China — Golden Tax Phase IV and e-fapiao

In China the invoice (fapiao, 发票) is a state-controlled tax document: without a valid fapiao, the buyer can neither deduct VAT nor book the expense. The State Taxation Administration (STA, 国家税务总局) has shifted this regime to the fully digitalised e-fapiao (全面数字化的电子发票, shortened to 全电发票) issued on its national service platform, underpinned by Golden Tax System Phase IV (金税四期). The pilot began in late 2021 and nationwide generalisation completed across 2024-2025.

Quick facts

Regulator: State Taxation Administration (STA — 国家税务总局), with its provincial and municipal tax bureaus. The system sits under the Golden Tax System (金税工程), now in Phase IV.
B2G status: The fapiao is mandatory for any deductible transaction, public sector included; there is no separate B2G platform like Chorus Pro — the channel is the same as B2B.
B2B status: State-controlled issuance via the national platform. The fully digitalised e-fapiao (全电发票) is generalised nationwide (2024-2025); every fapiao remains issued/allocated under STA control. Status: in force.
Legal basis: Law on the Administration of Tax Collection (税收征收管理法); Measures for the Administration of Invoices of the PRC (中华人民共和国发票管理办法, revised 2023); STA announcements (公告) framing the pilot then the rollout of the 全电发票.
Format: National proprietary format (OFD — Open Fixed-layout Document — with attached PDF/XML). No UBL/EN 16931, no PEPPOL. The digital fapiao no longer has a paper carrier or a physical red seal.
Signature: No issuer signature in the European sense: authenticity comes from issuance on the state platform and the fapiao number allocated by the STA, replacing the former anti-counterfeit control (防伪税控).
Identifier: 18-character Unified Social Credit Code (统一社会信用代码, USCC) for businesses; each fapiao carries a fapiao number (发票号码) allocated by the STA.
Portal: STA's national electronic invoice service platform (电子发票服务平台), reached via the electronic tax bureau (电子税务局). Legacy hardware providers: Baiwang (百望), Aisino/航天信息.

Regulatory timeline

1994 — Golden Tax System launched (金税工程). National VAT-control programme born of the 1994 tax reform. Phases I to III progressively deploy anti-fraud VAT-invoice control (防伪税控).
2015-2016 — general e-fapiao. The STA authorises electronic issuance of the ordinary VAT fapiao (增值税普通发票), first in e-commerce and telecoms.
2016-2020 — Golden Tax Phase III nationalised. Provincial systems are unified, forming the basis for mass cross-checking between returns and fapiao.
September 2020 — electronic special VAT fapiao (电子专用发票). Pilot for electronic issuance of the special fapiao (the deduction-bearing one), first for new taxpayers in selected regions.
December 2021 — fully digitalised fapiao pilot (全电发票). Launched in Guangdong (excluding Shenzhen), Inner Mongolia and Shanghai, on the new national service platform, with no hardware or control disk.
2022-2023 — provincial expansion. The STA progressively extends the 全电发票 pilot to a growing set of provinces and cities, for both issuance and receipt.
2023 — revision of the Invoice Administration Measures. The regulation (发票管理办法) is revised to fully recognise the e-fapiao and the digital fapiao as equivalent to paper.
2024-2025 — nationwide generalisation. The fully digitalised fapiao becomes available and used across the whole country; Golden Tax Phase IV (金税四期) consolidates entity-level cross-checking (以数治税, ‘governing tax through data’).

Technical schema

China does not use a European semantic format (UBL, CII, EN 16931) nor the PEPPOL network. The fully digitalised fapiao is an STA-proprietary object:

Carrier: an OFD file (Open Fixed-layout Document, GB/T 33190), with PDF and XML variants generated by the platform. The OFD is the authoritative ‘original’.
Issuer/recipient identifier: 18-character Unified Social Credit Code (统一社会信用代码, USCC).
Fapiao number: a 20-digit number (发票号码) allocated by the STA platform at issuance — the paper-era pairing of ‘fapiao code + number’ is gone.
Types: special VAT fapiao (增值税专用发票, deduction-bearing) and ordinary fapiao (增值税普通发票, not deduction-bearing).
Authenticity: guaranteed by issuance on the state platform, not by an issuer signature. The legacy hardware (the 防伪税控 control disk supplied via Baiwang/Aisino) disappears for the 全电发票.

Schematic example of a digital-fapiao header (simplified, non-normative XML view):

<Fapiao type="special">
  <FapiaoNumber>24312000000012345678</FapiaoNumber>
  <IssueDate>2026-05-16</IssueDate>
  <Seller uscc="91440300MA5XXXXXXX">深圳示范科技有限公司</Seller>
  <Buyer uscc="91310000MA1FXXXXXX">上海客户示范有限公司</Buyer>
  <Amount currency="CNY">10000.00</Amount>
  <VatRate>0.13</VatRate>
  <VatAmount currency="CNY">1300.00</VatAmount>
</Fapiao>

The real format is the STA-standardised OFD/XML; this block only illustrates the load-bearing fields.

Submission flow

The Chinese model is state-controlled issuance (often labelled ‘clearance’ by vendors), distinct from the PEPPOL four-corner model. Control is centralised on the STA platform:

1. Enablement. The business registers on the electronic tax bureau (电子税务局) and receives an issuance quota (额度) computed by the STA from its risk profile, as a total amount rather than a paper-fapiao count.
2. Issuance. The seller enters the fapiao directly on the national platform (电子发票服务平台) or via a connected ERP; the platform allocates the fapiao number in real time — this is the state ‘clearance’ step.
3. Delivery. The digital fapiao (OFD/PDF/XML) is made available to the buyer: a tile in their tax account, e-mail, or QR code. No paper carrier required.
4. Deduction and cross-checking. The buyer pulls the fapiao into their digital ‘tax account’ (税务数字账户) to deduct VAT; the STA continuously cross-checks issuance against deduction (Phase IV, 以数治税).

Unlike an interoperability network, there is no mandatory third-party Access Point: the STA is both the authority and the central operator of the flow.

Validation

Check a fapiao's status and authenticity against official sources:

Note: to confirm case by case, access is from mainland China and the issuance service portal (电子税务局) is province-specific; there is no international interoperability directory.

Common pitfalls

Confusing the fapiao with a commercial invoice. The fapiao is the official tax voucher issued under STA control; a commercial invoice has no value for VAT deduction. Issuing one does not replace the other.
Assuming a UBL/PEPPOL-style format. China is not on PEPPOL or EN 16931; the format is the national OFD. European ‘e-invoicing’ connectors do not plug in as-is.
Mixing up special and ordinary fapiao. Only the special VAT fapiao (增值税专用发票) confers deduction rights. Receiving an ordinary fapiao for a deductible purchase loses the input VAT.
Ignoring the issuance quota (额度). With the 全电发票, the STA controls an amount ceiling, adjusted dynamically by risk. Unanticipated volume growth can block issuance.
Expecting an issuer e-signature. Authenticity comes from the state platform, not a seller certificate; looking for a ‘signature’ in the European sense is a category error.
Underestimating Golden Tax Phase IV. Entity-level cross-checking (以数治税) links fapiao, returns and banking data; mismatches trigger audits faster than in the Phase III era.

Foundations

Standards

Flagship messages

Tools