China’s New E-Invoice Data Standard (GB/T 36619-2024) Review: What It Means for E-Invoicing in China

China’s New E-Invoice Data Standard (GB/T 36619-2024) Review: What It Means for E-Invoicing in China

On November 28, 2024, the State Administration for Market Regulation (SAMR, 国家市场监督管理总局, Guójiā Shìchǎng Jiāndū Guǎnlǐ Zǒngjú) and the Standardization Administration of China (SAC, 国家标准化管理委员会, Guójiā Biāozhǔnhuà Guǎnlǐ Wěiyuánhuì) jointly released the revised national standard GB/T 36619-2024, “Information Technology — Electronic Invoice Data Elements” (信息技术 电子发票数据元, Xìnxī Jìshù — Diànzǐ Fāpiào Shùjù Yuán). This standard, which replaces the 2018 version (GB/T 36619-2018), establishes a unified data element specification for all electronic invoices in China, including the fully digital e-fapiao (全面数字化的电子发票, quánmiàn shùzìhuà de diànzǐ fāpiào). For foreign-invested enterprises, the standard has critical implications for ERP system configuration, cross-border data transfer compliance, and invoice data interoperability.

Executive Summary

GB/T 36619-2024 is the technical backbone of China’s fully digital e-fapiao system. It defines exactly which data elements must appear in every electronic invoice, the format and character set of each element, the validation rules that determine whether an invoice is legally valid, and the metadata structure that enables automated processing by tax authorities. The standard includes 87 mandatory data elements, 23 conditional elements (required under specific circumstances), and 12 optional elements. By comparison, the 2018 version had 54 mandatory elements, 18 conditional elements, and 8 optional elements — representing a 61% increase in mandatory data requirements over six years.

For FIEs operating in China, the most significant changes in the 2024 revision are the introduction of a standardized QR code format, the requirement for real-time (rather than batch) invoice data submission, and the expansion of cross-reference data fields that link invoices to underlying contracts, customs declarations, and logistics documents. These changes collectively shift China’s e-invoicing framework from a transaction recording system to a supply chain monitoring system — invoices now serve not only as evidence of a transaction but as a node in a real-time data network that connects buyers, sellers, logistics providers, customs authorities, and tax authorities.

What Is GB/T 36619-2024 and How It Works

GB/T 36619-2024 is a mandatory national standard under China’s standardization law, meaning that all electronic invoices issued in China must comply with its data element specifications. The standard is maintained by the National Technical Committee on Electronic Commerce of the Standardization Administration of China (SAC/TC 564), with technical input from the STA, the General Administration of Customs, and the Ministry of Commerce. The standard has five sections: scope, normative references, terms and definitions, data element specification, and data exchange format.

The core of the standard is the data element specification, which organizes 122 data elements into 9 categories: invoice identity elements (发票身份标识, fāpiào shēnfèn biāoshí), issuer information (开票方信息, kāipiào fāng xìnxī), receiver information (受票方信息, shòupiào fāng xìnxī), transaction details (交易明细, jiāoyì míngxì), tax breakdown (税额明细, shuì’é míngxì), payment information (支付信息, zhīfù xìnxī), logistics information (物流信息, wùliú xìnxī — new in 2024), cross-reference links (关联凭证, guānlián píngzhèng — new in 2024), and digital signature (数字签名, shùzì qiānmíng). Each data element is specified with its identifier (ID), name (both Chinese and English), data type (string, numeric, date, time, code list), mandatory/conditional/optional status, maximum length, and validation rule reference.

The standard uses XML as the primary data exchange format, with JSON as a supplementary format for API-based transmission. The XML schema (InvoiceDataElement.xsd) defines the document structure, including the root element , the namespace declaration, and the element hierarchy. The JSON schema (InvoiceDataElement.json) mirrors the XML structure but uses camelCase naming conventions. Both schemas are published on the SAMR’s national standards portal and are freely downloadable.

Key Changes in the 2024 Revision

Technical Requirements for FIE Compliance

QR code standardization (Annex A). The most visible change in the 2024 standard is the mandatory QR code format. All fully digital e-fapiao must include a machine-readable QR code that encodes 12 core data elements: invoice code (发票代码, fāpiào dàimǎ), invoice number (发票号码, fāpiào hàomǎ), issuer tax ID (开票方纳税人识别号, kāipiào fāng nàshuìrén shíbié hào), receiver tax ID, issue date, total amount (including tax), total tax amount, check code (校验码, jiàoyàn mǎ), QR code version number (currently “02”), data standard version (“GB/T 36619-2024”), digital signature algorithm identifier (“SM2”), and a 32-byte digital signature value. The QR code uses QR Code Model 2 with error correction level M (15%) and must be printed at a minimum size of 2cm × 2cm on any printed representation of the invoice.

Real-time transmission requirement. The 2024 standard eliminates the batch submission model that was permitted under the 2018 standard. Under the new framework, every invoice must be submitted to the STA’s e-invoicing platform within 60 seconds of issuance. This has significant implications for FIEs that currently batch-process invoices and submit them to the tax bureau at the end of each day or week. The real-time requirement means that the invoice issuance process must be fully online and integrated with the ERP system’s transaction processing — it is no longer acceptable to generate invoices offline and submit them in batches.

SM2 digital signature migration. The 2024 standard mandates the use of the SM2 elliptic curve public-key cryptographic algorithm (SM2椭圆曲线公钥密码算法, SM2 tuǒyuán qūxiàn gōngyào mìmǎ suànfǎ) for all digital signatures. This is China’s national cryptographic standard (GB/T 32918-2016), which is not interoperable with international standards such as RSA or ECDSA. FIEs that currently use RSA-based digital signatures for invoice processing must migrate to SM2-compatible cryptographic hardware or software modules. The STA has announced that after June 30, 2026, invoices signed with non-SM2 algorithms will be rejected by the e-invoicing platform.

How Foreign Companies Should Use This Standard

ERP system mapping. The first step for any FIE is to map its ERP system’s invoice data fields to the 122 data elements defined in GB/T 36619-2024. The mapping exercise should identify which ERP fields already contain the required data, which fields contain data in the wrong format (e.g., free text where a code list is required), and which fields are missing entirely. For each missing field, the FIE must either extend its ERP system’s data model or configure the middleware layer to calculate or derive the missing data from existing fields. The mapping exercise typically takes 2-4 weeks for an SAP-based FIE and 3-6 weeks for an Oracle-based FIE due to Oracle’s more rigid data structure.

Middleware validation layer. All invoice data submitted to the STA’s e-invoicing platform must pass schema validation against the GB/T 36619-2024 XSD schema before submission. The middleware should include a pre-submission validation step that checks each invoice against the 87 mandatory element rules and 23 conditional element rules, generating a detailed error report for any non-compliant invoices. This validation layer prevents the STA from rejecting invoices after submission, which would trigger a compliance incident and potentially a tax audit.

Testing with sandbox environments. The STA maintains a publicly accessible sandbox environment (接口仿真测试平台, jiēkǒu fǎngzhēn cèshì píngtái) where FIEs can test their invoice data against the GB/T 36619-2024 schema without submitting live invoices. The sandbox returns detailed validation error messages, including the specific data element ID, the expected value range, and the actual value submitted. FIEs should complete at least 500 test invoices in the sandbox environment, covering all invoice types (sales, purchase, credit, debit, export, import) before going live.

Limitations and Caveats

Standard does not cover all invoice types. GB/T 36619-2024 covers electronic invoices only. It does not apply to paper-based fiscal invoices, which will be phased out by 2027 under the STA’s full digitalization policy. However, during the transition period (2025-2027), FIEs that still receive paper invoices from non-digitalized suppliers must maintain separate data processing workflows for paper invoices, which are not governed by the standard.

Provincial implementation variations. While GB/T 36619-2024 is a national standard, individual provincial tax bureaus are permitted to add supplementary data requirements for invoices issued or received within their jurisdiction. For example, the Shanghai tax bureau requires an additional data element for the district-level tax office code (税务所代码, shuìwùsuǒ dàimǎ), which is not included in the national standard. FIEs operating in multiple provinces must configure their middleware to append province-specific supplementary elements to invoices that fall within a given province’s jurisdiction.

Industry-specific extensions. The standard defines baseline data elements that apply to all invoice types, but industry-specific extensions exist for certain sectors. The automotive industry, for example, requires additional data elements for vehicle identification numbers (VIN), engine numbers, and vehicle type codes on vehicle sales invoices. Similarly, the pharmaceutical sector requires drug approval numbers and batch numbers on pharmaceutical invoices. FIEs in regulated sectors must verify whether their industry has published an extension to GB/T 36619-2024 and implement the additional elements.

1. The standard requires 87 mandatory data elements — a 61% increase from the 2018 version
2. SM2 digital signature migration is mandatory by June 30, 2026
3. Real-time invoice submission (within 60 seconds) replaces batch processing
4. Standardized QR codes must encode 12 core data elements
5. Logistics data is now mandatory for physical goods transactions
6. FIEs should complete a minimum of 500 sandbox test invoices before going live

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China’s New E-Invoice Data Standard (GB/T 36619-2024) Review: What It Means for E-Invoicing in China — first published on China Gateway 360. Last updated: July 2026.