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UAE e-invoicing: who must comply, the deadlines and what to do now

The UAE is moving business invoices onto a national electronic invoicing system. Invoices and credit notes between businesses will travel as structured data through accredited service providers, and the tax data is reported to the Federal Tax Authority (FTA) as each invoice is exchanged. The rules are in Ministry of Finance Decisions No. 243 and No. 244 of 2025, as amended in 2026.

Who must comply

• Any person doing business in the UAE, for its business transactions: sales to other businesses and to government. It is not limited to VAT-registered businesses.
• Sales to consumers (people not in business) are not in scope until the Minister decides otherwise, and a business that sells only to consumers is not in scope either.
• Some transactions are excluded, for example VAT-exempt and zero-rated financial services, airline passenger tickets and government activity in a sovereign capacity.
• Transactions between members of the same VAT tax group are excluded for 24 months from 1 January 2027 (Decision No. 197 of 2026).

The deadlines

Your phase depends on your revenue: the gross income of your most recent accounting period, from your financial statements (or other records the FTA accepts).

• From 1 July 2026: a pilot with selected businesses, and any business may start voluntarily.
• Revenue of AED 50 million or more: appoint an accredited service provider by 30 October 2026 (moved from 31 July 2026) and go live by 1 January 2027.
• Revenue below AED 50 million: appoint an accredited service provider by 31 March 2027 and go live by 1 July 2027.
• Government entities: appoint a provider by 31 March 2027 and go live by 1 October 2027.

What counts as an e-invoice

• An invoice issued, sent and received in a structured electronic format that systems can process automatically. In the UAE that is an XML file following the Peppol PINT-AE specification.
• A PDF, a scan or an emailed invoice is not an e-invoice. E-invoices carry no QR code or barcode.
• It must contain the mandatory fields the Ministry publishes. An electronic credit note is needed when a sale is cancelled, reduced, refunded or corrected.
• It must be issued and sent within 14 business days of the transaction; a VAT-registered business also keeps to the VAT deadline for tax invoices.
• If your customer is not on the system yet, you still send the e-invoice and also give them a regular tax invoice, for example a PDF.

How it works: the 5-corner model

1. You, the supplier, send the invoice data from your accounting system to your accredited service provider.
2. Your provider checks it, turns it into the UAE XML format and sends it over the Peppol network.
3. Your customer's provider receives and checks it.
4. Your customer receives it in their own system.
5. The providers report the tax data to the FTA.

Only accredited service providers (ASPs) connect to the network; a business cannot connect directly. The Ministry of Finance publishes the list of accredited providers on its e-invoicing page.

Penalties

Cabinet Decision No. 106 of 2025 sets AED 5,000 for each month, or part of a month, of delay in implementing the system or appointing a provider, and AED 100 for each e-invoice or electronic credit note not issued and sent on time, up to AED 5,000 a month. Businesses that start voluntarily are not penalised before their own mandatory date. The Ministry's October 2026 programme overview lists a newer Cabinet Decision No. 173 of 2026 on these penalties, so check the amounts in force on the Ministry's e-invoicing page.

What to do now

1. Work out your revenue for your latest accounting period, so you know your phase and dates.
2. List where your invoices come from: your accounting software, other billing tools and anything issued by hand.
3. Check that your customer and supplier records have the correct names, addresses and TRNs.
4. Choose an accredited service provider from the Ministry's list and agree the contract.
5. Onboard with that provider through EmaraTax (you start this, not the provider) and get your Peppol participant ID.
6. Test sending and receiving e-invoices with your provider well before your go-live date.
7. Keep e-invoices, credit notes and their data for the period the Tax Procedures Law sets.

BOSS ERP Mini and e-invoicing

BOSS ERP Mini issues the tax invoices and credit notes the FTA asks for today. It does not send e-invoices yet: we are adding e-invoicing support before the 1 July 2027 date for businesses below AED 50 million. BOSS ERP Mini is not an accredited service provider.