Kazakhstan: Proposed amendments to e-invoicing rules

A draft law published on October 10, 2025, would introduce significant changes to the Electronic Invoice System (EIS), expected to take effect on January 1, 2026, if approved. The proposed amendments include:

General changes for value added tax (VAT) taxpayers

• Individual entrepreneurs would be exempt from issuing electronic invoices (e-invoices) when selling personal property.
• The IIN (Individual Identification Number) would not be a mandatory field on fiscal receipts from cash registers unless requested by the buyer.
• The deadline for issuing an e-invoice upon buyer request would be reduced from 180 to 15 calendar days from the date of the transaction.
• New obligation for passenger transportation service providers: Purchasers of passenger transportation services may request an e-invoice or a travel confirmation document within 15 calendar days. The supplier would need to issue a document including the recipient’s personal data.

New requirements for issuing e-invoices in the electronic invoice information system (EIS)

• E-invoices must be issued no earlier than the transaction date and no later than 15 calendar days after it (unless otherwise specified by law).
• For certain transaction types, e-invoices may be issued monthly, but no later than the 20th of the following month.
• The list of transaction types eligible for monthly invoicing would be expanded.
• In emergency situations, paper invoices must be entered into the EIS within 30 calendar days after the emergency period ends.
• Biometric identification would be introduced for signing e-invoices electronically in cases when risk indicators are triggered.
• New mandatory e-invoicing obligations would apply to freight forwarders and commission agents providing services or works, regardless of VAT registration status.
• In the event of a legal entity reorganization, the successor must issue a supplementary e-invoice (if an increase in value is required) within 180 calendar days of the transaction date.
• For services or works purchased from nonresidents, the Kazakhstani buyer must issue an e-invoice within five calendar days after paying VAT on behalf of the nonresident (including cases of offset under Articles 122 and 123 of the Tax Code).

New obligations for e-invoice recipients

For corrected or additional e-invoices:

• VAT taxpayers must confirm or reject the invoice. It is considered issued only upon confirmation.
• Non-VAT taxpayers may reject the invoice within 10 calendar days; otherwise, it is deemed accepted.

For revoked e-invoices:

• VAT taxpayers must confirm the revocation for it to be valid.
• Non-VAT taxpayers may reject the revocation within 10 calendar days; if not, the revocation is considered accepted.
• Recipients retain the right to request reissuance of a previously revoked invoice.

VAT credit recognition in the EIS

• To claim input VAT, taxpayers must mark the VAT amount as creditable in the EIS before submitting Form 300.00 (VAT return).

New categories required to issue e-invoices

The following non-VAT taxpayers would be required to issue e-invoices:

• Commission agents
• Freight forwarders
• Taxpayers providing international transportation services
• Taxpayers under the simplified declaration regime
• Providers of medical services
• Sellers of medicines and medical devices
• Law firms providing legal assistance

These taxpayers would need to issue e-invoices when selling to:

• End consumers
• Individuals or legal entities classified as micro-entrepreneurs

Exceptions (e-invoicing not required) would apply to:

• Sales with cash register receipts, payment terminals, or mobile apps (IIN included upon request)
• Sales to individuals paid via electronic money or cards
• Payments for utilities or telecom services via banks or postal operators
• Sales of train or airline tickets
• Free-of-charge transfers to individuals not engaged in business or private practice
• Financial operations under Article 477 of the Tax Code

For further information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com