--- title: "Issuance of an invoice by VAT non-payers: in which cases is this mandatory?" country: KZ lang: en author: Сапа Т.И. (https://buhgpt.kz/authors/sapa-ti) date: 2026-09-04 canonical: https://buhgpt.kz/suraqtar/vypiska-scheta-faktury-neplatelshchikami-nds-v-kakih-sluc-en source: BuhGPT --- # Issuance of an invoice by VAT non-payers: in which cases is this mandatory? > **TL;DR:** What is it about As a general rule, value-added tax (VAT) payers are required to issue invoices. However, there are exceptions to this rule: in certain situations, invoices (usually in electronic form — electronic invoice (ESF)) must also be issued by those who are not VAT pay --- What is it about As a general rule, value-added tax (VAT) payers are required to issue invoices. However, there are exceptions to this rule: in certain situations, invoices (usually in electronic form — electronic invoice (ESF)) must also be issued by those who are not VAT payers. Let's explore when a non-VAT payer has such an obligation and how to prepare for it to avoid claims during a tax audit. It is important to understand that the mere fact that you are not registered for VAT does not always exempt you from issuing a document. The obligation may be linked not to the status of the person but to the type of operation or the category of goods sold. When a non-VAT payer is still required to issue an invoice The obligation to issue an invoice for a person who is not a VAT payer is usually associated with specific types of operations and goods. In practice, such situations include: - Sale of certain categories of goods, the turnover of which is subject to traceability and is accompanied by the issuance of accompanying documents for goods (SNT) — for example, goods from the list of exemptions imported from EAEU countries, or excise goods and other controlled products. - Operations under commission, mandate, or transportation expedition agreements, where the person acts in the interests of another party and is required to reissue documents. - Sales in foreign economic and cross-border operations in the context of interaction with countries of the Eurasian Economic Union. - Situations explicitly provided for by tax legislation, where the obligation to issue is established for a specific type of activity or transaction regardless of VAT status. Since the list of such cases and the rules for their application are established by tax legislation and subordinate acts and are periodically updated, it is always worth checking a specific operation against the current version of the norms and explanations from tax authorities. Who is affected This issue is particularly relevant for sole proprietors and legal entities that operate without VAT registration: they apply special tax regimes, have not exceeded the threshold for mandatory registration, or engage in activities where VAT registration is not required. Special attention should be paid to those who: - trade in goods subject to traceability or requiring the issuance of SNT; - import goods from EAEU countries for subsequent sale; - work under intermediary agreements (commission, mandate, expedition); - participate in supply chains where counterparties require electronic documents. What to do 1. Determine the nature of the operation. Check whether your goods fall into categories requiring the issuance of accompanying documents and whether you are acting as an intermediary. 2. Connect to the electronic invoice information system and ensure you have an electronic digital signature — most mandatory invoices are issued in electronic form. 3. Configure your accounting system so that documents are generated correctly and on time, and that the details meet the requirements. 4. Adhere to the issuance deadlines established for the specific type of operation and keep supporting documents. 5. If in doubt, seek official clarification from the tax authority or a relevant consultant — it is cheaper than correcting mistakes retroactively. Why this is important Failure to issue or timely issue an invoice in cases where it is mandatory can lead to claims from tax authorities and complicate relationships with counterparties: the buyer needs a correct document for their own accounting. Careful document preparation reduces risks during desk audits and tax inspections. Frequently Asked Questions Is a non-VAT payer always required to issue an invoice? — No, as a general rule, this obligation lies with VAT payers, but for certain operations and categories of goods, the law provides exceptions that also apply to non-payers. In what form should an invoice be issued? — As a rule, in electronic form (ESF) through the state information system; an electronic digital signature is required for this. What happens if an invoice is not issued when it is mandatory? — There may be claims from tax authorities and problems for the counterparty who needs the document for accounting; therefore, it is important to determine in advance whether the operation falls under mandatory cases. How to understand if my goods fall into categories with mandatory issuance? — You need to compare the goods with the current lists (including goods requiring the issuance of accompanying documents) and, if necessary, request clarification from the tax authority. Does an intermediary need to issue an invoice if they do not pay VAT? — When working under commission, mandate, or expedition agreements, the intermediary usually has an obligation to issue and reissue documents regardless of VAT status. Sources - “Issuing invoices by non-VAT payers: in which cases is this mandatory?” — 1C:ITS Kazakhstan (news) --- _BuhGPT — ИИ-помощник для бухгалтеров Казахстана: https://buhgpt.kz_