
On 15 May 2026, the Minister of Finance, Economic Development and Investment Promotion issued the Income Tax (Fiscalised Recording of Fuel Transactions) Regulations, 2026 (SI 88 of 2026), in terms of section 90 as read with section 80DD of the Income Tax Act. The Regulations clarify the implementation of Fuel Fiscal Devices, introduced into the definition of a fiscal device through Finance Act No. 7 of 2025.
What is a Fuel Fiscal Device?
Section 2 of the Regulations defines a Fuel Fiscal Device as specialised hardware, software, electronic systems, or a Virtual Fiscal Device capable of integrating with fuel pumps and the Fiscalisation Data Management System (FDMS), approved by the Commissioner to record and transmit fuel data. Virtual Fiscal Devices, include, Point of Sale (POS) systems, accounting systems, and other software-based solutions compatible with the FDMS.
Registration and Compliance Requirements
Section 4 of the regulations requires all fuel operators to acquire Fuel Fiscal Devices from approved suppliers or developers. The Regulations apply to fuel transactions involving the procurement, sale, movement, transfer, distribution, storage, or holding of petroleum products as defined in the Petroleum Act, including petrol, diesel, and liquid petroleum gas.
To qualify as an approved supplier or developer of Fuel Fiscal Devices, section 5(3) of the regulations requires a person to be certified, licensed, and tax-registered with a valid tax clearance certificate; have a permanent establishment or representative taxpayer in Zimbabwe; maintain minimum capital of US$25,000; possess qualified technical personnel; and demonstrate the ability to develop compliant integrations with the FDMS.
Mandatory Recording of Fuel Transactions
All fuel operators must start to electronically record and transmit fuel transactions to the FDMS within six months from 15 May 2026. The Commissioner may postpone this requirement by public notice where technical, operational, or administrative challenges arise.
Features of a valid fiscal invoice or fiscal receipt
Paragraph 1 (1) of S.I. 88 of 2026 describes the required information which must be found on the fiscal invoice or fiscal receipt generated by the fuel fiscal device:
(a) the words “START OF” at the top and “END OF” at the bottom;
(b) the name and address of the Fuel Operator of the registered device;
(c) Taxpayer Identification Number of the Fuel Operator of the registered device;
(d) name and address of the purchaser;
(e) Tax Identification Number of the purchaser, where provided;
(f) the identification number of the Fuel Fiscal Device;
(g) the name, quantity, currency, unit price and item description of the product or service;
(h) discounts, markups, changes, corrections;
(i) the date and time of issue of the receipt;
(j) the total amount payable;
(k) daily ascending serial number for the receipts; and
(l) Verifiable Fiscal Signature in the form of an Authentication Code and QR Code generated from FDMS.
Penalties and Offences
Failure to acquire, install, or use a Fuel Fiscal Device may result in business closure until compliance is achieved. Non-compliance attracts penalties of US$1,000 per point of sale, plus US$25 per day (up to 90 days) for continued non-compliance or FDMS interfacing failures, with additional payments for non-payment. Continued non-compliance may constitute a criminal offence punishable by a fine or imprisonment up to 12 months, or both imprisonment and fine. The Commissioner may waive or refund penalties where non-compliance was unintentional.
How Baker Tilly can assist
- Interpreting SI 88 of 2026 and related tax legislation;
- Assessing compliance readiness;
- Advising on invoicing requirements; and
- Supporting engagements with ZIMRA.
Conclusion
The introduction of Fuel Fiscal Devices marks a significant shift in Zimbabwe's tax administration for the fuel sector. Operators should assess their systems promptly to ensure compliance within the prescribed timelines.
Tax Consultant at Baker Tilly
References
- The Income Tax (Fiscalised Recording of Fuel Transactions) Regulations, 2026, published through Statutory Instrument 88 of 2026.