Integrating an ERP with Egypt's e-invoice and e-receipt systems

An ERP connects to the e-invoice system by integrating with it: each invoice is issued from it, signed electronically and sent in real time to the system of the Egyptian Tax Authority (the ETA) to verify the invoice and the issuer's signature; once accepted, the ETA gives it a unique number and the issuer is notified. For the electronic receipt, the system integrates directly with the taxpayer's ERP or points of sale, and receipts are sent in real time. The rules are in the executive regulations of the Unified Tax Procedures Law issued by Law 206 of 2020 (Official Gazette, issue 42 bis (C), 19 October 2020), which Minister of Finance Decree 286 of 2021 issued (Al-Waqa'i al-Misriyya, issue 123 continued (C), 3 June 2021; "the Regulations"), and, for the electronic receipt, in Minister of Finance Decree 230 of 2022 (Al-Waqa'i al-Misriyya, issue 116 continued, 25 May 2022).

They bind the taxpayer required to issue electronic invoices or receipts. A taxpayer required to issue invoices must obtain an electronic signature certificate, appoint a delegate to manage dealings with the system, carry out the integration steps if it has an ERP, use the unified codes approved by the ETA, and sign each invoice and send it immediately on drafting, within the period set by a decision of the Head of the ETA. A taxpayer required to issue receipts must register on the system, provide the details of its administrator, and code its goods and services under the GS1 or the EGS system.

Registration, delegation and integration

For a business under the invoice or receipt mandate (the legal side sits in E-invoicing in Egypt), integration starts outside the ERP itself. The conditions of the electronic invoice system include obtaining an electronic signature certificate; contracting with a service provider, or submitting invoices through the ETA as service provider in the cases a decision of the Head of the ETA sets; providing the details of the system administrator (name, capacity, national ID, email and telephone number); and, for taxpayers with an ERP, carrying out the steps needed to integrate and connect with the system (article 34 of the Regulations).

To secure the invoice, the taxpayer appoints a delegate to manage dealings with the system, who may add other users with powers the delegate assigns to them. Only the delegates managing the system may issue, review and cancel invoices, and only the system's managing delegate may set the channels for receiving notifications. The taxpayer keeps the login password and protects it against loss or theft, protects its own cryptographic keys on receiving the electronic signature certificate, and protects the cryptographic keys used in the integration between its system and the ETA's (article 36 of the Regulations).

Signing, submission and coding

The Regulations require a valid electronic signature of the invoice's issuer, and real-time transmission of invoices to the system through the service provider or the ETA to verify the invoice and the issuer's signature. The ETA issues a unique number for each electronic invoice, and once it accepts the invoice and gives it that number, the issuer is notified of its receipt, verification and acceptance (article 35 of the Regulations). Each invoice is signed electronically in line with the technical and legal rules on electronic signatures (article 36 of the Regulations).

When an invoice is issued, the electronic format approved by the ETA for invoices and for credit and debit notes is used, together with the unified codes for goods, services and activities approved by the ETA and the code of the issuing branch. The taxpayer uses the electronic signature certificate to sign its invoices and sends them immediately on drafting, within the period set by a decision of the Head of the ETA (article 43 of the Regulations).

The data of an electronic invoice or receipt include the code of the goods or service under the unified coding system set by a decision of the Head of the ETA (article 42 of the Regulations as replaced by Minister of Finance Decree 188 of 2023, Al-Waqa'i al-Misriyya, issue 83 continued (F), 9 April 2023). For receipts, the GS1 or the EGS coding system is used (article 2 of Decree 230).

Cancellation, rejection, and credit and debit notes

"The buyer may reject the invoice within the period that a decision of the Head of the Authority sets, counted from its issue date. The seller may also cancel the invoice within the period that a decision of the Head of the Authority sets from its issue date, after the buyer approves the cancellation" (article 43 of the Regulations; unofficial translation).

The Regulations fix neither period and leave both to a decision of the Head of the ETA, so in our view no fixed period should be hard-coded in the ERP.

All the controls of article 43 apply to credit and debit notes, the approved format, the codes and the signature among them. A note must show, among other data, the number and date of the original tax invoice, the amount of the reduction or addition, and a detailed statement of the tax reduced or added (article 11 of the executive regulations of the Value Added Tax Law issued by Law 67 of 2016, issued by Minister of Finance Decree 66 of 2017, Al-Waqa'i al-Misriyya, issue 55 continued (A), 7 March 2017).

The e-receipt and points of sale

The electronic receipt is issued for services rendered and goods sold to the final consumer (article 1 of Decree 230). The taxpayer must take the steps to register on the ETA's electronic tax invoice (electronic tax receipt) system, through self-registration or the competent tax office; achieve direct integration between that system and the ERP or the points of sale (POS) it has, or will later use; and provide the details of the system administrator (name, national ID, capacity and proof of it, telephone number and personal email). Receipts are sent in real time to the system's production environment from the date set for the taxpayer's phase, and the taxpayer cooperates with the ETA's specialists in the technical review needed to apply the system (article 2 of Decree 230).

The data of an electronic receipt include the serial number of the point-of-sale device and, for a returned receipt and for notes, the reference identification number (article 42 of the Regulations). Who must issue receipts, and the phases, are covered in Egypt's electronic receipt: who must issue it, when, and the penalty.

What we recommend

• Confirm the e-invoice and e-receipt mandate decisions that cover the business, and the date from which each applies, before starting the integration.
• Obtain the electronic signature certificate, appoint the system's delegate and set the users' powers, and protect the password and the cryptographic keys.
• Build the item-mapping file against the codes, under the unified coding system for invoices and GS1 or EGS for receipts, before issuing begins, not during it.
• Assign a named internal or external team to the integration, and run the full submission-and-verification cycle on a test environment before going live.
• Build a way to receive or poll for the system's notifications, so rejected or cancelled documents are caught before they are posted.

The firm's ERP Consulting Department assesses a taxpayer's ERP readiness for this integration, builds the item-mapping file against its codes, and oversees testing on a test environment before go-live.

Mahmoud Nassef, Founder Partner
Chartered Accountant, Ministry of Finance, Egypt

Member, Egyptian Society of Accountants & Auditors
Member, Egyptian Tax Society
Member, Egyptian Society for Public Finance and Taxation

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Disclaimer: This bulletin is prepared for general information on the legislation in force at the date of its publication. It does not constitute a professional opinion or tax or legal advice on any particular matter, and it should not be relied upon in place of advice based on an examination of the circumstances of each case. Nassef & Partners International accepts no responsibility for any action taken, or refrained from, in reliance on its contents. The positions stated remain subject to subsequent legislation and decisions.