E‑invoicing in Bahrain

Bahrain does not currently have e-invoicing mandates in place for business-to-government (B2G), business-to-business (B2B), or business-to-consumer (B2C) transactions. Though Bahrain is preparing a mandatory e‑invoicing regime, effective dates and full rules have not yet been published.

The National Bureau for Revenue (NBR) is the tax authority for VAT and the lead body in developing the e‑invoicing framework in Bahrain. Expectations are that large taxpayers will be required to comply with any mandate first and that structured invoice data (likely XML/JSON) will need to be submitted to the NBR or via a central portal.

Though businesses are currently allowed to issue electronic‑format invoices in PDF and without prior NBR approval, they should monitor NBR developments on its e-invoicing framework and be ready to adopt e‑invoice formats once announced.

Under Bahrain VAT law, irrespective of e‑invoicing, a VAT‑registered person must issue a tax invoice for taxable supplies. It must include:

• Label “VAT Invoice” (or “Tax Invoice”)

• Supplier’s name and address

• Supplier’s VAT account number

• Customer’s name and address

• Sequential VAT invoice number

• Date of issue, date of supply (if different)

• Description of goods/services, quantity, unit price (in Bahraini dinars)

• Value excluding VAT, VAT rate(s), VAT amount per line if differing rates, total inclusive of VAT

• Where foreign currency used, exchange rate applied

• If supply exempt: a clear statement

VAT‑registered persons must keep records and invoices for audit/inspection by the NBR.

Although the full e‑invoicing mandate is not yet in force, businesses should still be aware of the VAT law penalties in Bahrain, which apply broadly to invoicing, record‑keeping, and other VAT obligations. These will likely apply (and possibly be expanded) when the e‑invoicing regime becomes mandatory. Once the mandatory e‑invoicing rules are in place (especially if they require structured submission/real‑time reporting), failure to comply with those e‑invoice issuance or submission requirements will likely be treated as a breach of VAT law/invoice‑issuance rules, and therefore subject to the existing administrative or criminal penalty regimes (or possibly new enhanced fines).