South Africa E-Invoicing Requirements: 2028 Mandate Guide

South Africa will mandate electronic invoicing by 2028 under the SARS VAT modernisation programme. The framework uses a Peppol-based 5-corner model where invoices are transmitted through certified Access Points in structured PINT format, with SARS receiving real-time transaction data. Phased onboarding begins in 2026 with large taxpayers, and full implementation targets 2028.

This guide covers the complete South Africa e-invoicing requirements from regulation to readiness: what the mandate actually requires, the VAT fraud problem driving it, the full TALAB-to-2028 regulatory timeline, how the Peppol 5-corner model works, international comparisons, and a practical preparation checklist for finance teams.

Before mapping out those timelines and technical details, the first question to address is what SARS actually means by "e-invoicing," because the term carries a specific regulatory definition that goes well beyond sending invoices electronically.

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What E-Invoicing Means Under South Africa's New Mandate

Most South African businesses already handle invoices electronically in some form. PDF attachments sent via email, invoices generated through accounting software, VAT201 returns filed through SARS eFiling. Under the Electronic Communications and Transactions Act (ECTA), these electronic invoices are legally accepted. But none of this qualifies as "e-invoicing" under the incoming mandate.

The distinction matters. What exists today is document exchange: a human-readable file (typically a PDF) moves from one party to another, and VAT data reaches SARS only at the return level, aggregated across all transactions. SARS sees totals. It does not see individual invoices.

What the mandate introduces is data exchange. Under the framework established by the Draft 2025 Tax Administration Laws Amendment Bill (TALAB), "e-invoicing" means structured data in XML/UBL format transmitted through certified Peppol Access Points. The TALAB introduced formal legal definitions of "electronic invoice" and "electronic report" into the VAT Act for the first time, creating the statutory foundation for invoice-level reporting.

This changes three things simultaneously:

• Format shifts from visual to structural. Instead of a PDF designed for human reading, invoice data is encoded in a standardized machine-readable format that systems can validate, process, and reconcile automatically.
• Transmission moves from point-to-point to network-based. Rather than emailing a file directly to a client, businesses will send invoice data through certified Access Points on the Peppol network, where it reaches both the recipient and SARS.
• Reporting becomes real-time and granular. SARS will receive invoice-level data as transactions occur, replacing the current model where tax authorities only see aggregated figures at filing time.

South Africa is not pioneering this approach. Structured e-invoicing mandates are already operational across dozens of countries, and South Africa joins a global e-invoicing landscape where governments are systematically replacing document-based invoicing with standardized data transmission. The Peppol framework South Africa has adopted is the same infrastructure used by the European Union, Australia, and New Zealand — and by Singapore, whose InvoiceNow mandate is already phasing in Peppol-based e-invoicing for GST-registered businesses.

The scale and urgency behind this shift become clearer when you examine what is driving SARS to mandate it.

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Why SARS Is Mandating E-Invoicing: VAT Fraud and Revenue Recovery

South Africa has a VAT fraud problem measured in tens of billions of rand. Estimates place the annual cost of VAT fraud between ZAR 22 billion and ZAR 50 billion, and SARS has identified approximately R800 billion in unpaid taxes across multiple components of the tax system. These figures represent a significant drain on public revenue, and they explain why SARS is treating e-invoicing not as an administrative upgrade but as a fiscal enforcement priority.

The core strategy behind the mandate is Continuous Transaction Controls (CTC). Under a CTC model, SARS receives invoice data in real-time or near-real-time as transactions occur. This fundamentally changes the enforcement dynamic. Instead of detecting fraudulent invoices, fictitious vendors, and VAT carousel schemes during audits conducted months or years after the fact, SARS can identify suspicious activity before VAT refunds are issued. For businesses, this means the days of paper-based or PDF invoice fraud going undetected for extended periods are numbered.

E-invoicing sits within the broader SARS VAT modernisation programme, which combines digital reporting, e-invoicing infrastructure, and AI-enabled risk engines into a single compliance framework. According to KPMG's analysis of South Africa's e-invoicing reform, South Africa's revenue service has confirmed a multi-year e-invoicing and real-time VAT digital reporting reform, with system design and pilots running through 2026 and large taxpayer onboarding planned for 2026-2029, as part of its strategic vision to integrate e-invoicing with AI-enabled risk engines, customs, and trade systems.

The regulatory signals are already visible beyond VAT. SARS customs began requiring invoice data in all electronic customs declarations effective April 2025, reinforcing the direction of travel toward complete digital documentation across tax and trade systems. Each of these measures feeds into the same objective: closing the gap between taxable activity and reported activity.

For financial controllers and CFOs, the takeaway is straightforward. This mandate is backed by quantifiable revenue losses in the tens of billions, an enforcement architecture already under construction, and a government agency that has publicly committed to a multi-year rollout.

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The SARS E-Invoicing Timeline: From TALAB to Full Mandate

South Africa's path to mandatory e-invoicing follows a structured legislative and implementation sequence. Unlike many countries that announced mandates with compressed timelines, SARS has laid out a multi-year roadmap that gives businesses defined milestones to plan against.

Here is the full SARS e-invoicing timeline from legislation through enforcement:

• August 2025: The draft 2025 Tax Administration Laws Amendment Bill (TALAB) is published for public comment. This bill introduces formal legal definitions for "electronic invoice" and "electronic report" into South African tax law, along with an interoperability framework that establishes how e-invoicing data will flow between businesses and SARS.

• Late 2025: A second public consultation round addresses technical standards, including accepted data formats, access point provider certification requirements, and interoperability specifications. Businesses and software vendors can submit feedback during this window.

• 2026: System design moves into implementation. The final bill is expected to go before Parliament for debate and passage. SARS is anticipated to launch pilot programs with large taxpayers during this period, testing real transaction flows before broader rollout.

• 2026-2029: Phased onboarding begins with large VAT-registered taxpayers and priority sectors, then expands progressively to mid-size and smaller businesses. Companies in designated sectors or above specific revenue thresholds should expect compliance obligations well before the universal deadline.

• 2028: Full operational implementation of mandatory e-invoicing across all VAT-registered businesses in South Africa.

Transmission Windows Will Tighten Over Time

One detail that carries significant operational weight is the planned progression of submission windows. At launch, businesses will submit invoice data to SARS on a daily basis. As the system matures, that window narrows to 6 hours, and eventually to 1 hour. This compression means your invoicing processes and systems need to operate in near-real-time by the time the mandate reaches full maturity. Batch processing invoices at the end of a billing cycle will not meet these requirements.

VAT Registration Threshold Changes

Running parallel to the e-invoicing mandate, SARS is adjusting VAT registration thresholds effective 1 April 2026 for the first time since 2009. The mandatory registration threshold increases from R1 million to R2.3 million in annual turnover, while the voluntary registration threshold rises from R50,000 to R120,000.

The practical effect: fewer businesses will be required to register for VAT. However, every business that remains VAT-registered faces a higher compliance burden under the e-invoicing mandate, including system upgrades, access point provider integration, and adherence to tightening transmission windows. These businesses must also continue meeting the South Africa tax invoice requirements under the VAT Act, which define mandatory fields across full tax invoices, abridged invoices, and credit notes — the baseline that e-invoicing will digitize rather than replace.

The VAT rate itself remains stable at 15%. A proposed increase was reversed in April 2025, removing one variable from compliance planning.

Plan for Earlier Deadlines

While 2028 is the headline date for full implementation, businesses in priority sectors or above certain revenue thresholds should plan for compliance starting in 2026 during the phased rollout. Waiting until 2028 to begin preparation creates unnecessary risk, particularly given the system integration and testing required.

Specific penalties for non-compliance with the e-invoicing mandate have not yet been defined in the current legislation. However, the Tax Administration Act already provides SARS with broad enforcement powers including administrative penalties and interest charges for non-compliance with tax obligations, and these would likely extend to e-invoicing requirements once the mandate is enacted.

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How the Peppol 5-Corner Model Works in South Africa

South Africa's e-invoicing framework is built on Peppol, an international interoperability standard originally developed in Europe and now adopted by governments across multiple continents. Understanding the architecture behind this system is essential for both financial leaders evaluating the business impact and IT teams planning technical integration.

The standard Peppol 4-corner model establishes four participants in every invoice exchange:

1. Corner 1 - Sender: The supplier who issues the invoice.
2. Corner 2 - Sender's Access Point: A certified intermediary that validates the invoice format, routes it through the Peppol network, and confirms delivery.
3. Corner 3 - Receiver's Access Point: Another certified intermediary that receives the invoice on behalf of the buyer.
4. Corner 4 - Receiver: The buyer who receives the validated invoice.

In this model, businesses never transmit invoices directly to each other. Instead, certified Peppol Access Points handle format validation, network routing, and delivery confirmation on their behalf. This removes the need for point-to-point integrations between trading partners.

South Africa extends this to a 5-corner model by adding SARS as a fifth participant. Every invoice transmitted through the Peppol network is simultaneously delivered to SARS in real time. This is a form of Continuous Transaction Controls (CTC), where the tax authority gains ongoing visibility into B2B transactions without requiring businesses to file separate VAT returns or submit invoice data through a separate reporting portal. The tax authority receives the same structured data that flows between trading partners, eliminating reconciliation gaps between what businesses report and what actually occurred.

The data format underpinning this system is PINT (Peppol International Invoice), a standardized XML-based specification maintained by OpenPeppol. PINT replaces the current patchwork of unstructured PDFs, emailed spreadsheets, and proprietary ERP export formats with a single interoperable standard.

Certified Peppol Access Points are central to the architecture. Businesses will not connect directly to the Peppol network or to SARS. Instead, each organization selects a certified Access Point provider that handles the technical requirements: converting invoice data into PINT format, validating it against the schema, routing it to the correct recipient Access Point, and delivering the required copy to SARS. South Africa has not yet formally appointed a Peppol Authority under OpenPeppol, which means the certification framework for Access Points is still being developed. Businesses should monitor SARS announcements for updates on when Access Point registration opens.

Storage requirements add another layer of compliance. Electronic invoices transmitted through the Peppol network must be retained for a minimum of 5 years, consistent with existing South African tax record-keeping obligations. Organizations should confirm that their chosen Access Point provider or internal archiving systems can meet this retention period with full data integrity.

South Africa's choice of the Peppol 5-corner model is not experimental. France adopted a structurally similar Peppol-based framework for its own B2B e-invoicing mandate, using certified platforms and a government portal as the central data recipient. The parallel between the two systems confirms that South Africa is following a proven international approach rather than building an untested national system. For organizations that operate across borders, familiarity with France's Peppol-based e-invoicing mandate provides useful context for what to expect from the South African rollout.

For businesses already using Peppol infrastructure in EU or Asia-Pacific jurisdictions, the SA mandate may require minimal additional technical investment. The Peppol network is designed for cross-border interoperability, and Access Point providers certified in other jurisdictions are likely to extend coverage to the South African market as certification opens.

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How South Africa's Mandate Compares to Other Countries

South Africa is not pioneering e-invoicing in isolation. Over 50 countries worldwide are at some stage of mandating or planning structured e-invoicing, and SA's approach draws directly from lessons learned elsewhere. Understanding where South Africa fits in this global wave helps you benchmark timelines, anticipate challenges, and plan with greater confidence.

Italy offers the most instructive precedent. Its Sistema di Interscambio (SDI) platform went live in 2019, making it the first EU country to mandate B2B e-invoicing. The results speak for themselves: Italy reported a measurable reduction in its VAT gap within the first two years of enforcement. While Italy uses a centralized exchange system rather than the Peppol network South Africa has adopted, the underlying goal is identical: giving the tax authority real-time visibility into commercial transactions. For South African businesses, Italy's experience confirms that mandatory e-invoicing delivers on its revenue recovery promise, which means SARS is unlikely to soften or delay its mandate once timelines are set.

Spain is taking a structurally different path with its Verifactu system. Rather than routing invoices through a network of Access Points, Spain's Verifactu e-invoicing requirements center on a certified software model where approved invoicing applications report transaction data directly to the tax authority. The contrast highlights why SARS chose the Peppol 5-corner route instead: Peppol's interoperable network architecture scales more naturally across industries and company sizes, and it avoids locking businesses into specific software vendors for compliance.

The United Kingdom is on a timeline that closely mirrors South Africa's. The UK's planned 2029 e-invoicing mandate places it roughly a year behind SA's expected full enforcement, and both countries are currently in consultation and planning phases. For multinational companies operating across SA and the UK, this parallel rollout means e-invoicing readiness investments made for one jurisdiction will largely transfer to the other.

South Africa benefits from joining later in this global wave. The Peppol infrastructure is proven, international precedent provides a clear roadmap for what the transition requires, and Access Point providers already operating in other jurisdictions will bring established processes to the SA market.

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How to Prepare Your Business for E-Invoicing in South Africa

Even though the full mandate date is 2028, the groundwork you lay now will determine whether your transition is controlled or chaotic. Businesses that start planning early consistently spend less and experience fewer disruptions than those that scramble at the deadline. The following checklist covers the critical preparation steps for financial controllers, AP managers, and IT teams.

1. Audit your current invoice formats. Determine what percentage of your invoices are paper, PDF, or already structured data. This baseline tells you the scale of your transition challenge. Most South African businesses today rely on PDF invoices sent via email, which means the shift to structured e-invoicing will require meaningful process changes for the majority of organizations.

2. Evaluate your accounting and ERP system's Peppol readiness. Check whether your current software supports Peppol connectivity or has a published roadmap for adding it. Major ERP providers like SAP, Sage, Xero, and QuickBooks are at various stages of building Peppol support for the South African market. If your system lacks a clear Peppol roadmap, begin evaluating alternatives or middleware solutions that can act as an intermediary layer between your existing system and the Peppol network.

3. Understand Access Point requirements. Every business participating in the e-invoicing network will need to connect through a certified Peppol Access Point. Start researching potential providers now. Because the South African certification framework is still being developed by SARS, prioritize providers that already hold Peppol credentials in other jurisdictions such as Australia, Singapore, or the EU. These providers will have operational experience with the protocol and are likely to be among the first certified locally.

4. Plan for data format conversion. Your invoices will need to be transmitted in PINT format, which is a structured data standard. If your current system generates PDFs or proprietary formats, you will need a conversion layer or middleware to produce compliant output. For businesses still processing legacy-format invoices, whether paper, scanned PDFs, or image files, automated invoice data extraction tools can bridge the gap during the transition period by converting unstructured documents into structured data. Platforms that handle PDF and image formats (JPG, PNG) with batch processing capacity for up to 6,000 documents at a time are particularly relevant for organizations managing high invoice volumes while building toward full Peppol compliance.

5. Review storage and record-keeping requirements. Electronic invoices must be stored for a minimum of 5 years under South African tax law. Ensure your archiving systems can handle structured e-invoice data in its native format, not just PDF copies. This distinction matters because SARS will expect you to retain the machine-readable invoice data, not a visual representation of it.

6. Set internal timelines against the SARS phased rollout. If your business qualifies as a large VAT taxpayer or operates in a priority sector, you may need to comply well before the 2028 full mandate date. Monitor SARS announcements closely for sector-specific timelines, and build your project plan around the earliest possible date your organization could be called to participate. Working backward from that date gives you a realistic implementation schedule.

7. Budget for implementation. Factor in costs across four categories: system upgrades or new software, Access Point subscriptions, staff training, and potential consulting fees for gap analysis or integration work. International experience from countries that have already rolled out Peppol-based e-invoicing consistently shows that businesses starting early face lower total costs, largely because they avoid rush implementation premiums and have time to negotiate better vendor terms.

The preparation window between now and the first compliance deadlines is finite. Businesses that treat this as a 2028 problem risk discovering in 2027 that their systems need fundamental changes they cannot implement in time. Starting with these seven steps positions your organization to move through each phase of the SARS rollout with confidence rather than urgency.

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Key Takeaways and Next Steps for South African Businesses

South Africa's e-invoicing mandate represents a significant shift in how businesses handle tax compliance. Here are the five facts that matter most:

1. Structured e-invoicing becomes mandatory by 2028, with phased onboarding likely beginning as early as 2026 for large taxpayers registered with SARS.
2. The Peppol-based 5-corner model means SARS receives invoice data in real time through certified Access Points, replacing the current approach of PDF invoices and periodic VAT return submissions.
3. VAT fraud losses of ZAR 22-50 billion per year are driving this mandate, making it highly unlikely that SARS will delay or soften the requirements.
4. Your invoices must transition from unstructured formats to PINT-compliant structured data transmitted through certified Peppol Access Points. Paper and PDF invoices will no longer satisfy compliance requirements.
5. The VAT registration threshold increase to R2.3 million (effective April 2026) narrows the pool of VAT-registered businesses, but raises the compliance bar for every business that remains in scope.

Three steps to take now:

• Audit your current invoice volumes and formats. Quantify how many invoices you send and receive monthly, what percentage are paper or PDF, and which systems generate them. This defines the scope of your transition.
• Contact your accounting or ERP vendor about their Peppol roadmap. Ask specifically whether they plan to support PINT-format invoicing and Peppol Access Point connectivity, and when those capabilities will be available.
• Monitor SARS announcements for rollout details. Watch for sector-specific phasing schedules, Access Point certification requirements, and any pilot program invitations that could affect your compliance timeline.

South Africa's e-invoicing mandate follows a proven international model already operating across Europe, Saudi Arabia, and other markets. Businesses that begin preparing now, before specific deadlines are assigned to their sector, will face a smoother transition and lower compliance costs than those waiting until the final mandate takes effect.