Unfiscalised sales on a Kenyan VAT return
How a Kenyan business uses the list of unfiscalised invoices, credit notes and till sales to clear eTIMS gaps before its VAT return is due.
By Achekam · · 4 min read · For Running a business businesses in Kenya
The VAT return is the point where two records of your sales meet. One is your own books. The other is what KRA's eTIMS system has seen. If an invoice reached your books but never reached eTIMS, the two will not agree, and the gap is yours to explain, along with a penalty for failing to e-invoice in the first place.
Finding those gaps is much easier before the return than after it. In Achekam, the VAT return itself shows you where to look. This article explains what that list contains, what it does and does not do, and a routine for clearing it before the 20th.
The list on the VAT return
When you prepare a Kenyan VAT return in Achekam, it lists the period's invoices, credit notes and till sales that are not fiscalised. "Fiscalised" here means that the document has been through eTIMS and its eTIMS details have been recorded and verified in Achekam.
Each line on that list is a question to answer before you file:
- Was this document issued on eTIMS, and the details simply never recorded in Achekam?
- Was it never issued on eTIMS at all?
- Should it exist in the period at all, or is it a draft, a duplicate or an error?
KRA pre-fills parts of the VAT return from its own data. Its page on the VAT auto-populated return explains how returns are pre-filled from iTax, TIMS/eTIMS and customs data, what VAT-registered businesses must do to confirm them, and how to check that an invoice is TIMS/eTIMS compliant. A sale missing from eTIMS is a sale missing from that pre-filled picture.
A warning, not a block
Achekam does not stop you filing while the list has lines on it. There can be good reasons a document is on the list at the moment you are working, and the decision to file belongs to the business, not the software. It does mean the list only helps if someone reads it. Treat an unread list as an unanswered question about your return.
What a document says until it is fiscalised
Achekam prints eTIMS identifiers on an invoice only once the invoice is fiscalised. Until then, the document says it is not yet fiscalised. If a customer receives an invoice with that wording, it is a sign that the invoice has not completed the eTIMS step on your side, and the customer may ask for a proper eTIMS invoice before paying or claiming input VAT on it.
Recording the eTIMS details
Achekam does not yet transmit invoices to eTIMS itself. A Kenyan business issues the invoice through another eTIMS channel (eTIMS Lite, eTIMS Client or a third-party integrator) and records three things from it in Achekam:
- the control-unit invoice number;
- the internal data;
- the receipt signature.
A second person verifies them. Only then does the invoice count as fiscalised and leave the list. Often a line turns out to be a document that was issued on eTIMS but whose details were never recorded, or were recorded and not yet verified. Such lines are quick to clear, as long as the eTIMS copy can be found.
Credit notes follow the original
Credit notes need particular care. In eTIMS, a credit note comes from the same solution as the original invoice. If the invoice went through eTIMS Client, the credit note should too. An unfiscalised credit note on the list usually means a refund or price adjustment was recorded in the books but not reversed on eTIMS, which leaves eTIMS showing more sales than you made. Which transactions need an eTIMS document in the first place is set out in which Kenyan transactions need an eTIMS invoice.
Clearing the list before the 20th
A Kenyan VAT return is due by the 20th day after the end of the month. Leave yourself time between closing the month and that date:
| Step | When | Who |
|---|---|---|
| Close the month's sales and credit notes | First days of the month | Bookkeeper |
| Open the VAT return and read the unfiscalised list | Soon after | Bookkeeper |
| Record missing eTIMS details from the eTIMS copies | Same week | Bookkeeper |
| Verify the recorded details | Same week | A second person |
| Issue on eTIMS anything never issued, and note why it was late | Before the return | Finance lead |
| Correct drafts, duplicates and errors in the books | Before the return | Bookkeeper |
| File the return on iTax | Before the 20th | Person with the filing permission |
Till sales may appear on the list too. If you run Achekam's till, the eTIMS check belongs at the end of each trading day rather than the end of the month; see fiscalising Kenyan till sales through eTIMS.
What failing to e-invoice costs
Under the Finance Act 2026, failing to use e-invoicing, e-filing or e-payment in Kenya costs the higher of 5% of the tax or KES 100,000 for a company, or KES 10,000 for an individual. For a company, the minimum alone is a large price for a missed step that the list would have shown you.
The penalty is about the e-invoicing failure itself. It sits beside, not instead of, whatever follows when KRA compares its eTIMS data with your return and finds sales missing. A document issued late on eTIMS, with a note of why, leaves you in a better position than one that never appears there at all.
That is the case for reading the list every month, not just when a return is due: each line cleared promptly is one less to explain later. To put the 20th and the rest of the month's dates on one page, see a Kenyan business's tax calendar.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
