The UAE Ministry of Finance, in coordination with the Federal Tax Authority (FTA), has issued Ministerial Decisions No. 243 and 244 of 2025, introducing the national Electronic Invoicing System (EIS), the UAE’s first unified electronic invoicing framework pursuant to Federal Decree-Law No. 8 of 2017 on Value Added Tax.
Decision No. 243 defines the scope and requirements of the system, while Decision No. 244 establishes the phased implementation timeline. Together, these decisions represent a major milestone in the UAE’s digital tax transformation and alignment with international compliance standards.
Scope and Requirements
The E-Invoicing System applies to business-to-business (B2B) and business-to-government (B2G) transactions. Business-to-consumer (B2C) transactions are not yet in scope and will be included under a later ministerial decision.
Key Exclusions
Certain transactions are excluded from the system’s initial scope, including:
- government-in-sovereign-capacity activities not competing with the private sector;
- international passenger air transport supported by electronic tickets and ancillary passenger services supported by electronic miscellaneous documents;
- international goods transport supported by an air waybill (for 24 months following system commencement);
- VAT-exempt or zero-rated financial services.
Accredited Service Providers (ASPs)
Under the new system, all invoices and related documents must be issued, transmitted, and stored through an Accredited Service Provider (ASP), a licensed technology entity authorized by the Ministry of Finance and the FTA to operate within the national E-Invoicing System.
Both issuers and recipients are required to appoint an ASP through which invoices and related documents will be processed. Invoices must include all mandatory data fields and formats prescribed by the Ministry.
The Ministry of Finance has also released an initial list of pre-approved ASPs, which will be updated periodically to include new providers. This flexibility allows businesses to select from a broader pool of service providers to meet their operational needs.
(Note: The list of accredited providers is available on the Ministry of Finance website.)
Standards and Interoperability
The programme references the OpenPeppol international standard, ensuring interoperability, security, and efficient cross-border data exchange. This aligns the UAE with global best practices, promoting consistency and credibility in electronic invoicing across jurisdictions.
Each transaction must be supported by an electronic invoice, while electronic credit notes must be issued for cancellations, refunds (full or partial), adjustments, or administrative corrections.
Date | Applies to | Requirement |
1 July 2026 | Selected taxpayers (pilot) and voluntary adopters | Pilot programme by written agreement; voluntary adoption permitted. |
31 July 2026 | Businesses with ≥ AED 50 million annual revenue | Appoint ASP by this date. |
1 January 2027 | Businesses with ≥ AED 50 million annual revenue | Go live on e-invoicing (mandatory). |
31 March 2027 | Businesses with < AED 50 million and in-scope government entities | Appoint ASP by this date. |
1 July 2027 | Businesses with < AED 50 million | Go live on e-invoicing (mandatory). |
1 October 2027 | In-scope government entities | Go live on e-invoicing (mandatory). |
Implications for Businesses and Practitioners
- Compliance Planning. Businesses should determine which revenue threshold applies to them, identify reporting obligations, and appoint ASPs early. Aligning accounting systems with OpenPeppol standards will be critical for readiness.
- Contractual Adjustments. Procurement, supply, and service agreements may require amendments to clearly allocate e-invoicing responsibilities and ensure counterparties comply with technical standards
- Governance and Training. Companies should update internal accounting policies, establish controls for issuing, receiving, and correcting invoices electronically, and conduct staff training on new workflows
- Advisory Opportunities. Legal and tax professionals can provide essential support in system integration, ASP contracting, risk assessment, and dispute prevention related to e-invoicing compliance.
Risk of Non-Compliance. Failure to comply after the effective deadlines could lead to penalties, administrative complications, and weakened ability to substantiate tax positions before authorities.
The rollout of the UAE’s E-Invoicing System is more than a technology upgrade; it marks a legal and operational transformation in how businesses document, verify, and defend their tax obligations. With clear deadlines and international standards embedded in the framework, proactive preparation is key.
Businesses that plan early, review contracts, and modernize accounting systems will be best positioned to transition smoothly and maintain full compliance once the EIS formally takes effect.
Our legal team would be pleased to assist you in understanding the implications of these developments and their relevance to your business. You are welcome to reach out to Mamdouh Tawfik at m.tawfik@alsuwaidi.ae, Suneer Kumar at suneer@alsuwaidi.ae, Vida Grace Serrano at vida@alsuwaidi.ae and Rajiv Suri at r.suri@alsuwaidi.ae.