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04/06/2026Beware: Double VAT
The new electronic invoicing labeling system is already in effect. One careless signature on a "red" invoice, and a company pays VAT twice. We break down the risk mechanism and protection methods.
Legal Basis: Resolution of the Cabinet of Ministers No. 830 dated 12/26/2025
⚠ Important for every VAT payer
With the entry into force of the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 830 dated December 26, 2025, the electronic document management system has received mandatory risk level labeling. Lack of knowledge of these rules is already leading to real tax losses for enterprises across the country.
What is Resolution No. 830 and why was it adopted?
Resolution No. 830 establishes a mechanism for determining risk levels when issuing and receiving electronic invoices (E-Invoices). Its goal is to reduce the share of fictitious transactions in the VAT system and increase the transparency of tax turnover.
In practice, this means the following: every E-Invoice passing through the My3.soliq.uz platform now automatically receives one of the risk levels. The most significant for the taxpayer are "red" (high risk) and "green" (low risk).
For accountants and company managers, this innovation means the need to revise the daily routine for processing incoming documents.
E-Invoice Color Labeling: What is the difference?
"Red" Invoice
An invoice from a counterparty whose transactions the system has recognized as risky. Accepting such a document deprives you of the right to a VAT tax credit.
"Green" Invoice
A standard document with a confirmed tax history of the counterparty. VAT credit for such operations is accepted in full.
There are intermediate levels between these extreme values, but it is the "red" status that carries direct financial consequences.
Why is signing a "red" invoice a direct loss?
This is a key question that entrepreneurs ask us. The loss mechanism works as follows. According to Article 267, Part 2 of the Tax Code of the Republic of Uzbekistan, signing an incoming E-Invoice with a high risk level entails three consecutive negative consequences:
Loss of the right to VAT credit
The VAT amount indicated in the "red" invoice is not accepted for credit. You have already paid VAT as part of the cost of the goods or services — and you will not be able to get it back.
Actual double payment of VAT
Since the credit is not accepted, you are obliged to additionally pay the same amount of VAT to the budget. That is, the company pays the same tax twice: once to the counterparty, and the second time directly to the state.
Prohibition on deduction when calculating income tax
The "extra" amount of VAT cannot be included in the company's expenses, which further increases the tax burden when calculating corporate income tax.
This is exactly how much one careless signature costs
A company that accepts a "red" invoice pays VAT twice — and cannot either offset or write off this amount as an expense.
Why can your own invoices become "red"?
Risk exists not only on the part of incoming documents. If your outgoing E-Invoices receive a "high risk" status, this signals problems in your company to counterparties — and they will reject your invoices.
Chapter Two of Resolution No. 830 contains an exhaustive list of criteria for assigning high risk. Among the most common:
- ● Inconsistencies in financial or tax reporting
- ● Negative history of tax payments
- ● Technical discrepancies in the "Autocameral" program
- ● Low reliability rating of the business entity
- ● Frequent changes of founders or managers
- ● Systematic submission of updated tax reports
Each of these factors reduces your overall rating in the system. Regular audit of these indicators allows for timely elimination of the grounds for labeling.
Practical Recommendations: How to protect the company
1. Establish a routine for monitoring incoming E-Invoices
Do not wait until the end of the month. Check the status of incoming invoices in the personal account on the My3.soliq.uz portal every 3–4 business days. This will allow for the timely detection of "red" invoices before they are signed.
2. Reject "red" invoices without exception
If an incoming E-Invoice has a high risk level — do not sign it under any circumstances. Contact the counterparty and demand the elimination of the reasons for labeling. Only after receiving "green" status can the document be accepted for accounting.
3. Monitor the share of risky transactions
According to Resolution No. 830, the share of E-Invoices with a high risk level in your total volume of issued documents must not exceed 10% for the reporting period. Exceeding this threshold automatically affects your reliability rating.
Create an internal checklist for the accountant
Before signing any incoming E-Invoice, the employee must check three points:
- ✓ Document status on the My3.soliq.uz portal (green / red)
- ✓ Compliance of the counterparty's details in the system and the contract
- ✓ Availability of supporting documents (act, invoice, contract)
This simple routine takes no more than 5 minutes but protects the company from losses.
Frequently Asked Questions
Can the assignment of "red" status to our invoices be appealed?
Yes. Resolution No. 830 provides for an appeal mechanism. To do this, it is necessary to eliminate the reasons for the high risk assignment (correct reports, pay off debts, etc.) and submit a corresponding application via the My3.soliq.uz personal account.
Does the resolution apply to turnover tax payers?
The direct financial consequences regarding the loss of VAT credit apply only to VAT payers. However, counterparties working on turnover tax may also face their invoices being rejected by VAT-paying partners.
How often does the system review risk levels?
Labeling is updated automatically as new data arrives from the tax system. That is why it is recommended to check statuses at least once every 3–4 days, and not just before closing the period.
What to do if the counterparty refuses to fix a "red" invoice?
In this situation, you have two options: either reject the invoice and decline the deal, or consciously accept the tax losses. From the point of view of financial security of the business, the first option is almost always preferable.