Reconciling client books to eTIMS schedules

How a firm reconciles a Kenyan client's ledger to its TIMS/eTIMS schedules before the annual return, now that KRA validates returns against that data.

By Achekam · 11 October 2026 · 5 min read · For Accountants & audit firms in Kenya

For years, a Kenyan company's income tax return was built from its books and the auditors' adjustments. KRA might later compare it with other data, but the return itself started from the ledger. That order has changed. KRA now checks the return against what its own systems already know, and a figure the systems cannot see is a figure the client may have to defend.

For the firm preparing the return, the reconciliation between the client's ledger and its TIMS/eTIMS schedules has moved from a nice-to-have to the first job of the engagement. This article explains why, how to get the schedules, how to match them, and how to report the differences before anything is filed.

Why the reconciliation now matters

KRA says that from 1 January 2026 it validates the income and expenses declared in individual and non-individual income tax returns against TIMS/eTIMS data, withholding income tax data and customs import records. According to KRA's public notice of 10/11/2025, the validation applies when returns for the 2025 year of income or accounting period are submitted.

The same notice says all declared income and expenses must be supported by a valid electronic tax invoice, correctly transmitted with the buyer's PIN where applicable. That is subject to the exceptions in section 23A of the Tax Procedures Act and the Tax Procedures (Electronic Tax Invoice) Regulations, 2024. A later notice, dated 08/06/2026, says that from the 2026 year of income all declared income and expenses must be supported by valid electronic tax invoices generated and transmitted through eTIMS/TIMS.

KRA's notice on validating income and expenses in income tax returns sets out the checks against TIMS/eTIMS, withholding tax and customs records. How the validation works from the return's side is covered in income tax validation against eTIMS.

Getting the schedules

KRA encourages taxpayers to request TIMS/eTIMS schedules of their annual income and expenses from their designated account managers. For a firm, that means a request goes from the client to its KRA account manager early in the engagement, not in the week before filing.

Ask the client for:

• the TIMS/eTIMS schedule of sales for the year;
• the TIMS/eTIMS schedule of purchases for the year;
• the withholding certificates issued against the client in the year; and
• the customs entries for imports, if the client imports.

Matching sales by invoice date

The sales side has a trap. KRA says that for VAT, sales are pre-populated by invoice date, not by transmission date, so all sales for a period must be declared whether or not they were transmitted by the filing date. KRA also says a taxpayer cannot reduce the pre-populated sales in the VAT return below what was transmitted through TIMS/eTIMS, but can adjust them upwards, for example for sales made outside TIMS/eTIMS.

For the annual reconciliation, match on invoice date as well. Late-transmitted invoices otherwise appear to fall in the wrong year. Then sort the differences:

Purchases, withholding and imports

Expenses deserve the closest look, because each one declared needs the support of a valid electronic tax invoice from the supplier, subject to the exceptions. Go through the purchases schedule against the expense accounts and list:

• expenses in the ledger that do not appear in the purchases schedule;
• invoices in the schedule that are missing the client's PIN; and
• items within the exceptions, such as imports, which should be traced to customs entries instead.

Withholding certificates are matched against the income they relate to; reconciling withholding tax certificates covers that in detail.

Bringing the ledger into Achekam

The client's books and Achekam meet at the ledger. A firm can upload a general ledger in the layout the client's accounting package exports. It reads CSV, .xlsx and .xls files. Achekam adds the ledger up into a trial balance and checks every printed account total against its own sum. Differences are named and never quietly fixed, so a ledger export that does not add up is caught before the reconciliation starts.

Achekam then suggests where each trial balance line belongs, drawing on the file's own mapping column, earlier mappings, AI or keyword rules. No suggestion becomes an approved mapping until a person approves it. Without an AI key, keyword rules are used and labelled as such. With the revenue and expense lines mapped, the reconciliation can be done account by account against the eTIMS schedules.

For VAT, Achekam computes a client's Kenyan VAT return from imported sales and purchase schedules, because the client's own books are not linked to it. That makes the schedules the common starting point for both the VAT work and the annual reconciliation. The matching of ledger lines to eTIMS lines is the firm's own work; Achekam gives it a ledger that adds up and a mapped trial balance to work from.

Reporting differences to the client before filing

Send the client a short reconciliation report before the return is finalised:

1. Total sales per ledger and per eTIMS schedule, with each difference explained.
2. Expenses without a matching valid electronic tax invoice, with amounts.
3. Any invoices missing the client's PIN, by supplier.
4. Proposed treatment of each item, and what the client needs to do, such as asking suppliers to correct invoices.
5. A deadline for the client's response that leaves time before filing.

The report is also the evidence that the firm raised the issues, which matters if a disallowed expense later becomes a dispute. The completed reconciliation then goes into the return file; see preparing the IT2C pack.

Make it the first task

Ask for the eTIMS schedules in the engagement's opening request, alongside the trial balance. A reconciliation started early leaves time for suppliers to fix their invoices; one started at the deadline leaves only adjustments.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.