The UAE Ministry of Finance (MoF) has introduced two significant regulatory updates to its Electronic Invoicing System, refining compliance requirements for businesses and the accreditation framework for service providers.
Ministerial Decision No. 197 of 2026 amends Ministerial Decision No. 243 of 2025, formalising previously announced guidance on intra-group transactions and data storage, while introducing changes to invoice issuance deadlines and system failure reporting.
Meanwhile, Ministerial Decision No. 168 of 2026 replaces Ministerial Decision No. 64 of 2025 and its amendments, establishing an updated accreditation framework for eInvoicing Service Providers.
Both decisions are effective from 1 October 2026.
Previously Announced VAT Tax Group Relief Formalised in Regulation
Ministerial Decision No. 197 of 2026 formally incorporates the previously announced temporary relief for transactions between members of the same VAT Tax Group into the UAE’s eInvoicing regulatory framework.
The 24-month grace period had already been communicated in the UAE Electronic Invoicing Guidelines, which clarified that intra-group transactions would not be subject to mandatory electronic invoicing obligations during this transitional period.
The new decision now explicitly includes these transactions under the exclusions in Article 4 of Ministerial Decision No. 243 of 2025.
Accordingly, business transactions between members of the same VAT Tax Group are excluded from mandatory eInvoicing exchange and reporting requirements from 1 January 2027 through 31 December 2028.
The exclusion applies specifically to transactions between members of the same VAT Tax Group and does not extend to all related-party or intercompany transactions.
Following the expiry of the temporary exclusion, the applicable electronic invoicing requirements will apply to these transactions.
Invoice Issuance Deadline Changed to 14 Business Days
Ministerial Decision No. 197 of 2026 also amends Article 6(5), changing the applicable electronic invoice and credit note issuance deadline from 14 calendar days to 14 Business Days.
Under the revised provision, electronic invoices and credit notes covered by Article 6(5) must be issued and transmitted within 14 Business Days from the Date of Business Transaction.
The amendment changes the general eInvoicing issuance deadline from 14 calendar days to 14 Business Days. However, this revised deadline primarily affects transactions not subject to the VAT-specific invoicing timelines.
For VAT-registered issuers, the deadlines prescribed under the UAE VAT Law continue to apply, generally requiring tax invoices to be issued within 14 calendar days from the Date of Supply, subject to applicable exceptions.
Clarification of Electronic Invoice Storage and Retention Requirements
The amendment to Article 11 introduces greater clarity regarding the storage and retention of electronic invoices and credit notes.
Previously, Ministerial Decision No. 243 of 2025 referred to the requirement to store electronic invoices, electronic credit notes and associated data within the State. Read independently, this wording could suggest a mandatory physical data storage requirement within the UAE.
However, the UAE Electronic Invoicing Guidelines published earlier in 2026 had already clarified that storage infrastructure could be located inside or outside the UAE, provided that records remained securely retained, accessible and capable of being produced to the Federal Tax Authority (FTA) upon request.
Ministerial Decision No. 197 of 2026 now aligns the regulatory wording with this earlier clarification by removing the reference to storage within the State.
Under the revised Article 11, businesses must retain electronic invoices, credit notes and associated data for the prescribed retention period and ensure that these records can be provided to the FTA upon request.
Importantly, this amendment does not override separate data residency requirements under other UAE regulations. For example, banking regulations issued by the Central Bank of the UAE require banks to maintain their Master System of Record, including confidential data, within the UAE, subject to specified exceptions. Certain government entities and public-sector data may also be subject to additional data classification, hosting and sovereignty requirements.
Businesses should therefore assess their applicable sector-specific obligations before adopting data storage arrangements outside the UAE.
System Failure Notification Requirement Repealed
Ministerial Decision No. 197 of 2026 removes the definition of “System Failure” from Article 1 and repeals Article 12 of Ministerial Decision No. 243 of 2025.
Previously, Article 12 required issuers and recipients to notify the FTA of a system failure within two Business Days of its occurrence.
With the repeal of this article, the specific two-Business-Day system failure notification requirement under Ministerial Decision No. 243 of 2025 no longer applies.
This amendment does not automatically remove separate operational or service-provider notification requirements that may apply under other rules.
The decision also updates the definition of an Accredited Service Provider to refer to the legislation governing the Electronic Invoicing System and introduces definitions for “Tax Group” and “Taxable Person”.
New Accreditation Framework for UAE eInvoicing Service Providers
Ministerial Decision No. 168 of 2026 introduces a revised framework for the accreditation of eInvoicing Service Providers, repealing Ministerial Decision No. 64 of 2025 and its subsequent amendments.
The most significant change is the removal of the previous pre-approval stage, replacing the earlier two-stage process with a direct accreditation framework.
Under the new framework, Service Providers must complete the necessary eligibility assessment, interoperability testing, end-user verification testing, tax data reporting testing and production environment readiness procedures before receiving full accreditation.
The requirements include demonstrating compliance with the Peppol Interoperability Framework, PINT AE specifications and the relevant FTA verification and reporting procedures.
The new decision also maintains key eligibility requirements, including Peppol certification, information security standards, financial requirements and insurance coverage.
Third-Party Technology Flexibility and Transitional Provisions
Ministerial Decision No. 168 of 2026 retains the flexibility previously introduced under Ministerial Decision No. 56 of 2026, allowing Service Providers to use third-party Peppol Service Provider Products (PSP Products) and outsource elements of their electronic invoicing services.
The applicable experience requirement can be satisfied where the PSP Product has been operational for at least two years and either the Service Provider or the relevant third party has experience operating or managing that product.
However, the accredited Service Provider remains fully responsible for regulatory compliance and oversight of service delivery.
The decision also introduces important transitional arrangements:
- Existing pre-approved Service Providers: Providers granted pre-approval under the previous framework must complete the new accreditation requirements within 30 days from 1 October 2026.
- New applications: Previously pre-approved providers are not required to submit a new application unless otherwise determined by the Ministry.
- Rejected applications: Service Providers may reapply after 90 Business Days, provided the reasons for rejection have been rectified.
Accreditation remains valid for two years, with renewal applications required no later than 70 Business Days before expiry.
What Do These Changes Mean for Businesses?
The latest UAE eInvoicing amendments provide greater regulatory certainty and operational flexibility while maintaining the broader mandatory implementation framework.
Businesses preparing for UAE eInvoicing compliance should review their intra-group transaction classifications, ensure that applicable invoice issuance deadlines are correctly reflected in their systems, and reassess their electronic record retention arrangements, taking into account any sector-specific data residency obligations.
They should also ensure that their selected Accredited Service Provider meets the updated accreditation requirements and can support the necessary electronic invoice exchange and tax data reporting processes.
Importantly, these decisions do not postpone the UAE’s phased mandatory eInvoicing implementation timeline. Businesses with annual revenue of AED 50 million or more must appoint an ASP by 30 October 2026, ahead of their mandatory e-invoicing implementation deadline of 1 January 2027. Businesses should therefore continue preparing for their respective compliance deadlines and ensure timely completion of their ASP appointment and system readiness activities.
