The short answer
Scope depends on registration status, turnover and the kind of transactions a business makes, not on size alone, and a business can be out of scope as a seller while still needing the invoices it receives as a buyer. For agencies specifically, that plays out against how the trade already sells and to whom.
Who must comply for agencies
No inventory, but pass-through media and production costs that must be billed accurately and separated from the agency's own fee. That is the background against which who must comply has to work in this trade.
What invoicing actually looks like here
Invoice trade where the document often has to separate the agency fee from pass-through media spend, because the client treats the two differently and so does the tax position.
What the rules say
This page explains how a requirement generally works. It is not tax advice, and it cannot account for the specifics of any one business. For a position you intend to rely on, confirm with KRA directly or with a registered tax agent.
Tax rules in Kenya change with each Finance Act and with regulations made during the year. Before acting on any figure, deadline or threshold, check the current position on KRA's own website.
What we are not stating here. Some of the specific requirements relating to this topic have not yet been verified against their primary source by our reviewer, so they are withheld from this page rather than stated from memory. That means you will not find a threshold, rate, deadline or penalty figure below. For those, check KRA directly. Everything else on this page explains how the mechanism works and is not affected.
Why this question is harder than it looks
Businesses reasonably want a single number: a turnover figure above which this applies and below which it does not. The position is genuinely more layered than that, because it depends on registration status, on the kind of transactions the business makes, and on specific exclusions set out in regulations. A business can be below a threshold on one measure and still in scope because of what it sells or who it sells to.
The practical test most businesses can apply
Two questions get most businesses to the right answer quickly. First: do your customers ask you for documents they intend to use in their own tax position? If they do, the question is already live regardless of your size. Second: are your own suppliers issuing you electronic tax invoices? If they are, you are already inside this system as a buyer, and your records need to hold those invoices whether or not you issue any yourself.
The part nobody mentions
Being out of scope is not the same as having nothing to do. A business below every threshold still buys from suppliers who are in scope, still needs those purchase records to compute its own position, and still has customers who may ask. The useful posture is to understand where you sit rather than to establish that the question does not apply to you.
Where this goes wrong
- Pass-through costs absorbed instead of billed
- Client approvals delaying invoicing
- Withholding tax on professional fees
Common questions
Does a agency need to issue a tax invoice for every sale?
Invoice trade where the document often has to separate the agency fee from pass-through media spend, because the client treats the two differently and so does the tax position.
What usually goes wrong with records in a agency?
The recurring problems in this trade are pass-through costs absorbed instead of billed; client approvals delaying invoicing; withholding tax on professional fees; freelancer costs against project margins. Each of them shows up in the records before it shows up in the bank balance.
How should a agency keep stock records?
No inventory, but pass-through media and production costs that must be billed accurately and separated from the agency's own fee. Records that do not reflect that pattern will not tell you anything useful, whatever system produces them.
How do I know this information is current?
Tax rules in Kenya change with each Finance Act and with regulations made during the year. Before acting on any figure, deadline or threshold, check the current position on KRA's own website.
Sources
- officialeTIMS (Electronic Tax Invoice Management System) — Kenya Revenue Authority, checked 2026-09-18
- officialeTIMS taxpayer portal — Kenya Revenue Authority, checked 2026-09-18
- officialTax Procedures Act, 2015 (Act No. 29 of 2015) — National Council for Law Reporting (Kenya Law), checked 2026-09-18
- officialFinance Act, 2023 (Act No. 4 of 2023) — National Council for Law Reporting (Kenya Law), checked 2026-09-18
- officialTax Procedures (Electronic Tax Invoice) Regulations, 2024 — Kenya Gazette / Kenya Law, checked 2026-09-18
- officialValue Added Tax Act, 2013 (Act No. 35 of 2013) — National Council for Law Reporting (Kenya Law), checked 2026-09-18
- officialKenya Revenue Authority — Kenya Revenue Authority, checked 2026-09-18
- officialIncome Tax Act (Cap. 470) — National Council for Law Reporting (Kenya Law), checked 2026-09-18
Further reading on Veira
- eTIMS compliance checklist for SMEsA checklist version of the scope question
- eTIMS compliance checkerAnswers the scope question against your own details
Veira publishes this site. These are its own pages, offered because they cover the same ground, not as independent recommendations.