In 2026, as a general rule, an invoice is issued electronically in the E-Invoicing IS; a paper document is permitted only in cases established by the Tax Code and, where required, is subsequently entered into the system within 15 or 30 calendar days (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan). Similar rules are provided for VAT payers and non-payers, although different articles of the Code apply.
What Is the Electronic Invoicing System in Kazakhstan?
The Electronic Invoicing Information System (E-Invoicing IS) is a state information system in which electronic invoices are issued. The abbreviations “ESF” and “E-Invoice” are also commonly used, but the document itself is called an electronic invoice, while the system is called the E-Invoicing IS.
An electronic invoice is prepared in the system in the form and according to the procedure determined by the authorized body. The Tax Code establishes the categories of persons required to issue invoices: these include registered VAT payers as well as non-VAT payers in the cases provided for by Articles 208 and 209 of the Tax Code of the Republic of Kazakhstan. The form and issuance procedure are approved by the authorized body subject to the provisions of the Code (Article 207 of the Tax Code of the Republic of Kazakhstan).
From 2026, former Article 412 of the 2017 Tax Code may no longer be cited as the applicable provision governing the issuance of electronic invoices: in the new Tax Code, Article 412 regulates the calculation of individual income tax on an individual’s income subject to self-assessment. The requirements governing electronic and paper invoices for non-VAT payers are established by Article 209, while those for VAT payers are established by Article 492 of the Tax Code of the Republic of Kazakhstan.
Who Works in the E-Invoicing IS: Participants, Operator, and Authorized Persons
For tax accounting purposes, the taxpayer responsible for issuing the invoice remains the key party. Registered VAT payers issue it under the rules of Chapter 50 of the Tax Code of the Republic of Kazakhstan, while non-VAT payers do so under Articles 208 and 209 of the Tax Code of the Republic of Kazakhstan (Article 207 of the Tax Code of the Republic of Kazakhstan).
- The supplier prepares the invoice electronically or, where grounds provided for by the Code exist, on paper.
- The recipient receives a copy of the paper invoice if the document has lawfully been prepared on paper. Such an invoice is prepared in two copies, one of which is provided to the recipient (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
- A legal entity and its structural subdivision may be shown on an invoice subject to the legal entity’s decision. If a structural subdivision acts on behalf of the legal entity as the supplier or recipient, the subdivision’s details may be stated in the document (Article 209 of the Tax Code of the Republic of Kazakhstan).
- Employees of the organization perform actions in the E-Invoicing IS within the scope of the authority granted to them and their configured access rights.
In practice, an organization should specify who prepares and signs outgoing invoices, who reviews incoming documents, and who substitutes for the responsible employee during their absence. This helps ensure compliance with the issuance procedure and the deadlines for entering paper documents into the E-Invoicing IS.
Electronic Invoices and VAT: Why the Electronic Document Matters
For a VAT payer, electronic form is the general rule. An invoice may be prepared on paper if no public telecommunications network is available at the payer’s location, if the authorized body confirms that it is technically impossible to use the E-Invoicing IS, if invoice issuance in the system has been suspended, or during an emergency or a state of emergency (Article 492 of the Tax Code of the Republic of Kazakhstan).
The same general approach applies to non-VAT payers: an invoice is issued electronically in the E-Invoicing IS, except in the expressly listed cases where a paper document is permitted. Values and amounts in such an invoice are stated in the national currency of the Republic of Kazakhstan (Article 209 of the Tax Code of the Republic of Kazakhstan).
If a paper invoice was prepared due to confirmed technical errors, it must be entered into the E-Invoicing IS within 15 calendar days from the date on which the errors were resolved. If invoice issuance in the system was suspended, the deadline is 15 calendar days from the date on which the suspension was lifted. A document prepared during an emergency or a state of emergency must be entered into the system within 30 calendar days after the end of the relevant period (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
The accountant should reconcile the invoice details with the transaction data: the parties to the transaction, the date, item description, value, and VAT amounts. If the document was initially prepared on paper, the grounds for using that form and compliance with the prescribed deadline for entering it into the E-Invoicing IS should be reviewed separately.
The “Virtual Warehouse” Module and Goods on the List
Working with goods in the E-Invoicing IS may involve using the “Virtual Warehouse” module. When preparing documents, the accountant should select goods according to their actual characteristics and accounting data so that the transaction details do not differ from the description and quantity of the goods.
Articles 207, 209, and 492 of the Tax Code of the Republic of Kazakhstan establish the obligation to issue invoices and the form in which they must be issued, but they do not contain a list of goods for the “Virtual Warehouse” module. Therefore, the company’s accounting policy and operating instructions should not reproduce such a list without reference to a current regulatory legal act of the authorized body.
When recording a sale, reconcile the name, unit of measurement, quantity, and other product details with the source documents and accounting system data. This reconciliation reduces the risk of discrepancies when preparing the electronic invoice and subsequently reviewing the transaction.
Storing Electronic Invoices Under the Current Rules
The Tax Code classifies invoices as accounting documentation. The taxpayer must retain documents related to taxable items until the limitation period for the relevant tax or payment expires, but for no less than five years. The period begins with the tax period following the period in which the tax liability was calculated on the basis of the document (Article 206 of the Tax Code of the Republic of Kazakhstan).
- accounting documentation may be prepared on paper and/or electronically in Kazakh and/or Russian;
- if documents are available in a foreign language, the tax authority may require a translation into Kazakh or Russian;
- during a tax audit, electronic documentation must, as a general rule, be provided on paper at the request of the tax authority;
- an exception applies to invoices, accounting documentation, and source documents registered in the E-Invoicing IS: the requirement to provide paper copies does not apply to them (Article 206 of the Tax Code of the Republic of Kazakhstan).
Accordingly, the accountant must ensure that documentation related to taxation is retained for no less than five years or, where a longer limitation period applies, until that period expires. The presence of a document in the E-Invoicing IS is taken into account when documentation is provided during a tax audit, but the organization must still maintain complete tax and accounting records of its own.
What the Accountant Should Do: A Practical Checklist
- Determine the grounds for issuance. Check whether the supplier is a VAT payer or non-payer and apply the relevant requirements of Article 209 or 492 of the Tax Code of the Republic of Kazakhstan.
- Use the electronic form. Prepare a paper invoice only in cases expressly provided for by the Tax Code.
- Allocate authority. Appoint persons responsible for issuing, signing, receiving, and reviewing invoices, and establish a substitution procedure.
- Monitor the entry of paper documents. A deadline of 15 calendar days applies to technical errors and the lifting of a suspension, while a deadline of 30 calendar days applies after the end of an emergency or a state of emergency (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
- Reconcile product data. Compare the details in the electronic invoice, source documents, accounting system, and product modules used.
- Arrange document retention. Retain accounting documentation until the applicable limitation period expires, but for no less than five years (Article 206 of the Tax Code of the Republic of Kazakhstan).
- Take special deadlines into account. For example, when goods are exported to another EAEU member state, the invoice must be issued no later than 20 calendar days after the date of the sales turnover (Article 527 of the Tax Code of the Republic of Kazakhstan).
Frequently Asked Questions
What is the Electronic Invoicing Information System? — It is a state information system in which electronic invoices are issued. Electronic form is the general rule both for VAT payers and for non-VAT payers that are required to issue invoices (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
Are the E-Invoice and the E-Invoicing IS different systems? — No. E-Invoice is used as a shortened English term, while the Tax Code uses the name “Electronic Invoicing Information System.”
When is a paper invoice permitted? — When no public telecommunications network is available at the taxpayer’s location, in the event of confirmed technical errors in the E-Invoicing IS, when invoice issuance in the system has been suspended, or during an emergency or a state of emergency (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
Does a paper invoice need to be transferred to the E-Invoicing IS? — In the event of technical errors, the document must be entered into the system within 15 calendar days after they are resolved; when a suspension is lifted, within 15 calendar days after it is lifted; and after an emergency or a state of emergency, within 30 calendar days after the end of the relevant period (Articles 209, 492 of the Tax Code of the Republic of Kazakhstan).
Can a structural subdivision be stated on an invoice? — Yes. If, by decision of the legal entity, the subdivision acts on its behalf as the supplier or recipient, the subdivision’s details may be stated (Article 209 of the Tax Code of the Republic of Kazakhstan).
How long should electronic invoices and related accounting documentation be retained? — Until the limitation period established for the relevant tax or payment expires, but for no less than five years. The period begins with the tax period following the period in which the liability was calculated on the basis of that document (Article 206 of the Tax Code of the Republic of Kazakhstan).