Can an e-Archive Invoice Be Issued to an e-Invoice Taxpayer?

 

Obligations Between e-Invoice and e-Archive Systems

 

Within the scope of electronic document systems, the rules regarding when e-Invoices and e-Archive Invoices must be used are clearly defined in the General Communiqués of the Tax Procedure Law. According to the regulations, if both the buyer and the seller are registered in the e-Invoice system, the transaction must be documented exclusively through an e-Invoice.
However, if one of the parties is not included in the e-Invoice system, issuing an e-Archive Invoice is allowed.

In short, the answer to the question “Can an e-Invoice taxpayer issue an e-Archive invoice?” is yes, provided that the counterparty is not an e-Invoice taxpayer.

 

Does an e-Archive Invoice Replace an e-Invoice?

 

In transactions where issuing an e-Invoice is mandatory, an e-Archive Invoice cannot replace an e-Invoice. If an e-Archive Invoice is mistakenly issued to an e-Invoice taxpayer, this constitutes non-compliance with the regulations and the transaction must be corrected. Otherwise, various administrative penalties may arise.

 

In Which Transactions Is an e-Archive Invoice Issued?

 

According to the invoice issuance threshold determined for 2025, sales amounting to 9,900 TRY and above must be documented with an e-Archive Invoice. However, this requirement applies only when the buyer is not an e-Invoice taxpayer.

 

What Happens If an e-Archive Invoice Is Issued to an e-Invoice Taxpayer?

An e-Archive Invoice issued to an e-Invoice taxpayer is not considered legally valid. In such cases, the seller must cancel the incorrect e-Archive Invoice and issue a proper e-Invoice instead.

Key points to consider in this process include:

• The correct e-Invoice must be issued within 7 days from the date of delivery of the goods or services.
• Failure to complete this process within the specified period results in an irregularity penalty.
• If an incorrectly issued e-Archive or paper invoice has already been recorded in the accounting records, it cannot be canceled and may lead to additional sanctions.
• An e-Invoice taxpayer acting as the buyer may request the cancellation of the e-Archive Invoice and the issuance of a new e-Invoice.

 

Are There Penalties for Issuing an e-Archive Invoice to an e-Invoice Taxpayer?

 

Although there are certain cases where issuing an e-Archive Invoice is allowed, transactions that do not comply with legal requirements are subject to penalties.
If an e-Archive Invoice is mistakenly issued to an e-Invoice taxpayer and the error is not corrected within the 7-day cancellation period, and the invoice is recorded in the accounts or included in the VAT Return, cancellation is no longer possible. In such cases, administrative fines are imposed in accordance with the Tax Procedure Law.

 

How Is an e-Archive Invoice Issued to an e-Invoice Taxpayer Canceled?

 

Canceling an incorrectly issued e-Archive Invoice may seem complicated at first, but the process is actually quite straightforward if the correct steps are followed:

• Within 7 days from the date the invoice becomes official, cancellation procedures can be completed through the Revenue Administration’s cancellation and objection portal.
• A qualified electronic signature or financial seal is required to complete the cancellation. If the signing tool is not available, the relevant software provided by the Revenue Administration must be downloaded and installed.
• Canceled e-Archive Invoices must be reported to the Revenue Administration by the evening of the following day after the cancellation.
• If the 7-day cancellation period has expired, it is recommended that the buyer issues a return invoice to the seller. After receiving the return invoice, the seller must issue a new and correct e-Invoice.