ZRA Smart Invoice: what Zambian businesses need to know

If you run a registered business in Zambia, you must issue your invoices through the Zambia Revenue Authority Smart Invoice system. This article explains what the system is, who it applies to, and what your options are. It is written for business owners and for the people who look after their software.

Everything below comes from ZRA’s own published material. Tax rules change. Confirm the current position with ZRA before you make a decision.

What Smart Invoice is

ZRA describes Smart Invoice as a software-based electronic invoicing solution that taxpayers use to manage invoices and stock data transmitted to ZRA. Each transaction receives a fiscal signature. Each invoice carries a QR code, so a customer can check that the invoice is genuine.

Smart Invoice replaced the Electronic Fiscal Devices, or EFDs. ZRA states the difference plainly: EFDs were physical gadgets, while Smart Invoice is software. EFDs covered only Value Added Tax and the Insurance Premium Levy. Smart Invoice covers more tax types, including VAT, Turnover Tax, Income Tax, Rental Income Tax, Local Excise Duty on coal and electricity, the Insurance Premium Levy and the Tourism Levy. Smart Invoice also includes stock management.

Taxpayers who used EFDs had to move to Smart Invoice and return their devices to ZRA for deregistration.

The legal basis

Two instruments created the system, both in force from 1 January 2024: the Value Added Tax (Amendment) Act No. 27 of 2023, and the Value Added Tax (Electronic Invoicing System) Regulations, Statutory Instrument No. 58 of 2023. The regulations revoked the Electronic Fiscal Devices Regulations of 2020. On the income tax side, the Income Tax (Amendment) Act No. 22 of 2023 added section 55B(1), which requires taxpayers to use an electronic invoicing system to record sales.

Section 7A(1) of the VAT Act now reads that a taxable supplier shall use an electronic invoicing system to record each sale or transaction. Section 7A(2) allows the Commissioner-General to approve another document, device or system for a category of taxpayers. That approval is not automatic. If you want to keep using manual invoices or an unintegrated accounting package, you must be granted approval.

ZRA required all VAT taxpayers to register and use Smart Invoice no later than 30 September 2024, and stated that standard penalties applied from 1 October 2024.

Who must comply

There is no turnover threshold. ZRA states that a business is eligible if it is registered for any of these: Value Added Tax, Turnover Tax, the Insurance Premium Levy, the Tourism Levy, Excise on coal and electricity, Rental Tax or Income Tax. In practice, that is most registered businesses.

If you already run an accounting package or an ERP that ZRA approved in the past, that is not enough on its own. ZRA states that such taxpayers must integrate their systems with Smart Invoice to meet the legal requirement.

The four ways to comply

ZRA offers four invoicing solutions. Pick the one that matches how you actually sell.

1. Smart Invoice Desktop and Tablet Application

A Windows application for a desktop, laptop or tablet running Windows 10 or higher. ZRA describes it as suitable for all taxpayers except those with accounting packages, and lists it for small, medium and large taxpayers.

2. Smart Invoice Mobile Application

An Android application for a phone, tablet or PDA running Android 8 or higher. ZRA describes it as for Turnover Tax taxpayers, not for taxpayers registered for VAT. Note that ZRA’s own pages are not consistent on whether Rental Tax is included here, so confirm this point directly with ZRA.

3. Online Smart Invoice

A web portal you use in a browser. ZRA describes it as suitable for taxpayers in the service industry who issue few invoices. It needs a working internet connection.

4. Certified or approved invoicing systems

This is your own accounting package or ERP, integrated with Smart Invoice and approved by ZRA. The integration runs through an interface called the Virtual Sales Data Controller, or VSDC. This is the option for a business that already runs software it does not want to abandon.

On cost, ZRA states that the mobile, desktop and online packages are free to taxpayers, but that taxpayers who need to integrate an accounting package carry the integration cost themselves.

What integration actually means

If you choose the fourth option, here is the shape of the work. ZRA publishes a VSDC API Specification Document that sets it out.

• The VSDC runs on your server. ZRA gives you a WAR or JAR package that you deploy yourself. It needs Java and a servlet container such as Apache Tomcat or Eclipse Jetty. Your software then talks to it over local HTTP.
• The interface is a plain REST API. Requests and responses are JSON over HTTP, so you can call it from any language. Your existing stack does not have to change.
• You apply and wait for approval. You register on the Smart Invoice taxpayer portal, apply for the VSDC service, go through technical and administrative verification, and then download the VSDC package from the portal under Device Management.
• There are two environments. ZRA runs a sandbox for testing and a production environment for live trading. You sign up in both. You test against the sandbox, pass user acceptance testing, then go live.
• Each device is initialised once. An initialisation call sends your TPIN, branch ID and device serial number, all issued by ZRA. It returns security keys and configuration that your installation stores.
• The API covers more than sales. The service groups include device initialisation, code data, branch information, item information, import information linked to the customs system, sales, purchases and stock.

ZRA also publishes supporting material for developers: a VSDC sign-up guide, the item classification codes, and a developer self-check list. Start from the Integrations section of the ZRA website at zra.org.zm.

You can build in-house, or use a vendor

ZRA recognises two routes to integration: in-house development, and vendor development. Either way, the finished system must be approved. ZRA maintains and publishes a list of accredited software vendors and their approved invoicing systems, with version numbers.

That version column matters. Approval attaches to a specific version of a specific system. If you change your invoicing software substantially, plan for the approval work that follows.

What this means for your existing software

Most businesses we speak to already have something: a stock system, a rental platform, a job-card system, a point of sale. The question is never whether to throw it away. The question is where the invoice is created and what happens straight after.

Integration work usually touches four things. Your item catalogue must map to ZRA’s classification codes. Your invoice creation step must call the VSDC and store what comes back. Your printed and emailed invoices must show the fiscal details and the QR code. And your system must handle the case where the call fails, because a sale still has to complete when the network does not.

That last point is the one teams underestimate. A shop cannot stop trading because an API timed out. Design the queue and the retry before you design the happy path.

How a software partner helps

A good partner does the unglamorous parts. Reading the specification properly. Mapping your product list to the classification codes. Building against the sandbox and working through the checklist before you submit. Handling the offline case and the three-day upload window. Keeping your invoice layouts correct. And staying available afterwards, because the specification is versioned and it moves.

If your accounting package came from a vendor, ask them first whether they are on the accredited list and which version is approved. If your software is your own, or your vendor cannot help, that is where a development firm comes in.

Before you act

The details in this article were correct at the time of writing, and they come from ZRA’s published guidance. Requirements, forms and specification versions change. Confirm your own position with ZRA, or with a tax adviser, before you commit money to a solution. ZRA gives smartinvoice@zra.org.zm as the contact address for integration questions.