: Larger SMEs that use accounting software may need to update or configure it to integrate with the GRA API. This might involve IT consultant fees or new software modules. There could be certified point-of-sale software available for free or low-cost; if not, that’s a market opportunity that hopefully local tech firms will fill.
• Certified provider fees: Since GRA is offering a free platform, businesses are not required to use any paid intermediary. So unlike some countries where you must buy a certified invoicing machine or service, Gambia’s system itself is provided (development is funded centrally). This reduces direct cash outlays for compliance. SMEs can use the free government portal to issue invoices, avoiding the need for expensive hardware (like dedicated fiscal devices) – an important consideration the GRA likely took to heart following experiences in other African nations where businesses had to buy fiscal devices. [voicegambia.com]
• Training and time: There’s a learning curve. Business owners or their staff will spend time to learn the new system. Time is money – while learning, they might handle fewer customers, etc. There might be initial slowdowns in invoicing as they get used to it. Over time though, it likely saves them time on record-keeping (no more writing paper invoices and manually adding them up each month).
• Maintenance: If the SME uses its own device or software, they have to maintain it (ensure internet, manage updates if any, etc.). There’s the ongoing cost of data connectivity which in Gambia can be relatively high for unlimited plans, though basic usage might not consume huge data.

• The system being provided free.
• Possibly preferential treatment or incentives for early adopters: A local expert suggested offering incentives such as faster VAT refunds or access to contracts if companies comply early. For example, the government could prioritize businesses that e-invoice for certain opportunities or expedite their tax clearances. We don’t know if GRA will do this, but it’s an idea on the table. [igrowventure.com]
• Donor or fintech involvement: Sometimes international partners (World Bank, etc.) support digital inclusion for SMEs. It’s possible such programs could emerge to help SMEs acquire the needed tech (for instance, a grant or loan scheme to get equipment). No specific program announced, but given The Gambia’s digital ambitions, they might seek funding for SME digitization support.
• Education campaigns: The government has been encouraged to invest in national education campaigns and hands-on training especially for small business owners. This kind of support, while not monetary, can greatly reduce the cost of compliance by preventing trial-and-error or mistakes that could be costly. [igrowventure.com]

• Day-to-Day Operations: Initially, SMEs may find issuing e-invoices slower than writing a quick receipt, especially if internet is slow or if they aren’t tech-savvy. Over time, however, many routine tasks can be faster. For instance, calculating VAT is automated, which avoids errors. Summarizing sales at month’s end is just a report output, which saves labor. So, while there’s an adjustment period, in steady state the administrative burden could decrease for SMEs. A small trader can focus more on business and less on totaling up receipts for the tax return, since the system helps do that.
• Cash Flow Effects: One potential cash flow benefit is faster VAT refunds or less likelihood of missing input VAT credits. If purchase invoices from suppliers are all electronic, an SME can be confident that their input VAT claims match GRA’s data, hopefully leading to quicker refunds for those in net refund positions (like exporters). Moreover, if e-invoicing reduces under-reporting economy-wide, the government might increase revenue and possibly reduce VAT rates or offer incentives – but that’s speculative. On the flip side, SMEs who used to under-report sales to improve cash flow (essentially by evading some VAT) will no longer be able to without high risk. So those who survived by skimming tax will face an adjustment – they might need to improve cash flows by cutting costs or raising prices slightly to account for full tax compliance. However, it’s a fairer situation as all competitors have to comply, so no one should undercut by evading. Another cashflow consideration: by invoicing in real-time, SMEs might get paid faster by their business customers. If large buyers start requiring an e-invoice before payment, once it’s sent through the system, that might trigger quicker payment cycles (as everything is verifiable instantly). Indeed, the Standard news noted benefits such as “faster payment” as one outcome of the system, meaning SMEs could see improved payment timelines from clients because of the reliability or financing options tied to electronic invoices. [standard.gm]
• Detection of Errors: SMEs often make mistakes in tax filings. With e-invoicing, errors (like calculation mistakes) are minimized and if any discrepancy arises, it can be flagged early. This prevents cumulative errors that could lead to audits or penalties later. So in that sense, compliance becomes easier and less risky – a simplification benefit.
• Administrative Burden vs Simplification: There is a bit of both. The administrative burden initially increases (SMEs must learn new processes, possibly hire/bookkeep differently). But over the medium term, many burdens decrease: no need to print/store paper invoices (space and filing work saved), no need to manually prepare detailed sales ledgers for tax – the system does it. In essence, mundane tasks automate, freeing SME owners to focus on business. According to GRA, reducing paperwork is a goal. One potential residual burden is handling system downtime or occasional technical issues, which maybe they didn’t face with pen and paper. But GRA will strive to minimize downtime. [standard.gm]
• Need for Internet/Electricity: SMEs in areas with unstable electricity or internet may struggle. This was explicitly highlighted: “Many businesses…lack stable internet or electricity”. This could hamper rural or remote SMEs the most. Recognizing this, the strategy might be to improve connectivity (the government might increase infrastructure investment) and ensure the e-invoicing solution can work offline (with data syncing later). If offline capability is implemented, an SME could still make sales during outages and upload them later, which would mitigate lost time. Nonetheless, SMEs might incur new costs like a backup generator or UPS for powering a device, or have to get a data plan with better coverage – these are challenges that will need to be managed gradually. [igrowventure.com]

• Increased Digitalization Requirements: The mandate essentially forces SMEs to digitalize at least one part of their operations (invoicing). This can have spillover effects – once they get a computer for invoicing, they might start using it for inventory, payroll, etc., leading to broader business modernization. It’s a push towards digital transformation in the SME sector. Some small businesses that were very traditional will now use technology daily. This could improve efficiency and record-keeping overall. But for those resistant or slow to adapt, it’s a hurdle and they may need hand-holding.
• Potential Advantages for Early Adopters: SMEs or startups that embrace e-invoicing early could reap some advantages:
  • They’ll have better financial records which can open access to credit. For instance, a startup that can show banks a solid trail of electronic invoices and revenues might more easily obtain loans. Indeed, having reliable digital financial history is noted as a benefit: “businesses that issue digital invoices establish a reliable financial history, which can help them secure loans or attract investment”. [igrowventure.com]
  • They may integrate e-invoicing with their accounting, yielding real-time insight into cash flow and profitability, aiding decision-making.
  • Early compliance can also position them as trustworthy partners, possibly getting preference from larger companies or government contracts (since those counterparties will want compliant suppliers).
  • If GRA offered any incentives (like public recognition or small tax credits) for early adopters, those firms would benefit, though none such incentives are confirmed.
  • Startups by nature might adapt faster (often tech-savvy), so they could turn compliance into a virtue – even potentially developing innovative solutions or services around e-invoicing (like a startup might build an app to help micro-entrepreneurs comply).
• Interoperability Challenges: Many SMEs have very basic or no digital systems. Interoperability in this context means getting their existing way of doing things to work with the e-invoice system. Smaller businesses likely will use the GRA’s portal directly rather than integrate with existing software (since many don’t have any). So interoperability is not a huge issue if they adopt the portal as their primary method. For medium-sized firms with their own invoicing software, integration might require hired expertise. That’s a challenge: finding affordable IT help to connect to GRA’s API. The government might certify some simple ready-made software or partner with vendors to make plugins available cheaply. If not, those SMEs will have to do manual dual entry (generate invoice in their system and also input to GRA portal), which is time-consuming. Over time, the market will likely produce solutions (accounting software updates, etc.) to fill this need, but initially it’s a friction point.
  • Also, if an SME deals with foreign companies or uses an accounting system from abroad, adapting it to Gambia’s system could be technically complex – but since most SME operations are local, this is a limited case.
• Manual Process vs Automation: SMEs that previously did everything on paper might struggle at first with using computers for invoicing. Conversely, SMEs that had some digital workflow might find it easier. In the short run, some SMEs might find issuing an electronic invoice per sale burdensome if they have high volume of small transactions (like a grocery store). For such cases, one hopes GRA might integrate e-invoicing with point-of-sale systems (maybe via an SDK). Otherwise, an SME retailer might have to ring up sales on a cash register and also ensure an e-invoice is generated for each – requiring an integrated solution. If not integrated, it’s double work. This is recognized as a potential interoperability challenge for smaller systems or manual processes. [igrowventure.com]
  • The solution lies in affordable integrated POS systems for SMEs. Possibly, international development partners might subsidize some fiscal device or tablet with an app for small retailers. If not, there could be an initial slowdown or need to restructure how they operate at checkout.

• Pros: Once adapted, SMEs benefit from easier record-keeping, better access to finance (through transparent records), potentially faster payments and VAT refunds, and a fairer competitive environment (everyone pays their share). They also future-proof their operations in a digitizing economy. [igrowventure.com], [igrowventure.com]
• Cons/Challenges: Upfront training and equipment costs, need for internet/power, risk of technical hiccups, and a learning curve that could momentarily distract from business or require hiring skilled staff. [igrowventure.com], [igrowventure.com]
• Mitigations: Government phasing, workshops, possibly partnerships with telecoms to offer affordable data packages, etc. If well-executed, SMEs will gradually reap the benefits of digitization. If poorly executed (e.g., if rolled out too quickly without support), SMEs might struggle or even try to evade by dropping out of VAT system – which the government wants to avoid. That’s why so much emphasis is on making it inclusive and providing grace periods. [igrowventure.com], [standard.gm]

12. Official References

• Government and Tax Authority Publications:
  • The Gambia Revenue Authority (GRA) website and press releases provide official news. For example, GRA’s own news article “Conducts Due Diligence Visit to Côte d’Ivoire for E-Invoicing Implementation” outlines the preparatory steps and objectives of the system. GRA’s announcements around July 2025 (the launch and stakeholder workshop) were reported in local media, carrying official statements from the Commissioner General and Finance Minister. Once the Electronic Invoicing Regulations 2025 are finalized, they will likely be published in the government gazette or the GRA website. (Keep an eye on GRA’s “Media/News” section for the official regulation text and any guidelines; as of now only draft info is out.) [gra.gm] [standard.gm], [thepoint.gm]
  • The Ministry of Finance and Economic Affairs (MoFEA) released the 2026 Budget Speech (delivered Dec 5, 2025), which explicitly mentions the proposal for mandatory e-invoicing for VAT. This serves as an official policy reference signalling the government’s commitment. The Budget Speech is available on MoFEA’s site as a PDF, and it is an authoritative source because it’s the Minister’s address to the National Assembly, outlining the legislative changes. (See pages where digital tax reforms are discussed in that document.) [vatcalc.com] [sovos.com]
  • The Draft Electronic Invoicing Regulation 2025 itself was discussed at the stakeholder validation workshop. While the draft isn’t publicly posted online, its content was summarized by officials in media: e.g., it “applies to every taxpayer engaged in any form of business…except those exempted under income and VAT law” and establishes the centralized platform. When the final regulation is approved, it will be an official reference to cite chapter and verse for requirements and penalties. [standard.gm]
  • The GRA is expected to issue technical specifications and user guides on e-invoicing. These might be found on their website or provided directly to businesses. For instance, a “Taxpayer User Manual for E-Invoicing System” could be published. Checking GRA’s site or contacting them for such guides would yield official instructions on format, API, etc., once available.
• Legislative Texts:
  • The existing Income and Value Added Tax Act 2012 is an important reference for general VAT rules in Gambia. It covers invoicing obligations (e.g., requirement to issue VAT invoice and its contents) and record-keeping requirements (6-year retention). While it doesn’t mention e-invoicing (being older), it’s still the legal foundation that the new e-invoicing regulations will build on. [pwc.co.za]
  • Once passed, the Electronic Invoicing Regulations 2025 (or 2026, depending on when enacted) will become a primary legislative text. It will likely detail scope, procedures, and penalties. As soon as it’s gazetted, that document should be consulted for exact legal wording. The media references indicate what’s in it, but the final text will be definitive. [standard.gm]
  • If any amendments to the VAT Act are made (some countries amend the VAT law to mandate e-invoicing), the amending Act or clause in the Finance Bill 2025/2026 is an official reference. E.g., if the Finance Act 2026 has a section on e-invoicing, that would be cited.
• Government Portals:
  • GRA’s official portal (gra.gm) will be a key resource. It has sections like “Know Your Tax Obligations” and FAQs. As the e-invoice system goes live, the GRA may add an e-invoicing portal link or FAQ on their site, explaining how to use it and obligations. Monitoring their site for updates or dedicated pages on e-invoicing is advisable.
  • Ministry of Finance (mofea.gov.gm), aside from the budget speech, might post press releases or fact sheets on the digitalization of tax. Also, tender documents (like the Invitation to Bid for the e-invoicing system implementation) give insight into official project scope and aims, though not the rules for taxpayers. [mofea.gov.gm]
  • National Assembly records might later show the discussion or approval of the e-invoicing regulation if it requires parliamentary approval. Their Hansard or Acts could be referenced for context or legislative intent.
• Technical Specifications:
  • As part of rolling out the system, GRA/Avatar Tech might publish a technical integration guide (API documentation) for software providers. If made public, this is useful for IT departments. It might be available on request or through a developer portal. Not an obligation for all taxpayers to read, but an official spec for those integrating systems.
  • GRA could also provide data model documentation outlining the fields in the e-invoice schema (sometimes called a data dictionary). This might be referenced if one needs to confirm mandatory fields or code lists.
• Recent Big 4 / Law Firm Newsletters and Analysis:
  • VATupdate.com and Orbitax have summarized Gambia’s e-invoicing progress in early 2026. VATupdate’s piece “Gambia proposes mandatory e-invoicing in 2026 budget” concisely lists the key points of the proposal and sources to Orbitax and Vatcalc. While not official themselves, they often directly link to official sources (Orbitax linked to an official tax proposal, Vatcalc linked to MoFEA). Such newsletters are handy for staying up-to-date and often cite the government announcements. [vatupdate.com] [vatupdate.com], [vatupdate.com]
  • Vatcalc.com provided a detailed analysis referencing the Budget speech. This is a reliable secondary source because Vatcalc is maintained by VAT experts who compile info from official releases. They also link to the Finance Ministry site for verification. [vatcalc.com], [vatcalc.com] [vatcalc.com]
  • Deloitte, PwC, KPMG etc. – as of our knowledge cut-off, no dedicated article from these had surfaced publicly. However, PwC’s VAT in Africa – Gambia overview (2023) is a good primer for background law. After the mandate is enacted, Big4 firms are likely to issue Tax Alerts or Newsflash updates summarizing the e-invoicing requirements for their clients. Those will be useful references combining official info with practical commentary. It’s worth checking, for example, KPMG’s TaxNewsFlash or Deloitte’s tax newsletters repository for “Gambia e-invoicing” in 2025/2026. As a hypothetical, EY might cover it in a global tracker; indeed, EY has a global e-invoicing developments tracker that likely will include Gambia when mandated. [pwc.co.za]
  • Local consultancy articles: We saw an igrowventure.com article by Salifu Bah which, while not official, provides context and even recommendations in line with government thinking. It references the official announcements (Minister of Finance and GRA announced launch in June 2025). Law firms or consultancies in the region (like Tax firms in Senegal or Ghana who watch ECOWAS developments) might also have client notes referencing Gambia’s move – these can sometimes clarify the regulatory status and timeline. [igrowventure.com]
• Media (Newspapers/Broadcast) with official quotes:
  • Gambian newspapers such as The Standard, The Point, The Voice interviewed or quoted officials during launch events. These articles – e.g., “GRA, stakeholders validate digital e-invoicing regulations” or “GRA reassures taxpayers amid validity of e-invoicing” – contain direct quotes from the Commissioner General and Minister, which effectively serve as primary source statements on policy. They should be cited for specific points (like scope and intent) with attribution to the official. While not in a formal report, they are publicly accessible and authoritative as they relay what the leaders said on record. [standard.gm] [thepoint.gm]
  • Televised segments or YouTube (like StarTV’s report on e-invoicing launch) might include interviews with officials – these can be references if necessary, but the print articles suffice for most citation needs as they mirror those statements.
• International References:
  • For comparisons or context, references to how Ivory Coast or other countries implemented e-invoicing can be found in EDICOM’s blog or Comarch’s updates. Though not Gambian official sources, they sometimes incorporate statements from Gambian officials (EDICOM quotes GRA’s announcements for instance) and can validate certain facts like dates and partner involvement. They should be secondary to Gambian official references, but still useful (and publicly accessible). [edicomgroup.com] [comarch.com]
  • United Nations or IMF reports can also be pertinent. If, for example, the IMF did a country report mentioning GRA’s digital initiatives, that would be an authoritative external validation.
  • The question explicitly mentions providing links to Big 4/law firm newsletters – so including references such as the VATupdate summary or Vatcalc analysis with live links is expected. Those are publicly accessible. If Deloitte or KPMG issue something later, that would qualify as well.

• Legislation/Govt releases:
  • Income and VAT Act 2012, Section on record-keeping. [pwc.co.za]
  • Draft Electronic Invoicing Regulation 2025 (per Standard news report). [standard.gm]
  • 2026 Budget Speech – MoFEA, p. on e-invoicing (digital tax reform). [vatcalc.com]
  • GRA News: Press release July 8, 2025 – Launch of E-Invoicing Project (quoted in The Voice). [voicegambia.com]
  • GRA FAQ: Domestic Taxes FAQs – mentions invoice obligations (not specific yet, but GRA site has a FAQ section likely to be updated).
• Official websites/portals:
  • GRA official website (gra.gm) – news and any future e-invoicing portal.
  • MoFEA website (mofea.gov.gm) – Budget Speech PDF, procurement notice for e-invoice system. [sovos.com] [mofea.gov.gm]
  • Government Gazette (once reg is passed, a gazette link or PDF would be ideal, though might be behind paywall or print only).
• Newsletters/Analysis:
  • VATupdate.com – “Gambia proposes mandatory e-invoicing in 2026 budget”. [vatupdate.com]
  • Vatcalc.com – “Gambia 2026 budget e-invoicing proposal”. [vatcalc.com]
  • Comarch – “Gambia Proposes Mandatory E-Invoicing…”. [comarch.com]
  • EDICOM – “Discover How Mandatory e-Invoicing Works in Gambia”. [edicomgroup.com]
  • These contain links or references to the source (Orbitax, MoFEA, etc.) and summarize key details.

13. Summary

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Country Profiles on E-Invoicing, E-Reporting, E-Transport, SAF-T Mandates, and ViDA Initiatives
• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
• Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE