In 2026, an individual entrepreneur not registered for VAT is not required to issue an EWCC solely because of their status: Article 492 of the Tax Code of the Republic of Kazakhstan establishes requirements for the electronic issuance of invoices by VAT payers, but does not regulate the electronic work completion certificate or impose such an obligation on an individual entrepreneur not registered for VAT (Article 492 of the Tax Code of the Republic of Kazakhstan). The grounds for issuing an EWCC should be determined according to the electronic document management rules, the terms of the specific transaction, and the agreement with the customer.
What Is an EWCC and How Is It Related to the E-Invoicing IS?
An EWCC is an electronic work completion certificate (certificate of services rendered) issued in the Electronic Invoicing Information System. The document is used by the parties to electronically document the results of completed work or rendered services.
EWCCs and electronic invoices perform different functions:
- Electronic invoice — an invoice issued electronically. For VAT payers, the requirements for issuing it electronically are established by Article 492 of the Tax Code of the Republic of Kazakhstan. A VAT payer may issue a paper invoice only in the cases listed in this article, including the absence of a communications network, technical errors in the E-Invoicing IS, suspension of electronic invoice issuance, an emergency, or a state of emergency (Article 492 of the Tax Code of the Republic of Kazakhstan).
- EWCC — an electronic document certifying completed work or rendered services. The provisions of Article 492 of the Tax Code of the Republic of Kazakhstan concerning electronic invoices cannot automatically be applied to the procedure for issuing an EWCC.
Therefore, the VAT status of an individual entrepreneur does not in itself answer the question concerning an EWCC. To prepare the documents correctly, the accountant must separately determine which document is required for the transaction and which form of document exchange has been agreed with the customer.
Who This Concerns: Individual Entrepreneurs Not Registered for VAT
This question arises for individual entrepreneurs who are not registered for VAT and provide services or perform work for legal entities, government organizations, or other individual entrepreneurs. In practice, three situations must be distinguished:
- An electronic certificate is stipulated by the agreement. If the parties have expressly agreed to execute certificates through the E-Invoicing IS, the contractor prepares the documents according to the procedure established by the agreement. Before issuing the document, the accountant should reconcile the parties' details, the description of the work or services, the date, and the cost with the agreement and the documents concerning the performance of obligations.
- A special electronic procedure is established for the transaction. In this case, the rules relating specifically to the relevant transaction and document apply. The mandatory use of an EWCC cannot be justified solely by Article 492 of the Tax Code of the Republic of Kazakhstan: it concerns invoices issued by VAT payers, not certificates issued by individual entrepreneurs not registered for VAT (Article 492 of the Tax Code of the Republic of Kazakhstan).
- The agreement does not provide for an EWCC. The parties determine the form of the document with due regard to the applicable document management rules and the contents of the agreement. A customer's request to switch to an electronic certificate should preferably be formalized as an agreed amendment to the document exchange procedure so that the parties have consistent requirements for signing and accepting the certificate.
Important: an electronic invoice and an electronic certificate are not interchangeable documents. The rules of Article 492 of the Tax Code of the Republic of Kazakhstan concerning electronic invoices for VAT payers do not constitute independent grounds for requiring an individual entrepreneur not registered for VAT to issue an EWCC specifically (Article 492 of the Tax Code of the Republic of Kazakhstan).
How to Check Whether Your Individual Entrepreneur Is Required to Issue One
The accountant should consistently identify the grounds on which the customer expects an electronic certificate. This makes it possible to distinguish a statutory requirement from the document management procedure agreed upon by the parties.
- Determine the subject of the transaction: goods, work, or services. An EWCC concerns the documentation of completed work and rendered services; therefore, the description of the transaction in the agreement and documents must correspond to its actual substance.
- Review the agreement and its appendices. Pay attention to the form of the certificate, how it is sent, the signing procedure, the deadline for submitting the document, and the parties' actions if there are any comments.
- If the customer refers to the Tax Code, compare its requirement with the content of the cited provision. Article 492 of the Tax Code of the Republic of Kazakhstan regulates the issuance of invoices by VAT payers and the exceptions to electronic issuance available to them; it does not establish EWCC requirements for individual entrepreneurs not registered for VAT (Article 492 of the Tax Code of the Republic of Kazakhstan).
- If the transaction is conducted under a separate regulated procedure, apply the document preparation procedure established for that procedure together with the terms of the agreement.
- Document the agreed method for exchanging certificates. This is particularly important if the agreement originally provided for a paper document and the customer subsequently proposed switching to the E-Invoicing IS.
If the agreement serves as the basis for issuing an EWCC, the deadline for its issuance is determined by the terms of the agreement. If an electronic procedure is established by special rules for a particular transaction, the document is issued in accordance with those rules. The deadlines for issuing electronic invoices under Article 492 of the Tax Code of the Republic of Kazakhstan cannot automatically be applied to an EWCC.
How to Issue an EWCC in 1C: Practical Details
The procedure in 1C depends on the configuration used, its release, the integration settings, and the available functions of the E-Invoicing IS. In the current configurations “Accounting for Kazakhstan” 3.0.74.x and “Payroll and Human Resources Management for Kazakhstan” 3.1.37.x, command names and the location of interface elements may differ.
1. Identify the supporting document. Before creating an EWCC, verify that the accounting system records the transaction specifically as work or services and that the agreement details, customer details, transaction date, description, and cost have been completed. The selected document must correspond to the actual business transaction.
2. Check the electronic exchange method. The database must provide access to the E-Invoicing IS for the organization or individual entrepreneur on whose behalf the document is issued. If accounting records are maintained for several organizations, the settings and user permissions must be checked separately for the relevant taxpayer.
3. Reconcile the data before sending. The customer's name, identifier, agreement details, description of the work or services, date, and amount must match the accounting document. Discrepancies in the details may result in comments from the customer.
4. Do not change the VAT status to gain access to the document. The VAT registration indicator in the accounting system must correspond to the individual entrepreneur's actual status. Article 492 of the Tax Code of the Republic of Kazakhstan applies to VAT payers and does not provide grounds for indicating a different status for an individual entrepreneur in order to issue an EWCC (Article 492 of the Tax Code of the Republic of Kazakhstan).
After sending the document, check its status in the accounting system and the E-Invoicing IS. If the customer rejects the certificate, corrections should be made with due regard to the reason for rejection, the actual transaction data, and the document management procedure agreed upon by the parties.
What the Accountant of an Individual Entrepreneur Not Registered for VAT Should Do Now
- Compile a list of agreements under which work is performed or services are rendered, and mark those containing a provision on electronic certificates.
- Distinguish statutory requirements from contractual terms: the customer's reference to mandatory electronic invoices for VAT payers does not confirm that an EWCC is mandatory for an individual entrepreneur not registered for VAT.
- Check whether the 1C configuration is up to date, access to the E-Invoicing IS, user permissions, and the details of the individual entrepreneur and customer.
- Before sending, reconcile the electronic certificate with the agreement, the sales document, and the actual substance of the completed work or rendered services.
- Retain the document exchange procedure agreed upon by the parties together with the agreement and signed certificates.
Frequently Asked Questions
If an individual entrepreneur is not a VAT payer, can they issue an EWCC? — Article 492 of the Tax Code of the Republic of Kazakhstan does not prohibit an individual entrepreneur not registered for VAT from issuing an EWCC: it regulates the form of an invoice issued by a VAT payer (Article 492 of the Tax Code of the Republic of Kazakhstan). Issuing an electronic certificate requires access to the E-Invoicing IS, correct details, and grounds for applying this document management procedure.
The customer requires an EWCC, but Article 492 of the Tax Code of the Republic of Kazakhstan concerns VAT payers. What should be done? — Determine the grounds for the customer's requirement. If electronic certificates are stipulated by the agreement, follow the agreed procedure. If the customer refers only to Article 492 of the Tax Code of the Republic of Kazakhstan, this article regulates electronic invoices issued by VAT payers, not EWCCs issued by individual entrepreneurs not registered for VAT (Article 492 of the Tax Code of the Republic of Kazakhstan).
Why does the EWCC command not appear in 1C? — The reason may be related to the type of accounting document, the configuration release, the integration settings for the E-Invoicing IS, or user permissions. Verify that the transaction is recorded as the performance of work or rendering of services and that electronic exchange is configured for the relevant individual entrepreneur.
Can an EWCC be issued for the sale of goods? — An EWCC is intended to document completed work and rendered services. If goods were actually sold, the accountant should use a document corresponding to the substance of that transaction and should not use an EWCC as a substitute for documenting the sale of goods.
Can the exceptions for paper invoices be applied to an EWCC? — They cannot automatically be applied to an EWCC. Article 492 of the Tax Code of the Republic of Kazakhstan permits a VAT payer to issue a paper invoice in the expressly listed cases and establishes deadlines for its subsequent entry into the E-Invoicing IS, but these provisions apply specifically to invoices (Article 492 of the Tax Code of the Republic of Kazakhstan).
Where is the deadline for issuing an EWCC determined? — The deadline is determined by the provision governing the specific transaction and by the terms of the agreement. The deadlines stipulated by Article 492 of the Tax Code of the Republic of Kazakhstan for the subsequent entry of a paper invoice into the E-Invoicing IS after technical or other circumstances have been resolved are not deadlines for issuing an EWCC (Article 492 of the Tax Code of the Republic of Kazakhstan).