The Ministry of Finance has issued two Ministerial Decisions (Nos. 243 & 244 of 2025) that set the scope, obligations, and rollout plan for the UAE’s electronic invoicing system. The regime centres on structured e-invoices and credit notes exchanged via Accredited Service Providers (ASPs) with reporting obligation to the Federal Tax Authority (FTA) covering B2B and B2G transactions.
The Timeline
- Pilot programme starts: 1 July 2026 (invited working group only).
- Voluntary go-live: 1 July 2026 (any business may opt in).
- Mandatory Phase 1 (large taxpayers): Appoint ASP by 31 July 2026 → implement by 1 January 2027 if annual revenue ≥ AED 50m.
- Mandatory Phase 2 (other taxpayers): Appoint ASP by 31 March 2027 → implement by 1 July 2027 if annual revenue < AED 50m.
- Government entities: Appoint ASP by 31 March 2027 → implement by 1 October 2027.
- B2C transactions are not in scope, may be switched on by a separate ministerial decision in the future.
Who’s in Scope and What’s Excluded
- e-Invoicing applies to every business transaction in the UAE, unless excluded.
- Key exclusions: certain government sovereign activities, specified airline passenger and cargo flows, and exempt/zero-rated financial services—plus any future exclusions the Minister may set. Businesses may still opt in voluntarily even if an exclusion applies.
What Businesses Must Do
- Appoint an Accredited Service Provider (ASP): both issuers and recipients use ASPs to send/receive e-invoices and e-credit notes; the MoF will publish the accredited list.
- Exchange & reporting through the system:
- Issue and transmit an Electronic Invoice for each in-scope transaction (and an Electronic Credit Note when cancelling/reducing/returning or correcting).
- Send within 14 days of the Date of Business Transaction; recipients must process through the system; both parties must report to the FTA in the timeline the Minister prescribes.
- Data fields & format: follow the MoF-prescribed data set for e-invoices and e-credit notes (structured, machine-readable).
- Storage & access: keep e-invoice data within the UAE per Tax Procedures Law; FTA may access system data and share under legal gateways. Report system failures within 2 business days.
In addition to the MDs: VAT Executive Regulations update (effective 29 Sep 2025)
From 29 September 2025, Articles 59/60 were tuned to the e-invoicing model: once a document is issued electronically, the e-invoice/e-credit-note specification must be followed, and legacy paper-era shortcuts like the simplified invoice route and zero-rated ‘no invoice’ relief no longer apply. For non-electronic documents, the traditional VAT invoice/credit-note rules continue.
Businesses engaging in B2B or B2G transactions in the UAE should now plan against the published phase dates, appoint and integrate with an Accredited Service Provider, and align internal controls to the prescribed electronic data model and reporting timelines. For any documents still issued outside the system, apply the legacy VAT invoice/credit-note rules; once issued electronically, follow the e-invoice/e-credit-note specification without relying on paper-era concessions. Early readiness: governance, archiving, contingency procedures, and buyer/agent arrangements will reduce compliance risk and ensure a smooth transition.
