An agent can issue the Electronic Invoice. The supplier still answers for it. Scenario 6 of the Guidelines permits a disclosed agent to raise invoices on behalf of a principal, and then states plainly that the responsibility to issue an Electronic Invoice remains with the supplier even where the agent issues one on its behalf. For groups that route billing through brokers, commercial agents or collection agents, that sentence determines where the compliance exposure sits.
Disclosed Agents Only
The scenario applies where a Person is acting as a disclosed agent on behalf of a principal and issuing invoices on its behalf. The Guidelines exclude undisclosed agents from the scenario entirely. The example given is an insurance broker issuing an invoice to collect premiums from a buyer on behalf of a VAT registered insurance company principal.
Disclosure is the test that decides whether the arrangement is inside Scenario 6, and it is a question of fact about the commercial relationship rather than a configuration choice. An intermediary who contracts in its own name and resells is a principal, and its invoices are its own. An intermediary acting in the name of a named principal falls within the scenario. Businesses whose agency arrangements are still uncharacterised for VAT purposes should settle that characterisation before deciding how the invoice will be issued, because the answer changes which entity's TIN appears as supplier. The legal architecture behind this, in Articles 8 and 9 of Ministerial Decision No. 243 of 2025, is covered in the agent and self-billing analysis.
Where the Responsibility Sits
Scenario 6 applies to Commercial Invoices as well as to electronic Tax Invoices. The additional consideration attached to it is a single line: the responsibility to issue an Electronic Invoice remains with the supplier even if an agent issues one on its behalf.
The practical reading is that delegation reaches the operational act of issuing and stops there. Where an agent fails to transmit, transmits late, or transmits data that does not reflect the supply, the principal is the Person who has failed to issue an Electronic Invoice. Three requirements follow for the principal, and they sit independently of the agent's own systems: visibility of what the agent has issued, a means of confirming that transmission to Corner 5 succeeded, and a contractual right to the underlying records. The same structure applies to Scenario 7, where an e-commerce platform issues on the supplier's behalf and the issuance responsibility likewise stays with the supplier.
Import VAT Paid by an Agent
Section 12.2 of the Guidelines adds a related field-level rule. In accordance with Article 50 of the VAT Executive Regulation, where an agent imports goods and has paid import VAT on behalf of another party, an Electronic Invoice shall be issued by the agent. The VAT paid by the agent can be mentioned under the Document Level Charges section.
This is the recovery mechanism for a common freight and customs clearance pattern. The clearing agent settles import VAT at the border and recovers it from the importer. Placing that recovery under Document Level Charges keeps it visible on the Electronic Invoice as a charge rather than disguising it inside a service fee line, which preserves the audit trail from the customs entry to the importer's input tax position.
What to Settle Before Go-Live
Three questions decide whether an agency billing arrangement will work from the mandatory date. Which entity is the supplier on the Electronic Invoice, and does that match the agency characterisation. How the principal will see, in near real time, what the agent has transmitted and whether Corner 5 acknowledged it. And whether the agency agreement obliges the agent to produce transmission records on request, given that the principal will be the Person answering for any gap.
An agency arrangement that has run informally for years on the strength of a monthly statement now meets a system that timestamps every transmission. The agreement is the place to fix that, and it is easier to renegotiate now than after the first missed transmission.