{"id":53093,"date":"2026-08-26T07:31:11","date_gmt":"2026-08-26T04:31:11","guid":{"rendered":"https:\/\/kz.f-chain.com\/?p=53093"},"modified":"2026-08-26T07:31:11","modified_gmt":"2026-08-26T04:31:11","slug":"invoice-requirements-kazakhstan-2026","status":"publish","type":"post","link":"https:\/\/kz.f-chain.com\/en\/feautured-post\/invoice-requirements-kazakhstan-2026\/","title":{"rendered":"New Invoice Requirements in Kazakhstan"},"content":{"rendered":"

New Invoice Requirements in Kazakhstan<\/strong><\/h2>\n

Starting from January 1, 2026, the range of taxpayers required to issue invoices in Kazakhstan has been expanded. This obligation applies not only to registered VAT payers but also to certain categories of taxpayers that do not pay VAT. The relevant provisions are established by the new Tax Code of the Republic of Kazakhstan. The full list of persons required to issue invoices is set out in Article 207 of the Tax Code, while specific cases in which non-VAT payers must issue invoices are provided for in Articles 208 and 209. At the same time, the legislation specifies situations in which an invoice is not required, including certain payment methods and types of transactions. However, in the cases provided for by law, a buyer has the right to request an invoice within 15 calendar days, and the supplier is required to issue it. For businesses, this means that the absence of VAT registration does not in itself exempt a taxpayer from issuing invoices: the obligation depends on the taxpayer category, the nature of its activities, and the specific transaction.<\/p>\n

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Who Is Required to Issue Invoices<\/strong><\/h3>\n

The Tax Code provides for two main groups of taxpayers that are required to issue invoices. The first group consists of registered VAT payers, which issue invoices in accordance with the general rules established by Chapter 50 of the Tax Code. The second group includes taxpayers that are not VAT payers but are nevertheless required to issue invoices in cases expressly provided for in Articles 208 and 209 of the Tax Code. When determining whether an invoice must be issued, businesses need to consider not only their tax status but also the specific transactions they carry out. In particular, separate requirements apply to commission agents, freight forwarders, participants engaged in customs activities, taxpayers providing international freight transportation services, as well as transactions involving imported goods and goods recorded in the Virtual Warehouse module. The obligation also applies to taxpayers using the special tax regime based on a simplified declaration and to a number of other categories specified in the Tax Code. Therefore, not being registered as a VAT payer does not eliminate the obligation to issue an invoice if the taxpayer or the transaction falls within one of the cases established by law.<\/p>\n

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When Non-VAT Payers Are Required to Issue Invoices<\/strong><\/h3>\n

The list of cases in which the obligation applies to non-VAT payers covers various types of activities and transactions. In particular, invoices must be issued by:<\/p>\n

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  1. commission agents \u2014 in the cases provided for in Article 495 of the Tax Code;<\/li>\n
  2. freight forwarders \u2014 in the cases established by Article 494 of the Tax Code;<\/li>\n
  3. the department of the authorized body responsible for the state material reserve \u2014 when goods are released from the state reserve;<\/li>\n
  4. taxpayers providing international freight transportation services;<\/li>\n
  5. legal entities accredited to carry out conformity assessment activities;<\/li>\n
  6. taxpayers engaged in customs activities, including customs representatives and customs carriers, owners of temporary storage warehouses and customs warehouses, as well as authorized economic operators;<\/li>\n
  7. taxpayers applying the special tax regime based on a simplified declaration;<\/li>\n
  8. taxpayers making supplies under ratified international treaties;<\/li>\n
  9. taxpayers selling imported goods;<\/li>\n
  10. taxpayers selling goods recorded in the Virtual Warehouse module;<\/li>\n
  11. taxpayers providing medical services and selling medicines and medical devices;<\/li>\n
  12. law offices \u2014 in respect of legal assistance provided by lawyers under agreements concluded by such law offices.<\/li>\n<\/ol>\n

    This list demonstrates that the obligation to issue an invoice is not determined solely by whether a taxpayer is registered for VAT. In certain cases, the taxpayer\u2019s type of activity, the nature of the sale of goods or services, and the applicable tax regime are also relevant.<\/p>\n

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    When an Invoice Is Not Required<\/strong><\/h3>\n

    The Tax Code also provides for cases in which an invoice does not need to be issued. These include, in particular, certain payments accompanied by the issuance of a cash register receipt or payments made through payment terminals, the issuance of a receipt through a special mobile application, as well as payments made using electronic money. An invoice may also not be required when goods, works, or services are supplied to individuals for personal consumption and to microbusiness entities, when railway or air travel is documented by a ticket, and for certain financial transactions. However, the existence of grounds for not issuing an invoice does not in every case mean that no further action is required. A buyer has the right to request an invoice within 15 calendar days, after which the supplier is required to issue the document. Businesses should therefore take into account not only the applicable exemptions but also the possibility of receiving such a request from a buyer. A separate rule applies to the sale of personal property: an individual, including an individual entrepreneur, does not issue an invoice when selling personal property.<\/p>\n

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    What Changed in 2026<\/strong><\/h3>\n

    The key change is the expansion, from January 1, 2026, of the range of persons subject to the invoice issuance requirement. As a result, companies and entrepreneurs need to assess this obligation in accordance with the provisions of the new Tax Code and the specifics of their own transactions. This is particularly relevant for non-VAT payers, as this status alone no longer means that an invoice is not required. In cases provided for by law, the document must be issued even if the taxpayer is not registered for VAT. For businesses, it is therefore important to correctly determine their taxpayer category and identify the transactions for which the relevant obligation arises. This includes companies dealing with imported goods, using the Virtual Warehouse module, applying the special tax regime based on a simplified declaration, or carrying out specific types of activities expressly listed in the Tax Code.<\/p>\n

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    What Businesses Should Consider<\/strong><\/h3>\n

    The new rules require businesses to pay closer attention to the documentation of transactions and primary accounting records. Companies need to determine whether a specific transaction is subject to the mandatory invoice requirement or, conversely, falls within an exemption provided by law. Particular attention should be paid to situations where a company is not a VAT payer but falls within the prescribed list due to the nature of its activities or a specific transaction. This includes certain transactions involving imported goods, goods recorded in the Virtual Warehouse module, as well as specific categories of taxpayers expressly identified in the Tax Code. In addition, when applying exemptions, businesses should take into account the buyer\u2019s right to request an invoice within 15 calendar days. In such a case, the supplier is required to issue the document. Since the range of persons required to issue invoices expanded from January 1, 2026, non-VAT payers also need to consider the specific circumstances in which they are required to issue invoices. When organizing accounting and tax processes, businesses should align their invoice procedures with the transactions they actually carry out and the requirements applicable from 2026.<\/p>\n

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    FChain Accounting and Legal Support Services<\/strong><\/h3>\n

    Changes to invoice issuance rules directly affect the accounting documentation of business transactions. Companies need to organize their accounting processes properly and determine when the obligation to issue the relevant documents arises. FChain provides the following services in this area:<\/p>\n