A surprising amount of e-invoicing advice in circulation was written before the decisions were published, and some of it is still guessing. The decision is six pages long. It is worth knowing what it actually says, because several things businesses assume are excluded are not, and a couple of things they worry about are.
Who is in scope
Article 3 applies the decision to "any person conducting business in the State in respect of every business transaction", except where the person or the transaction is excluded. It is not written around VAT registration, and it is not limited to sales over a threshold. What the phased timetable does is decide when each group starts: the obligation is broad, and the dates stagger it.
| Group | Appoint a provider by | Mandatory from |
|---|---|---|
| Annual revenue of AED 50 million or more | 30 October 2026 | 1 January 2027 |
| Annual revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities (non-sovereign activity) | 31 March 2027 | 1 October 2027 |
| Anyone, voluntarily | — | From 1 July 2026 |
What is excluded
Article 4 lists these excluded transactions, and lets the Minister add more:
- Business transactions by government entities acting in a sovereign capacity and not in competition with the private sector.
- International passenger transport by an airline where an electronic ticket is issued.
- Services an airline provides directly to those passengers, ancillary to the flight, where an Electronic Miscellaneous Document is issued.
- International transport of goods by an airline under an airway bill, for 24 months from the date the system becomes effective.
- Financial services that are exempt or zero-rated under Article 42 of the VAT Executive Regulation.
Being excluded does not stop you joining. A person or transaction that is excluded can still issue and exchange e-invoices voluntarily; the rules then apply in full, except the penalties.
What you must do once you are live
| Obligation | Detail | Article |
|---|---|---|
| Appoint an accredited provider | Both the issuer and the recipient, from the Ministry's published list | 5 |
| Issue and transmit e-invoices | Within 14 days of the date of the transaction (the earlier of the transaction and payment) | 6 |
| Issue e-credit notes | When a transaction is cancelled, the price is reduced, consideration is returned, or there was an administrative or numerical error | 6 |
| Receive and process | Supplier e-invoices are received and processed through the system too | 6 |
| Keep provider details current | Tell your provider of changes to your registered data within 5 business days of FTA confirmation | 5 |
| Store the data in the UAE | For the record-keeping period under the Tax Procedures Law | 11 |
| Report a system failure | To the FTA within 2 business days of it happening | 12 |
Two practical points follow from that table. Credit notes are not optional paperwork any more: a price reduction after the invoice must be an e-credit note through the network, and "administrative error" is one of the triggers, so correcting a mistake by editing an invoice is out. And receiving matters as much as sending, because the recipient has obligations of its own: your purchase ledger needs to accept structured invoices, not just your sales ledger to produce them.
Questions people actually ask
Is B2C included in UAE e-invoicing?
Not in the current phases. The timetable covers B2B and B2G transactions, and the B2C requirement is to be set later by ministerial decision. A business that sells to both consumers and businesses must still e-invoice its business sales from its go-live date.
Are free zone companies excluded?
No. The exclusions are by type of transaction, not by location. A free zone business doing business in the UAE is in scope like any other.
Do I need to e-invoice exports?
Exports are not on the list of excluded transactions. How a foreign buyer without a Peppol endpoint receives the document is handled through your provider; check with them how exports are exchanged and reported.
How quickly must an e-invoice be issued?
Within 14 days from the date of the transaction, which the decision defines as the earlier of when the transaction happened and when payment was received.
Where these facts come from
Checked against the following on 8 October 2026. Rules and dates change — if you are reading this long after that date, verify before you act on it.
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System
- Ministerial Decision No. 244 of 2025 on implementation
- Khaleej Times — provider appointment deadline extended to October 2026
- Ministry of Finance — eInvoicing programme
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