ESF, CNT, and Virtual Warehouse in 2026
From January 1, 2026, the VAT rate in Kazakhstan increased from 12 to 16 percent, and the threshold for mandatory VAT registration decreased from 20,000 to 10,000 MCI — with an MCI of 4,325 tenge, this is about 43.25 million tenge of annual turnover. Simultaneously, the rules for accompanying invoices for goods changed: from the beginning of the year, they must be issued for domestic sales only for four categories — biofuel, alcoholic products, petroleum products, and traceable goods — while for other positions, CNT and the virtual warehouse are applied voluntarily. For businesses, this means one thing: more companies fall under VAT registration, and primary goods accounting increasingly moves into the electronic circuit, where every mistake is visible to the tax authority automatically.
At West Star Ltd, we have been integrating accounting systems with government services in recent years and observing how the combination of ESF, CNT, and the virtual warehouse is transforming from a formality into a real operational process that either works in the background or consumes the time of accountants and warehouse workers daily. In this article, we will analyze without marketing what these three entities are, what exactly changed in 2026, where companies most often stumble, and what can really be automated, and what will have to be kept under manual control.
WHAT ARE ESF, CNT, AND VIRTUAL WAREHOUSE
These are three interconnected but different tools within one electronic invoice information system.
ESF — electronic invoice. This is a tax document that confirms the sale of a product, work, or service and gives the buyer the right to a VAT credit. It is issued in the ESF IS, signed with an electronic signature, and stored in the system. For a VAT payer, the ESF is the main document around which all reporting revolves.
CNT — accompanying invoice for goods. This is a document that accompanies the physical movement of goods: with whom, from where, to where, and what exactly is being transported. CNT is not needed for VAT credit but for traceability — so that the state can see the movement of sensitive categories of goods from import or production to final sale.
Virtual warehouse — this is a module within the ESF IS, where the balances and movement of goods by nomenclature are recorded. It works as a mirror of your real warehouse: receipt by CNT and ESF increases the virtual balance, expenditure decreases it. The point is that you cannot issue a document for a product that, according to the system, you do not have. It is the virtual warehouse that links the ESF and CNT into a single chain and makes traceability work.
Simply put: ESF is responsible for tax, CNT for movement, and the virtual warehouse for balances that must match both.
WHAT CHANGED IN 2026
The new Tax Code, which came into force on January 1, 2026, changed not only the rate itself but also the entire logic around it.
First — the VAT rate is 16 percent instead of the previous 12. This directly affects the price of goods in the chain and the amounts that pass through the ESF.
Second — lowering the threshold for VAT registration from 20,000 to 10,000 MCI. Companies and individual entrepreneurs who previously worked calmly without VAT now, with a turnover of about 43 million tenge per year, are required to register, which means they must start issuing ESF and conducting all electronic document flow.
Third — updated list of goods for which CNT and the virtual warehouse are mandatory. The list is approved by the order of the Minister of Finance and has been revised since 2026. Within the country, mandatory electronic accompaniment is maintained for a limited range of categories; for import and export of EAEU goods, the rules are stricter. For other positions, businesses can voluntarily connect to the virtual warehouse — and many do this consciously to organize their balances.
Fourth — strengthening automatic control. A separate VAT tax account has appeared, from which amounts are deducted when issuing ESF, and the reconciliation of deductions is carried out automatically. This means that discrepancies between what you declared and what the system sees are revealed faster and without the inspector's involvement.
The paper form of CNT is allowed only as an exception — in case of technical failures in the system. The basic scenario for 2026 is fully electronic.
HOW IT WORKS IN PRACTICE
Imagine a wholesale company that purchases traceable goods and resells them further.
On the input, the supplier issues CNT and ESF. The goods are credited to your virtual warehouse — the balance increases. Until you confirm this receipt in the system, you cannot correctly move further with the goods.
When selling, you issue an outgoing CNT and ESF to the buyer. The system checks whether you have a sufficient balance of this nomenclature in the virtual warehouse. If yes, the document passes, the balance is written off. If not, the system will not allow issuing the document, and this is the first signal that accounting has diverged somewhere from reality.
In an ideal world, these operations run in the background: the company's accounting system exchanges data with the ESF IS directly, the nomenclature matches, and the balances converge. In the real world, an accountant often duplicates the same data in the accounting program and in the ESF IS cabinet manually, the nomenclature is called differently in two systems, and the virtual balance lives its own life. It is at this junction that most problems arise.
TYPICAL MISTAKES AND PENALTIES
Over the years of work, we see the same pitfalls that companies step on regardless of size.
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Nomenclature discrepancy. In the accounting program, the product is called by one article, in the virtual warehouse by another or by the HS code. Balances do not converge, documents do not pass, and a person spends hours on manual reconciliation.
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Untimely issuance of CNT. For traceable and mandatory categories, the invoice must be issued within the established period. Delay or non-issuance is administrative responsibility under the Administrative Code, and fines increase with repeated violations during the year.
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Negative virtual balance. The sale occurs before the receipt enters the system, and the balance goes negative. Formally, such a sale could not have happened, and this is a direct reason for questions from the tax authority.
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Ignoring the new VAT threshold. Companies that crossed the 10,000 MCI turnover in 2026 but did not register in time risk additional charges and fines for failing to fulfill the registration obligation.
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Manual data transfer between systems. Every manual action is a potential typo in the amount, date, or quantity, which automatic control will highlight as a discrepancy.
Separately note: the exact amounts of fines depend on the category of violation, taxpayer status, and recurrence, so the specific amount should always be clarified according to the current edition of the Administrative Code, not rumors in accountant chats.
HOW TO AUTOMATE THIS
The main idea is simple: data should be entered once and then move between systems on their own.
Technically, the bundle looks like this. The company's accounting system — most often this is 1C — stores nomenclature, receipts, and sales. The ESF IS stores ESF, CNT, and virtual balances. An exchange is set up between them, in which issuing a document in the accounting system automatically forms and sends the corresponding ESF or CNT, and the virtual warehouse data is pulled back for reconciliation.
What this gives in practice. The accountant stops manually duplicating documents in two cabinets. Nomenclature is synchronized through a single directory, so balances in the accounting system and the virtual warehouse converge. Reconciliation of balances and document statuses goes on schedule, not in an emergency mode at the end of the month. Discrepancies are visible immediately, while they are still cheap to fix.
It is important to understand that automation here is not a single button but a configured process. You need to put the nomenclature in order once, match codes, describe issuance rules for different categories of goods, and only then enable the exchange. In our practice, we always start not with integration but with auditing directories: if there is a mess in them, any automation will just multiply it faster.
LIMITATIONS AND WEAK SPOTS
An honest conversation about this topic is impossible without a list of what works poorly here or requires manual control.
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Dependence on the availability of the state system. The ESF IS is periodically unavailable due to load or technical work. At such times, issuance stops, and you have to either wait or switch to paper form by exception. Your automation is only as reliable as the service on the other side.
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The quality of the source data decides everything. No integration will save if the nomenclature is maintained carelessly. Garbage in — garbage in the virtual warehouse, only now also with discrepancies in VAT.
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Virtual balance is not equal to physical. The system shows what was entered into it by documents, not what is actually on the shelf. Misplacement, breakage, natural loss require separate inventory and adjustments, which a person still makes.
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Changing lists and rules. The list of mandatory categories and the order of issuance are revised by orders. What was voluntary can become mandatory, and the process will have to be reconfigured. This is not a one-time project but a living system that needs support.
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Entry threshold for small businesses. For a small company, setting up full integration may be more expensive than manually entering a dozen documents a month. Automation pays off on flow, not on single operations.
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Responsibility remains with the taxpayer. Even with full automation, the business, not the program, is responsible for the correctness of documents. Blindly trusting the exchange without periodic reconciliation is not allowed.
WHAT TO DO
A practical conclusion is conveniently laid out by roles.
For the accountant or primary specialist. Start by putting the nomenclature in order and matching it with the virtual warehouse. Check that for all mandatory categories of goods, CNT issuance is timely and balances do not go negative. Develop the habit of reconciling the virtual balance with the accounting system not at the end of the quarter, but weekly — this way discrepancies are caught while they are few.
For the manager or chief accountant. Assess whether the company falls under the new VAT threshold of 43 million tenge turnover, and plan registration in advance, not after additional charges. Calculate how many man-hours per month are spent on manual document entry in the ESF IS — this is the potential savings from automation.
For the owner. Look at this not as an accounting formality but as an operational risk and data source. Transparent balances and electronic document flow reduce penalty risks and at the same time provide you with a reliable picture of product flows. If the company has a significant turnover of traceable goods, integrating the accounting system with the ESF IS pays off through saved time and reduced risks faster than it seems.
FREQUENTLY ASKED QUESTIONS
Is it mandatory for everyone to issue CNT in 2026?
No. For domestic sales, CNT is mandatory only for a limited list of categories — biofuel, alcohol, petroleum products, and traceable goods. For other positions, the virtual warehouse and CNT are applied voluntarily, but for import and export of EAEU goods, the rules are stricter.
What is the difference between ESF and CNT?
ESF is a tax document for VAT credit, it's about money and tax. CNT is a document about the physical movement of goods, it's about traceability. For one operation with a mandatory product, both may be needed.
What happens if the virtual balance goes negative?
The system will not allow issuing a document for a product that, according to its data, you do not have. This is a signal that the receipt has not been processed or the nomenclature has diverged. Until the discrepancy is resolved, it will not be possible to correctly sell the product in the electronic circuit.
Is 1C necessary for all this?
Not necessarily, but convenient. Any accounting system can be linked to the ESF IS through data exchange. The point of integration is to enter the document once in your program, not to duplicate it manually in the state cabinet.