EFRIS Compliance Expands: What Ugandan Businesses Need to Know

Overview

Uganda's Electronic Fiscal Receipting and Invoicing Solution (EFRIS) is no longer just a VAT issue. With the expansion of the EFRIS requirements to businesses operating in designated sectors — including some businesses that are not VAT registered — the question is no longer simply "Are you VAT registered?" but "Does EFRIS apply to my business?"

This alert highlights the key changes, who is affected, the applicable exclusions and the practical steps businesses should take to stay compliant and avoid unnecessary exposure.

At a glance

The 12 designated sectors

EFRIS has been compulsory for VAT-registered businesses since 1 January 2021 — that has not changed. What is new is that General Notice No. 2218 of 2025 pulled in businesses from 12 specific sectors, including many that are not VAT-registered at all:

1. Wholesale and retail of fuel
2. Mining and quarrying
3. Manufacturing
4. Electricity, gas, steam and air-conditioning supply
5. Water supply, sewerage, waste management and remediation
6. Construction
7. Transportation and storage (other than land-based passenger transport services)
8. Accommodation and food service
9. Information, technology and communication
10. Real estate
11. Professional, scientific and technical services
12. Arts, entertainment and recreation

Do you need to use EFRIS?

Don't just ask "am I VAT-registered?" — that is no longer the full picture. Consider whether you are VAT registered, whether your business falls within one of the designated sectors, and whether any exclusion applies.

Worth remembering: the UGX 10 million and UGX 2,820,000 thresholds are specific to the 12 newly-covered sectors. They are not the same as the UGX 300 million threshold for compulsory VAT registration.

Common EFRIS compliance risks

• Not realising EFRIS applies to the business: sticking with manual invoices, using computerised e-invoicing systems that are not connected to EFRIS, or wrongly assuming that because you are not VAT-registered EFRIS does not apply.
• Records that do not add up: EFRIS transactions not matching VAT returns, income tax filings or the company's own books — especially where invoices are cancelled, amended or reversed.

What businesses should do now

• Check where you stand: review your VAT status, what your business does, your annual turnover, whether you fall in one of the 12 sectors, and whether the UGX 10 million exclusion applies.
• Tighten up your systems, checks and balances: make sure your EFRIS setup is configured correctly and reconciles with your accounts, bank statements and tax returns. Handle invoice amendments properly.
• Capture buyer details: ensure e-invoices and e-receipts capture the buyer's Business Registration Number (BRN), National Identification Number (NIN) or Taxpayer Identification Number (TIN), as applicable.

Conclusion

EFRIS compliance is no longer a VAT-only concern. If your business operates in one of the 12 gazetted sectors, it is time to check where you stand — based on what you do, how much you turn over, and whether any exclusion applies — and to make sure your invoicing is properly set up. Keep monitoring your turnover and activities as they change so you stay compliant and avoid unnecessary penalties.

Being required to use EFRIS does not by itself mean that a taxpayer is required to register for VAT. EFRIS and VAT registration are separate compliance obligations, although the two may apply simultaneously.

Download the full alert below for the complete analysis.

Prepared by TASLAF Advocates — Tax Practice.