What every invoice must show
- An RRA-certified EBM/EIS invoice number, which runs SDC identifier then receipt number — for example SDC004002498/6795. A handwritten or word-processed invoice is not a tax invoice in Rwanda; handwriting in duplicate is allowed only while the machine is down, and the certified receipt must be issued and kept with it once the machine is back.
- The buyer's TIN whenever the buyer is a business. For a sale to a final consumer the field is left empty and the system writes 999999999.
- The real name of the goods or services. A VAT-registered seller must show the true item name and the tax rate applied to it; a non-VAT seller must show the true item name and the price. Vague descriptions are a named EIS offence, and so is applying a tax rate RRA has not prescribed.
- VAT at 18% shown as its own amount, alongside the machine's own data — SDC identifier, receipt signature, date and time stamps and the machine registration code, all of which the certified system prints for you.
Numbering, keeping and correcting invoices
Books, records and documents must be kept in one of the official languages, and RRA may require a translation (art. 7 of Law nº 020/2023). They must be kept for 10 years from 1 January following the fiscal year, at your premises or another place in Rwanda, and may be kept electronically as the Commissioner General directs (art. 15). How much you must keep depends on turnover: from FRW 2,000,000 to 12,000,000 only sales records, from FRW 12,000,000 to 20,000,000 also daily purchases, financial transactions, tax liability and tax withheld, and above FRW 20,000,000 also assets, liabilities, expenses, closing stock and controlled transactions (arts 13-14).
Amounts on VAT documents are in Rwandan francs, and foreign-currency amounts are converted at the National Bank of Rwanda rate on the relevant date (art. 32 of the VAT law). When goods are returned, damaged or repriced, a VAT-registered seller keeps the original invoice together with an explanatory document cancelling it (arts 21-22 of the VAT law).
Not issuing an EIS invoice costs a business that is not VAT-registered a fine of twice the value of the transaction, and an under-valued invoice twice the under-valued amount, both doubled if repeated within two years (art. 84). A VAT-registered seller who sells without an electronic invoice is fined ten times the evaded VAT, twenty times on a repeat within two years (art. 88). Breaching the user obligations in art. 18 costs FRW 200,000, rising to FRW 400,000 on a repeat (art. 89). Failing to keep books under arts 13-15 doubles the fixed fine.
Electronic invoicing in Rwanda
Mandatory, and not only for VAT. Law nº 020/2023 on tax procedures requires any person carrying out any taxable activity to issue an invoice generated by an electronic invoicing system certified by the tax administration. RRA puts it as 'EBM for all': every registered taxpayer must have and use one at each of their sales locations, VAT-registered or not. RRA now calls the system EIS, Electronic Invoicing System; everyone in Rwanda still says EBM. The current version is EBM 2.1 and every flavour is free — EBM 2.1 Client Software for Windows 10.0.17 or Android 8 and above, with iOS and macOS not supported; an Android mobile app for micro and small non-VAT taxpayers under FRW 20 million turnover; Online EBM, a browser form for micro and small service-only businesses under FRW 20 million; and VSDC or OSDC if you want your own billing software certified and connected. Apply at myrra.rra.gov.rw. The user obligations that get enforced: issue an invoice to every buyer whether or not they ask for one, show the real name of the goods, tell RRA within six hours if the system fails, and do not delete invoices without sound grounds. Penalties: FRW 200,000 for a first offence of having no EIS where one is required or breaching a user obligation, FRW 400,000 on a repeat within two years. Having a working machine and not issuing the invoice costs ten times the evaded VAT for a VAT taxpayer and twenty times on a repeat; for a non-VAT taxpayer, twice the value of the transaction and four times on a repeat. Undervaluing an invoice carries the same multiples. RRA can also close the business for up to 30 days, bar it from public tenders, withdraw the business register entry and publish the name in national media. For the buyer this is the whole point: without an EBM invoice the purchase is not deductible. The income tax annexures only accept purchases and operating expenses 'supported by EBM/DMC/WOP' — EBM invoice, customs declaration or a declared withholding — and everything else has to be entered as it happens under Daily Capture of Uncontrolled Expenses. Consumers are paid to enforce it too: register on *800# under EBM Services and a final consumer gets 10% of the VAT on each EBM invoice carrying their mobile number, paid to mobile money quarterly.