The short version
- RRA's 19 December 2024 announcement requires non-EBM expenses to be uploaded to the E-Tax ledger as they occur, not at year-end. Effective 1 January 2025.
- 2025 was under-enforced, not withdrawn. The same pattern preceded EBM-for-All tightening.
- The upload is the easy part. The documentation behind it, IPV, proof of payment, invoice and contract, is what gets tested.
- Suppliers not registered on the tax system are a 15% withholding case, not a ledger upload.
Every December, Rwanda Revenue Authority issues the same reminder: expenses without an EBM receipt, a customs declaration, or a withholding tax certificate will not be accepted at income tax filing. Most finance teams read it, nod, and file it away until March gets close enough to hurt.
What far fewer businesses noticed is that the wording changed. Buried in RRA's announcement of 19 December 2024 was a single instruction that quietly redefined how unsupported expenses are handled. Instead of compiling them into a ledger annex at year-end, taxpayers must upload them as they occur, effective 1 January 2025.
A year on, most of the market still treats that instruction as optional. That gap, between what the law requires and what businesses actually do, is exactly where the risk sits.
The Instruction
What RRA actually announced
The announcement was explicit, and it tied the upload directly to continuous data matching.
Expenses that cannot be supported by an EBM receipt, a customs declaration (DMC), or a withholding tax declaration are deductible only if they are uploaded into the ledger account in E-Tax. From the start of 2025, that upload was no longer meant to wait until year-end.
RRA tied this directly to continuous data matching: technology has been deployed specifically to verify that declared income holds up against what the system already has on file.
RRA has reinforced the point since. It opened the E-Tax facility for unsupported expenses from the beginning of 2025 and has repeatedly urged taxpayers to record them progressively through the year rather than in one year-end push. The reason is practical: a last-minute rush of entries overwhelms both the system and RRA's support capacity, and genuine expenses end up missed or misclassified.
The Misreading
2025 did not test the rule. The next cycle will.
Encouragement in year one was read as optionality. It was not.
RRA's messaging through 2025 leaned on encouragement, submit early, avoid congestion, record progressively, rather than penalties for late entry. So many companies read the daily-upload instruction as guidance rather than a requirement, and reconciled their books exactly as before: expenses gathered, sorted and uploaded in the weeks before the annual declaration.
That approach still produced accepted declarations in 2025. It will not necessarily do so again.
The rule was never withdrawn. It was under-enforced in its first year, a familiar pattern with RRA rollouts. EBM-for-All followed the same arc: introduced as an expectation, then tightened once the data infrastructure caught up. Data matching for non-EBM expenses is that same infrastructure maturing.
The rule was never relaxed. It was simply not yet enforced.
The Exposure
What waiting actually costs
Interest, fines, and a five-year window in which any return can be reopened.
Under the Tax Procedures Law N° 020/2023, understated tax attracts non-compounding interest that accrues monthly, capped at 100% of the tax due, on top of administrative fines. Any filed return stays open to audit for five years.
Declared income also has to reconcile against figures RRA already holds from EBM and VAT declarations. So an expense entered late, or not at all, does not just risk rejection. It risks a taxable profit that does not match RRA's own numbers, which is exactly the kind of mismatch that turns into a full audit.
Then there is the everyday problem. Bank charges, foreign service providers, and other costs that never generate an EBM receipt are precisely the ones that get forgotten when they are not logged close to the transaction date. A twelve-month lookback rarely produces a complete, well-evidenced record. A same-week entry usually does.
The Evidence
The upload takes a minute. The paper trail does not.
The upload proves you declared the expense. The file proves it happened.
Uploading an expense into the E-Tax ledger takes a minute. Defending that entry when RRA queries it takes considerably more. This is where most businesses fall short, including the ones diligent enough to upload on time. An entry with no paper trail behind it is about as useful as no entry at all. For every non-EBM expense uploaded, the underlying file should be able to produce:
01
Internal Payment Vouchers (IPVs)
The internal authorization showing who approved the spend, for what, and on what basis.
02
Proof of Payment (POP)
MoMo statements, bank transfer confirmations, or bank statements showing the transaction cleared through a traceable channel.
03
Contracts or agreements
For recurring or professional services, the underlying agreement that establishes the relationship and the pricing.
04
Invoices
From the supplier, even where no EBM was issued, showing what was purchased and from whom.
05
Company policies
Internal policies covering travel, procurement and per diem that establish the expense was incurred within an approved framework rather than on an ad hoc basis.
RRA's data matching increasingly tests declared expenses against this evidence, not just against the ledger entry. Treat the documentation checklist as seriously as the upload itself, and build your filing habits around producing the evidence rather than around hitting the deadline.
Highest-Risk Category
International travel: the line item RRA looks at hardest
A flight or hotel booking on its own is rarely enough to hold up on review.
Payment from the company's official account
Settled through the company's own bank account or corporate payment channel, not a personal card or a director's personal MoMo line, so the transaction is traceable back to the business.
Invoices issued in the company's name
Airline, hotel and agency invoices addressed to the company, not to the traveling individual personally.
Supporting documentation for the mission
Evidence of why the trip was undertaken on behalf of the company: an invitation letter, a mission order, meeting or conference documentation, or a signed travel authorization tying the trip to a specific business purpose.
Without that combination, an international trip is hard to defend as a deductible business cost rather than a personal or director benefit, and it is exactly the kind of line item that draws attention on review.
Action Plan
What to fix before the next filing cycle
For businesses under the real tax regime, this is a change in timing and documentation discipline, not in substance.
Log as you go. Route every non-EBM cost through the E-Tax ledger entry as it happens, not at reconciliation time.
Build the file, not just the entry. Attach the IPV, proof of payment, invoice and contract to each entry as it is logged, so the evidence exists before it is ever asked for.
Reconcile monthly. Check declared expenses against the View Purchases screen so they never exceed what RRA's own system reflects.
Withhold, do not upload, for unregistered suppliers. Apply the 15% withholding tax at payment rather than treating the cost as a ledger item.
Tighten travel files specifically. Confirm every international trip has company-account payment, company-name invoices and mission documentation before it is filed away.
Extend the habit beyond finance. Build the process into whoever owns procurement, travel booking or petty cash, since that is where most non-EBM spend originates.
Leave this to year-end and you are not just risking a rejected expense line. You are risking a declaration that does not hold up against data RRA already has, at the exact moment it is hardest to fix.
FAQ
Quick answers
Does this apply to every business?
It applies to taxpayers under the real regime who claim expenses that carry no EBM receipt, customs declaration (DMC), or withholding tax declaration.
How often does “as they occur” actually mean?
RRA's instruction is to record progressively rather than in a year-end batch. In practice, weekly or at each monthly close is enough to stay defensible; the point is that entries sit close to the transaction date.
What if the supplier is not registered on the tax system?
That is not a ledger upload. Withhold 15% at payment and declare it; the withholding declaration is what supports the expense.
Is an entry alone enough if RRA queries it?
No. Expect to produce the IPV, proof of payment, invoice, and any underlying contract or policy behind the spend.
What happens if an expense is missed entirely?
It is likely to be disallowed, and the resulting understated tax attracts monthly non-compounding interest capped at 100% of the tax due, plus administrative fines. Returns stay open to audit for five years.
How ALSM Helps
Where ALSM Consulting Group comes in
This is the kind of requirement that sounds administrative until it costs real money at declaration time, so we build it into the accounting work rather than treating it as a year-end fire drill.
Bookkeeping & E-Tax integration
Structuring your chart of accounts and monthly close so non-EBM expenses are logged and evidenced as they occur, not reconstructed later.
Tax advisory & compliance
Guidance on which expenses qualify for the ledger-account route, which require withholding tax instead, and how to document each so they hold up under review.
Documentation reviews
Checking that IPVs, proof of payment, invoices, contracts and travel files meet what RRA expects before a query ever arrives.
Monthly reconciliation
Checking declared expenses against RRA's own View Purchases data before it becomes a March-deadline surprise.
Software implementation
Configuring Zoho or Frappe so EBM and non-EBM expense capture happen in the same workflow, with nothing left to manual memory.
Audit-readiness reviews
Making sure your books can withstand the data-matching checks RRA is increasingly running before you ever receive a query.
Rwanda's tax administration is moving toward continuous, system-based compliance rather than annual reconciliation. Adapt your bookkeeping and documentation habits now and the March routine, plus whatever data matching follows, becomes a formality. Leave it, and you are filing from a year-end shoebox against a system that already knows the answers.
Talk to us before your next filing cycle
Bookkeeping, tax advisory and audit-readiness support for businesses filing in Rwanda.
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Osias Dushimimana
Senior Manager
CPA(RW), Senior Manager at ALSM Consulting Group .