Is your business ready for UAE e-invoicing?

The eInvoicing framework is a decentralised 5 corner model. The Service Provider will validate all data fields and report the data to FTA/MOF. There are two components in this model: (1) exchange and (2) reporting. A Service Provider shall validate all the fields of an eInvoice based on the UAE data dictionary before exchanging the invoice over the Peppol network. Subsequently all the tax data fields in an invoice shall be reported to the FTA system (Corner 5)

Businesses in the UAE must engage with an Accredited Service Provider to issue and receive eInvoices. The buyer's electronic address (endpoint) will be used to share the invoice over the Peppol network.

Each member of the VAT group must have an endpoint via a UAE Accredited Service Provider.

Each member of the VAT group should have an endpoint via a UAE Accredited Service Provider. When issuing an invoice, the group's Tax Registration Number (TRN) should be provided, but the endpoint details should correspond to the specific group member conducting the transaction.

In case of exports, if the foreign buyer is already registered within the Peppol network, then the endpoint (electronic address) of the buyer is required to be provided. If they are not registered, then a dummy endpoint will be provided. In such cases, exchange of document will not happen via the Peppol network, however, the Corner 2 (SP of seller) will continue to report the invoice to Corner 5. The seller is required to send the invoice to the buyer outside the network such as via email. It is not mandatory for the overseas buyer to register with a UAE eInvoicing Service Provider if he is not obligated to do so as per the UAE VAT and Corporate Tax law.

It is proposed to be a near real time integration between businesses and UAE Accredited Service Providers.

In case of self-billing, the buyer (customer) should create the eInvoice and will exchange the document with the seller and will also report to the FTA via the Accredited Service Provider.

Should there be an issue with the invoice, the Accredited Service Provider shall return the invoice to the issuer.

The invoice has to be exchanged between the seller and the buyer via an Accredited Service Provider who would transmit the invoice in the form of an XML and the Service Provider will also report the invoice data to the FTA.

The business should analyse their transactions and the resulting invoicing data against the data dictionary and ensure that they are compliant. Once the list of Accredited Service Providers is published by MoF, the businesses need to enter into a commercial arrangement with one of them and work on the integration between their systems to transmit the invoice.

The eInvoicing framework encompasses all business-to-business (B2B) and business-to-government (B2G) transactions, regardless of the VAT registration status of the entities involved.

• The interface between C1 to C2 and C3 to C4 is not regulated by the Ministry of Finance (MoF) or the Federal Tax Authority (FTA). It is subject to the arrangements made between the businesses (seller, buyer) and their Accredited Service Providers (ASPs). Typically, their integration would be based on Application Program Interfaces (APIs), web interfaces, or SFTP/ETL methods.
• The interface between C2 to C3 is regulated by Peppol and utilises the Peppol AS4 protocol.
• The connection between C2 to C5 is regulated by the MoF/FTA and utilises the Peppol AS4 protocol."

The businesses are not required to interact directly with the UAE PEPPOL Authority. Instead, the Accredited Service Provider (ASP) will liaise with the UAE PEPPOL Authority on their behalf.

Businesses that are onboarded to the eInvoicing platform will be listed in the PEPPOL directory. The URL to access the PEPPOL directory will be made available on the websites of the FTA/MOF.

No, there is no proposal in place for any inquiry of invoices from C1 to C5 or from C3 to C5.

Actual exchange of eInvoicing can start without the legislation and the 5th corner. You can join the pilot from the moment there are Accredited Service Providers and your business is ready to exchange eInvoices.

There will be a testing phase before going live with Accredited Service Providers and the FTA platform to ensure there are no issues during the exchange.

Yes, payment due date should be mentioned even if the payment is on the spot. The due date will be the same as the invoice date.

We are still working on the rollout strategy, but it will be a phased implementation, with businesses implementing at prescribed stages according to specific criteria and adequate notice shall be provided in advance of the requirements coming into effect.

It will be the Tax Identification Number (TIN), which is the first 10 digits of the Tax Registration Number (TRN) issued to the business.

Please note that even if you are part of a Tax Group, your TIN is the first 10 digits of your own TRN and not the first 10 digits of the Tax Group representative's TRN.

Taxpayers that have registered with the Federal Tax Authority (“FTA”) for any Tax type, will have been assigned a TIN already as part of this registration process. The TIN is the first 10 digits of the TRN that you have been issued.

Yes, he has to be onboarded to an Accredited Service Provider.

In case of any errors in tax invoices, a credit note is required to be issued for its rectification.

It is the obligation of the seller (UAE business) to ensure that the eInvoice generated is compliant to the UAE PINT framework and the eInvoice is reported to the FTA through their Accredited Service Provider. The transmission of the invoice to the buyer can be managed outside the Peppol network wherein the seller can generate a PDF and transmit to the buyer (overseas business in a none Peppol-compliant country).

Currently, the scope of UAE eInvoicing includes only B2B and business-to-government (B2G) transactions. However, if a taxpayer wishes to issue B2C invoices through the eInvoicing network, this can be decided between the taxpayer and their Accredited Service Provider, but such invoices should not be reported to Corner 5.

B2C transactions are not currently within the scope of UAE eInvoicing.

There is no requirement for QR codes to be printed on the eInvoices.

There are no additional requirements beyond those supported by Peppol.

The legislation will be released first, followed by information on the accreditation process. Service Providers can then submit their applications for accreditation. Once they meet all requirements, including testing with Peppol and the FTA’s EmaraTax system, they will be listed as Accredited Service Providers on the MoF and FTA websites.

For the end-user onboarding pilot testing, the MoF is seeking taxpayers who are already using Service Providers to issue eInvoices. An existing combination of the taxpayer and Service Provider is required for testing.

The legislation is currently being finalised, with the majority expected to be issued in March. These changes will enable eInvoicing and are not material changes. The rollout of eInvoicing will not follow a big bang approach, ensuring flexibility for companies issuing eInvoices and those using traditional methods. Provisions have been introduced in the VAT law and Tax Procedures law to facilitate these changes, followed by a cabinet decision and ministerial decision detailing the requirements.

The MoF cannot impose its standards on foreign vendors, so these invoices will not be required to be sent through the UAE eInvoicing network, and there will be no additional obligation on taxpayers to report these transactions.

Once everyone is onboarded, there will be no mechanism other than eInvoicing. As eInvoicing is rolled out, buyers and suppliers will be aware of how invoices are issued between them. When it becomes mandatory, invoices must be exchanged through the eInvoicing network. For those for whom it is voluntary, they should ideally use the eInvoicing network if they have the required capabilities. During the transition period, scenarios may arise where not all invoices are exchanged via the eInvoicing network, necessitating the preservation of all documents.

This should be discussed between the taxpayer and their Service Provider as part of the architecture. If the taxpayer is within the scope of eInvoicing, all B2B transactions in scope should pass through the eInvoicing network.

Credit notes are the standard mechanism to be followed. There is no concept of cancellation of an invoice.

Both the supplier’s invoice and the buyer’s invoice will be sent through the eInvoicing network. Please refer to the use cases detailed in the public consultation document for necessary clarifications. Document identifiers will help identify that they refer to the same transaction.

The accreditation procedure will be issued shortly, and Service Providers will be informed of the requirements to commence their applications for accreditation. Updates will be communicated through the website and direct communications.

Communication will be provided regarding a dummy identifier that should be used in the case of the seller. Your Service Providers will discuss this in more detail.

Since these invoices cannot be issued through the eInvoicing network, the MoF seeks to avoid imposing additional reporting obligations for these transactions.

There are identifiers that can be discussed with the Service Providers.

Yes, and the details of the rollout strategy will be announced in due course.

The seller's legal registration identifier type and buyer's legal registration identifier type fields in the Data Dictionary will allow for capturing trade licenses, Emirates IDs, or passports for sellers/buyers without a TRN. If the contract is signed with a business, it is considered a B2B situation, and eInvoicing would apply.

You can receive invoices from a foreign supplier via the Peppol network. However, the UAE’s Data Dictionary cannot be imposed on them, and you are not mandated to report this transaction through the eInvoicing system.

To issue or receive eInvoices, the seller and buyer must have an endpoint and be associated with an Accredited Service Provider, who will work with you on the specifics of issuing and receiving eInvoices.

All mandatory business fields must be provided by the seller to the ASP. The form and structure of sharing such fields must be agreed upon with your ASP.

As defined for Corporate Tax in the UAE, a business is identified by its Tax Identification Number (TIN).

Some local Emirates might require invoices in Arabic. You must comply with such local regulations.

Each business entity must use the same Accredited Service Provider (ASP) for both sending (accounts receivable) and receiving (accounts payable) eInvoices.

• There is no Peppol Authority in the UAE. To become a Peppol member, you must register through peppol.org and coordinate with info@peppol.eu for membership processing.
• To comply with UAE eInvoicing requirements, you must complete testing as per PINT-AE specifications. While your Peppol membership is recognised globally, transactions in the UAE must adhere to PINT-AE standards"

Establishments that are registered for VAT in the UAE, must include their VAT TRN on every eInvoice.

The rollout of eInvoicing is scheduled to commence in July 2026. The detailed rollout plan will be published soon by the Ministry of Finance.

Electronic receipts are not eInvoices. For more information, please refer to https://mof.gov.ae/einvoicing.

Please use the following channels to contact Peppol:

• Option 1: You can email info@peppol.eu for enquiries.
• Option 2: Visit https://openpeppol.atlassian.net/servicedesk/customer/portal/1 to submit any queries"

All businesses operating in the UAE are required to have a Tax Identification Number (TIN). All B2B transactions involving such businesses fall within the scope of eInvoicing. Businesses that are registered for VAT will also have a VAT Tax Registration Number (TRN) which must be captured on the eInvoice.

Further legislation will clarify how commercial invoices will be treated. The eInvoicing design will ensure that only business transactions are covered by these requirements.

Yes. In accordance with the UAE Electronic Invoicing Guidelines, Business Transactions carried out between members of the same VAT Group fall within the scope of the UAE Electronic Invoicing System and are not excluded solely by reason of being intra-group.

Yes. To support implementation readiness for VAT Groups, a temporary grace period applies in respect of Business Transactions carried out between members of the same VAT Group for a period of twenty-four (24) months commencing on 1 January 2027. During this period, the Electronic Invoicing obligations under Ministerial Decision No. 243 of 2025 will not be required to be implemented in respect of Business Transactions carried out between members of the same VAT Group

The grace period affects the timing of compliance only. It does not remove intra-group transactions from the scope of the UAE Electronic Invoicing System and does not affect the application of the Electronic Invoicing obligations to other Business Transactions carried out by the Person. Upon expiry of the grace period, the requirements of the UAE Electronic Invoicing System will apply in full in accordance with the applicable mandatory implementation phase.