What has changed
The Ministry of Finance of the Republic of Kazakhstan has approved the list of goods for which electronic invoices must be issued through the “Virtual Warehouse” module of the electronic invoice information system. The new list was approved by Order No. 661 of the Acting Minister of Finance of the Republic of Kazakhstan dated 31 October 2025.
The document comes into effect from 1 January 2026. Therefore, when issuing electronic invoices after this date, parties involved in the circulation of goods should follow the new list and check whether the goods being sold are among the items for which the “Virtual Warehouse” module is mandatory.
The list is linked to the names of goods and the codes of the Commodity Nomenclature of Foreign Economic Activity of the Eurasian Economic Union. Therefore, relying solely on the common or abbreviated name of the goods is insufficient: the correctly determined EAEU CN FEA code must be taken into account during verification.
Who is affected by the new list
The changes are important for organisations and individual entrepreneurs that sell goods included in the approved list and issue electronic invoices for such transactions. In practice, the document affects accountants, tax accounting specialists, warehouse employees, procurement specialists, logistics specialists, and employees responsible for product directories in the accounting system.
Companies with a wide range of products, imported goods, or multiple warehouses will need to pay particular attention. The same goods may appear in internal documents under a commercial name, whereas the requirement to use the “Virtual Warehouse” is determined based on the item in the official list and the corresponding code.
The mere presence of a similar name does not replace classification verification. If the product code is determined incorrectly or does not match between the accounting data and source documents, this may complicate the issuance of electronic invoices and the recording of goods movements in the module.
What to check and do
Before processing further transactions, it is recommended to carry out the following checks in sequence:
- compare the company’s product range with the current list;
- check the EAEU CN FEA codes in product records, contracts, receipt documents, and sales documents;
- identify the goods for which electronic invoices must be issued through the “Virtual Warehouse”;
- reconcile the balances of such goods in the accounting system and the module;
- check that the units of measurement and product characteristics are correct;
- ensure that the responsible employees know the procedure for processing documents through the module;
- update internal instructions and controls performed before issuing electronic invoices.
If goods allow for different classification options, it is preferable to clarify the code before processing the sale. If there are discrepancies between the internal directory and the supplier’s documents, the correct data should first be established, and only then should the movement of the goods be recorded.
Transactions involving a change in how the quantity of goods is represented require separate control. For example, when converting tonnes into kilograms or packages into pieces, the “Disassembly” operation is used in the “Virtual Warehouse”. Its use must correspond to the actual movement and the adopted units of accounting.
Deadlines and practical controls
The new order is effective from 1 January 2026. Organisations should use the list approved by this order when checking transactions carried out after it comes into effect.
For ongoing control, it is advisable to appoint persons responsible for three areas: product classification, “Virtual Warehouse” balances, and the issuance of electronic invoices. Before submitting an invoice, the product code, inclusion of the item in the list, warehouse balances, and consistency of the unit of measurement should be checked. This procedure helps identify discrepancies before the document is registered.
Since the contents of the list may be amended by regulatory acts, the current version of the official document should be consulted for disputed or new product items, rather than a previously saved copy or an outdated directory.
Frequently asked questions
From what date does the new list apply? — Order No. 661 dated 31 October 2025 comes into effect from 1 January 2026.
How can it be determined whether an electronic invoice must be issued through the “Virtual Warehouse”? — The name and EAEU CN FEA code of the goods must be compared with the current official list.
Is it sufficient to check only the name of the goods? — No. The commercial name may differ from the wording in the list, so the EAEU CN FEA code must also be checked.
What should be done if packages are used in accounting while sales are recorded in pieces? — The units of accounting and the accuracy of the goods movement must be checked. To reduce the order of units of measurement, for example from packages to pieces, the “Disassembly” operation is used in the module.
Where should the current contents of the list be checked? — In the current version of the regulatory act in the “Adilet” legal information system.