Effective Date: October 2025

Last Updated: October 2025

1. Introduction

1.1 The purpose of this Invoicing Policy (“Policy”) is to establish a transparent and legally compliant framework for the issuance, delivery, correction, and storage of invoices, receipts, and credit notes in respect of Charging Sessions booked and paid for through the Zingrev platform (the “Platform”).

1.2 This Policy applies to all individuals and entities who participate in the Platform, namely:

• Charger Providers, who make electric vehicle (EV) charging services available via the Platform; and
• EV Drivers, who reserve and pay for those services via the Platform.

1.3 This Policy forms an integral part of the Zingrev legal framework and must be read together with the Terms of Service, Payment Terms & Fees Policy, Refunds & Cancellations Policy, Privacy Policy, and all other applicable Policies. 

1.4 In the event of inconsistency between this Policy and other Platform documents, the order of precedence set out in the Terms of Service shall apply.

2. Legal Basis

2.1 This Policy has been prepared in line with:

• Directive 2006/112/EC of the Council of the European Union on the common system of value added tax (the “EU VAT Directive”), in particular Articles 217–240 governing invoicing obligations;
• The Estonian Value Added Tax Act (Käibemaksuseadus) and related decrees on accounting and record-keeping;
• The EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679); and
• Relevant national VAT and accounting laws in other EU Member States where Charger Providers may be established.

2.2 In accordance with Article 224 of the EU VAT Directive, an invoice may be issued by the customer or a third party, provided that such arrangement is accepted by the supplier. Under this Policy, each Charger Provider expressly authorizes Zingrev to issue invoices, receipts, and credit notes on its behalf.

2.3 This Policy ensures compliance with the principles of authenticity of origin, integrity of content, and legibility of invoices, as required under Article 233 of the EU VAT Directive.

3. Definitions

For the purposes of this Policy:

• Zingrev means Zingrev OÜ, registry code 17315908, a private limited company incorporated in Estonia.
• Platform means the Zingrev website, web application, and mobile application.
• User means any natural or legal person registered on the Platform, whether as an EV Driver or Charger Provider.
• Charger Provider means a User who offers access to their EV charging point via the Platform.
• EV Driver means a User who books and pays for access to a Charger Provider’s EV charging point via the Platform.
• Invoice means a full tax invoice issued in accordance with VAT laws.
• Credit Note means a corrective document issued to adjust, reduce, or cancel the amount previously invoiced.
• Receipt means a simplified document evidencing payment, issued where VAT law permits simplified invoicing.

4. Zingrev’s Role in Invoicing

4.1 Zingrev provides invoicing services strictly as an intermediary. By using the Platform, Users acknowledge that Zingrev is not the supplier of electricity or charging services.

4.2 Zingrev is authorized by Charger Providers to issue invoices, receipts, and credit notes in their name and on their behalf. Such documents are legally deemed to be issued by the Charger Provider, with Zingrev acting only as the technical facilitator.

4.3 Zingrev assumes no liability for the accuracy of VAT rates, place-of-supply rules, or other tax determinations, which remain the sole responsibility of the Charger Provider.

5. Charger Provider Authorization

5.1 Each Charger Provider grants Zingrev the irrevocable right and authority to:

• Prepare and issue invoices, receipts, and credit notes in their name for all transactions concluded via the Platform;
• Use a centralized invoice numbering sequence;
• Deliver such documents electronically to EV Drivers.

5.2 Charger Providers acknowledge that they remain the supplier of record and are solely responsible for:

• Compliance with VAT and tax obligations in their jurisdiction;
• The accuracy of business name, address, VAT number, and pricing details supplied to Zingrev;
• Notifying Zingrev promptly of any changes to their legal or tax details.

5.3 Invoices issued under this arrangement shall be deemed accepted by the Charger Provider unless the Provider notifies Zingrev of an error within 7 calendar days of issuance.

6. EV Driver Acceptance

6.1 By registering on the Platform, EV Drivers expressly consent to:

• Receiving invoices, receipts, and credit notes issued electronically in the name of and on behalf of the Charger Provider;
• Treating such documents as legally valid and equivalent to paper invoices;
• Accepting refunds, partial refunds, or booking adjustments through credit notes issued by Zingrev on the Charger Provider’s behalf.

6.2 This consent satisfies the requirement under Article 232 of the EU VAT Directive that the recipient must agree to the use of electronic invoices.

7. Invoice Content Requirements

7.1 Invoices issued through the Platform will contain all mandatory information required under Article 226 of the EU VAT Directive and the Estonian VAT Act, including:

• Date of issue and sequential invoice number;
• Name, address, and VAT number (if applicable) of the Charger Provider;
• Name and address of the EV Driver (where required);
• Description of the charging service;
• Date of the charging session;
• Unit price and total consideration;
• VAT rate and VAT amount, or statement of exemption/reverse charge;
• Total amount payable.

7.2 Where a simplified invoice is permitted under Article 238 of the EU VAT Directive (e.g., transactions not exceeding EUR 100), Zingrev may issue a simplified document.

8. Electronic Invoicing Standards

8.1 All invoices, receipts, and credit notes will be issued electronically only.

8.2 In compliance with Article 233 of the EU VAT Directive, Zingrev ensures authenticity, integrity, and legibility through:

• Secure issuance from its controlled IT systems;
• Restricted user access and download permissions;
• Audit trails recording issuance, modification, and storage events.

8.3 EV Drivers and Charger Providers waive any right to paper invoicing and acknowledge that electronic delivery meets all legal requirements.

9. Currency and Language

9.1 Unless otherwise required, invoices are issued in euros (EUR). Where permitted, other currencies may be displayed, provided VAT amounts (if applicable) are shown in euros.

9.2 The default invoice language is English. If national legislation requires invoices in a specific local language, Charger Providers must notify Zingrev. Zingrev will use reasonable efforts to comply prospectively.

10. Delivery and Access

10.1 EV Drivers may access invoices and receipts via:

• Their in-app account history;
• Email delivery, where configured.

10.2 Charger Providers may access invoices issued on their behalf via their Provider dashboard.

10.3 Users are responsible for downloading and storing invoices for their own accounting and record-keeping purposes.

11. Record-Keeping and Retention

11.1 Zingrev retains invoices and related documents for at least seven (7) years, in line with Estonian VAT Act requirements.

11.2 Charger Providers remain independently responsible for meeting their own national record-keeping obligations, which may require retention periods of up to ten (10) years.

11.3 EV Drivers should retain invoices for their own expense reimbursement, accounting, or tax deduction purposes.

12. Corrections and Credit Notes

12.1 If an invoice contains incorrect or incomplete information, the Charger Provider must notify Zingrev without undue delay.

12.2 Zingrev will issue a corrective invoice or a credit note and replacement invoice, maintaining a clear audit trail.

12.3 Refunds, cancellations, and partial refunds are always accompanied by a credit note issued on the Provider’s behalf.

13. VAT and Tax Responsibilities

13.1 The Charger Provider is the supplier of record and remains solely responsible for:

• Determining whether VAT applies;
• Applying the correct VAT rate;
• Declaring and remitting VAT and other taxes;
• Ensuring compliance with local energy, tax, and consumer laws.

13.2 Zingrev issues a separate invoice to the Charger Provider for its 14% Service Fee, subject to Estonian VAT where applicable.

13.3 Zingrev has no responsibility for calculating or remitting VAT on the supply of electricity or charging services.

14. Indemnity by Charger Providers

14.1 Charger Providers indemnify and hold harmless Zingrev from any liability, claim, assessment, penalty, interest, or cost arising from:

• Incorrect VAT/tax information;
• Non-compliance with national tax obligations;
• Misclassification of supplies or services.

14.2 This indemnity survives termination of the Provider’s use of the Platform.

15. Data Protection (GDPR)

15.1 Invoice data constitutes personal data where it relates to identifiable natural persons (e.g., EV Driver names, addresses).

15.2 Zingrev processes invoice data as a data controller, in line with the Privacy Policy, for the purposes of:

• Issuing and delivering invoices, receipts, and credit notes;
• Complying with legal obligations under Estonian VAT and accounting laws;
• Facilitating record-keeping and audit requirements.

15.3 Legal basis for processing includes:

• Article 6(1)(b) GDPR – performance of a contract;
• Article 6(1)(c) GDPR – compliance with legal obligations;
• Article 6(1)(f) GDPR – legitimate interest in maintaining accurate records.

15.4 Invoice data is shared only with:

• The relevant EV Driver and Charger Provider;
• Payment service providers for reconciliation;
• Tax and supervisory authorities where legally required.

15.5 Data subjects may exercise GDPR rights (access, rectification, erasure, restriction, portability, objection) subject to legal and tax record-keeping requirements that may limit deletion.

16. Audit and Regulatory Cooperation

16.1 Zingrev may be required to provide invoices and records to the Estonian Tax and Customs Board (MTA) or other competent EU authorities.

16.2 Charger Providers agree to cooperate fully with such requests and provide supplementary information if necessary.

17. Dispute Resolution

17.1 Any dispute regarding an invoice must be raised within 14 calendar days of issue.

17.2 Zingrev will investigate promptly and, if appropriate, issue a corrective document.

17.3 Persistent disputes between Drivers and Providers shall be resolved under the Refunds & Cancellations Policy and applicable consumer laws.

18. Updates to this Policy

18.1 Zingrev may amend this Policy to reflect changes in law, accounting standards, or operational practices.

18.2 Material changes will be notified to Users by email or in-app message.

18.3 Continued use of the Platform after notification constitutes acceptance of the revised Policy.

19. Governing Law

19.1 This Policy is governed by Estonian law, subject to mandatory EU consumer protections.

19.2 Users may escalate disputes to:

• The Estonian Consumer Protection and Technical Regulatory Authority (TTJA);
• The Estonian Consumer Disputes Committee;
• The EU Online Dispute Resolution (ODR) Platform.

20. Contact

For questions or concerns about this policy, please contact us at: