Commercial records: Clarification Needed

Dear ZATCA Support Team,

One of my clients recently received an email from ZATCA stating that their invoices are not compliant with Phase 2 (Integration Phase) of E-Invoicing.

We have carefully implemented all the necessary requirements as per ZATCA’s E-Invoicing regulations. However, we would like to seek clarification regarding the specific issue mentioned in the email, particularly regarding Commercial Registration (CR) records:

  • The email states that when multiple CRs exist, the supplier must enter the CR of the branch issuing the invoice.
  • It also mentions the need to register all branches from which invoices are issued and ensure correct entry of the CR identifier field.

We believe our system already follows these rules, yet this notification was received. Could you please clarify:

  1. What exactly triggers this non-compliance notice?
  2. How can we verify if the CR identifier is correctly included in our invoices?
  3. Is there a specific format or additional validation required in the XML file?
  4. Would this issue cause invoices to be rejected in the upcoming enforcement phase?

For reference, the email also provided the following ZATCA links regarding compliance and penalties:

I would appreciate guidance from the ZATCA team or other professionals who have encountered a similar issue.