eTIMS invoice in Kenya: what you issue when you bill the same fee every month

If you bill a monthly fee in Kenya, every one of those bills has to be issued and transmitted as an electronic tax invoice through eTIMS, and that holds whether or not you are registered for VAT. The Finance Act 2023 introduced Section 23A in the Tax Procedures Act, 2015, which requires every person in business to record each sale and to issue and transmit invoices through an electronic system prescribed by the Commissioner. The Kenya Revenue Authority provides eTIMS for that. The part that catches recurring billers is narrower and almost never mentioned: the eTIMS online portal is only for taxpayers supplying services only and issuing no more than ten invoices a month. At eleven monthly clients that solution is no longer the one for you, and you move to the eTIMS client or to system integration.

What follows was written from two Kenya Revenue Authority sources read on kra.go.ke on November 10, 2026: the What is eTIMS page, and the Guidelines to Taxpayers on eTIMS Onboarding. This is not tax or legal advice, and your own obligations depend on your registration with KRA.

Who has to be on eTIMS

All persons engaged in business are required to onboard eTIMS and issue electronic tax invoices. KRA spells out that this is not a VAT-only rule, and the reason is the expense side rather than the sales side: the law requires that for any person to claim their business expense, the expense must be supported by an electronic tax invoice as at 1 January 2024. Your customer's deduction depends on the invoice you issue.

That is why the list of who is in scope reads the way it does. KRA names persons in business whether or not registered for VAT, including persons in business not required to register for VAT, and gives as examples hospitals supplying medical services and schools supplying education services. It also names persons with income tax obligations including Monthly Rental Income Tax, Turnover Tax, and annual income tax for corporations, partnerships and individuals.

Read that list against who bills a recurring fee and the overlap is most of it. A school collecting term fees, a clinic on a monthly care plan, a landlord on Monthly Rental Income Tax, a gym on memberships. The supply may be VAT exempt and the obligation still applies.

Which eTIMS solution you are eligible for

KRA publishes eligibility criteria per solution, and they are criteria rather than suggestions. Two of them are counts, which is what makes this a question about your billing volume.

The ten-invoice limit is the one recurring billers hit first

The online portal is the easiest way in and the quickest to outgrow. Ten invoices a month is ten clients if you bill each one once. A tutoring centre with forty students, a physiotherapy practice with sixty monthly plans, a serviced-office provider with twenty desks: all three are past the limit from the first month, and none of them would discover that by reading about VAT.

The second criterion on that row matters too. The portal is for taxpayers strictly supplying services only. A gym that also sells supplements at the counter is not supplying services only, so the portal is out regardless of the count.

When the buyer issues the invoice instead of you

There is one case where the direction reverses. KRA states that where the supply is received from a small business enterprise whose annual turnover does not exceed five million shillings, the purchaser shall issue a tax invoice on their behalf. KRA has made a Buyer Initiated Invoicing Solution available for this, accessible on the eCitizen platform, and the same applies to small-scale farmers.

This cuts both ways in a recurring relationship. If you are the small supplier under the threshold, the business customer who pays you every month is the one who issues the invoice, so your records have to match a document you did not create. If you are the one buying from small suppliers on a monthly contract, issuing their invoices is now part of your own month-end.

The costs that do not need an eTIMS invoice

KRA lists business costs excluded from the requirement of being supported by an eTIMS invoice. The list is short and worth knowing before you chase a supplier for a document that was never needed.

• Emoluments, meaning salaries and wages.
• Imports.
• Air passenger ticketing.
• Investment allowances.
• Interest.
• Fees charged by financial institutions.
• Expenses subject to withholding tax that is a final tax.
• Services provided by a non-resident person without a permanent establishment in Kenya.

What this changes in a monthly collections cycle

The practical shift is that two documents now exist where most small operations kept one. There is the electronic tax invoice, which is the one that went through eTIMS and the one your customer's deduction rests on. And there is the reminder, which is the message that tells a person a fee is due and gets them to pay it. They are not substitutes and they are not issued at the same moment.

1. 1The fee becomes due on its date, and the electronic tax invoice is issued and transmitted through your eTIMS solution.
2. 2The reminder goes out carrying the amount, the due date and the reference the customer needs to pay.
3. 3The payment arrives and is recorded against that invoice, not against the customer as a balance.
4. 4A receipt goes back, so the customer has their own proof of the date the money moved.

Keeping step three per invoice rather than per customer is what keeps the two records reconcilable. A customer who pays eight of eleven months has eight settled invoices and three open ones, and a single running balance cannot tell you which three.

For the documents around that cycle, the tax invoice template covers the fields a tax invoice carries and the cash receipt is what goes back when a client pays over the counter.

Makatea sends each fee reminder on its date by WhatsApp and email, records the payment you register against the specific invoice it settles, and stops the reminders for that invoice once it is paid. It does not issue or transmit the electronic tax invoice and it does not move money, so eTIMS stays with your invoicing solution. Plans and the 14-day free trial without a card are on pricing.