The UAE is replacing paper and PDF invoices with structured "electronic invoices". The change matters to any company in the UAE that sells to other companies or to the government, because its deadlines are close. This article is based on official announcements of the UAE Ministry of Finance, checked on 24 October 2026.
Legal basis
| Decision | Subject |
|---|---|
| Ministerial Decision No. 243 of 2025 | Scope and obligations of the electronic invoicing system |
| Ministerial Decision No. 244 of 2025 | Implementation timeline |
| Ministerial Decision No. 197 of 2026 | Amends some articles of Decision 243, in force from 1 October 2026 |
The Ministry of Finance announced the first two decisions on 29 September 2025 and says the system is built on the international OpenPeppol standard.
Scope
According to the Ministry of Finance:
- the system applies to all persons doing business in the UAE, for all business-to-business (B2B) and business-to-government (B2G) transactions, subject to specified exclusions;
- an electronic invoice is required for every business transaction;
- an "electronic credit note" is required for cancellations, reduced consideration, full or partial refunds and the correction of administrative or numerical errors;
- both the issuer and the recipient of the invoice must appoint an "Accredited Service Provider";
- a business outside the mandate may use the system voluntarily.
Standard, providers and voluntary use
The Ministry of Finance says the OpenPeppol standard was chosen so that the system is interoperable with other countries' systems, eases cross-border trade and protects data integrity. Both parties to a transaction must have their own accredited service provider. The Ministry of Finance has said it will publish the list of accredited providers.
A business that is not within the mandate may voluntarily issue, send, exchange and report electronic invoices and credit notes. For a company whose customers join the system earlier, starting voluntarily may make things easier.
Timeline
| Group | Deadline to appoint an accredited provider | Mandate starts |
|---|---|---|
| Selected pilot group | — | Pilot from 1 July 2026 |
| Businesses with annual revenue of AED 50 million or more | 30 October 2026 (extended from 31 July 2026) | 1 January 2027 |
| Businesses with annual revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| In-scope government entities | 31 March 2027 | 1 October 2027 |
On 10 May 2026 the Ministry of Finance announced the extension of the provider deadline for the large group and stressed that the 1 January 2027 start does not change. That announcement describes the group as "annual revenues above AED 50 million", while the 2025 announcement says "AED 50 million or more"; if your revenue is close to this line, ask the Ministry of Finance or an accredited provider which group you are in.
The October 2026 amendment
On 19 October 2026 the Ministry of Finance announced Decision No. 197 of 2026, in force from 1 October 2026:
| Change | Explanation |
|---|---|
| Tax group | Transactions between members of the same "tax group" are treated as "excluded transactions" for 24 months from 1 January 2027 |
| Data storage | Invoices, credit notes and related data must be kept for the period set in the tax procedures law and given to the Federal Tax Authority on request; the earlier requirement to store data inside the UAE was removed |
| System failure | The "system failure" provisions, including notifying the Federal Tax Authority within 2 business days, were removed |
A timeline example
This example is hypothetical and only puts the deadlines side by side.
| Company | Annual revenue | What is needed |
|---|---|---|
| Trading company A in Dubai | AED 80 million | Appoint an accredited provider by 30 October 2026; from 1 January 2027 issue electronic invoices for sales to companies |
| Service company B in a free zone | AED 10 million | Appoint a provider by 31 March 2027; mandate from 1 July 2027 |
| Company B, as a recipient | — | If it receives invoices from company A, note that the recipient must also have an accredited provider; ask the provider when exactly the recipient's obligation applies |
If A and B are members of the same tax group, the transactions between them are excluded for 24 months from 1 January 2027.
Checklist for companies
- Establish your annual revenue to know which group you are in.
- Choose an accredited service provider from the official list and sign before the deadline.
- Align your accounting or sales software with the provider; the Ministry of Finance has published the data an invoice must contain in its "mandatory fields" list.
- Define now how you will issue credit notes for cancellations and refunds.
- If you are a member of a tax group, take the 24-month exclusion into account when designing your processes.
- Align record keeping with the legal period.
E-invoicing and other obligations
Electronic invoicing does not replace VAT or corporate tax registration and returns. These are separate obligations; see our articles on UAE corporate tax and VAT.
Royal Golden does not give tax or e-invoicing advice. This article is general information and not tax advice.
Sources
- UAE Ministry of Finance, two ministerial decisions on the scope of obligations and the timelines of the electronic invoicing system (29 September 2025) — https://mof.gov.ae/en/news/ministry-of-finance-announces-the-issuance-of-two-ministerial-decisions-on-the-scope-of-obligations-and-the-timelines-for-implementing-the-electronic-invoicing-system-2/ (checked on 24 October 2026)
- UAE Ministry of Finance, targeted amendments to the e-invoicing system decisions (10 May 2026) — https://mof.gov.ae/en/news/ministry-of-finance-announces-targeted-amendments-to-einvoicing-system-decisions/ (checked on 24 October 2026)
- UAE Ministry of Finance, amendment of the electronic invoicing regulations to ease the burden on businesses (19 October 2026) — https://mof.gov.ae/en/news/ministry-of-finance-amends-electronic-invoicing-regulations-to-ease-the-burden-on-businesses/ (checked on 24 October 2026)
- UAE Ministry of Finance, e-invoicing page and guidelines — https://mof.gov.ae/en/about-ministry/mof-initiatives/einvoicing/ (via the search index; checked on 24 October 2026)
- UAE Ministry of Finance, e-invoice mandatory fields (23 February 2026) — https://mof.gov.ae/wp-content/uploads/2026/02/UAE-Electronic-Invoice-mandatory-fields_V-1.0-23Feb2026.pdf (via the search index; checked on 24 October 2026)