Rules as of 29 October 2026. Checked against Ministerial Decisions No. 243 and 244 of 2025, Ministerial Decision No. 66 of 2026, Cabinet Resolution No. 106 of 2025 and the Ministry of Finance e-invoicing guidelines (version 2.0, 26 October 2026).
The short answer: e-invoicing becomes mandatory in the UAE for business-to-business and business-to-government invoices. Companies with revenue of AED 50 million or more go live on 1 January 2027. Everyone else must appoint an accredited service provider by 31 March 2027 and go live on 1 July 2027. It applies whether or not you are VAT registered. Missing the deadline costs AED 5,000 a month.
What e-invoicing means in the UAE
An e-invoice is not a PDF. It is a structured XML file that your system sends to your customer's system through an accredited service provider, and the data is reported to the Federal Tax Authority (FTA). E-invoices have no QR code or barcode, and you can no longer send an invoice for a business sale as a PDF by email once your phase starts.
The UAE uses the international Peppol network with a UAE format called PINT-AE. The Ministry of Finance calls it a five-corner model:
- You (the supplier) create the invoice in your accounting system.
- Your service provider checks it and sends it over Peppol.
- Your customer's service provider receives it.
- Your customer gets it straight into their system.
- The FTA receives the tax data from the service providers.
Who must use e-invoicing
Ministerial Decision No. 243 of 2025 applies to any person doing business in the UAE, for every business transaction, unless the person or transaction is excluded. The Ministry's guidelines confirm this applies regardless of VAT registration. A business that is not registered for any tax must still register with the FTA to get a Tax Identification Number (TIN).
| Transaction | In scope? |
|---|---|
| Business to business (B2B) | Yes |
| Business to government (B2G), government to business, government to government | Yes |
| Business to consumer (B2C) | Not yet: excluded until the Minister issues a decision. A business that sells only to consumers is out of scope for now |
Excluded transactions include sovereign government activities that don't compete with the private sector, international airline passenger tickets and related services, international air cargo with an airway bill (for 24 months from go-live), and financial services that are VAT exempt or zero-rated under Article 42 of the VAT Executive Regulation.
The deadlines
| Who | Appoint a service provider by | Go live by |
|---|---|---|
| Pilot group (invited by the Ministry) | – | From 1 July 2026 |
| Anyone who wants to start early | – | Voluntary from 1 July 2026 |
| Revenue of AED 50 million or more | 30 October 2026 | 1 January 2027 |
| Revenue under AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities | 31 March 2027 | 1 October 2027 |
Revenue means the gross income in your most recent accounting period, as shown in your financial statements. The deadline for large businesses to appoint a provider moved from 31 July to 30 October 2026 under Ministerial Decision No. 66 of 2026. The go-live date of 1 January 2027 did not change.
VAT groups: invoices between members of the same VAT group get a 24-month grace period from 1 January 2027. Invoices to anyone outside the group follow the normal dates.
What you must do once you are live
- Issue and send every e-invoice through your service provider. If you are VAT registered, within the VAT law timeline; if not, within 14 days of the transaction.
- Issue an e-credit note when a sale is cancelled, the price is reduced, goods or money are returned, or there was an error.
- Receive and process e-invoices from your suppliers through the system.
- Store e-invoices and their data inside the UAE for the record-keeping periods of the Tax Procedures Law.
- Tell the FTA about a system failure within 2 business days.
- Tell your service provider about changes to your FTA registration details within 5 business days of the FTA confirming them.
Your Peppol identity is built from your TIN, which is the first 10 digits of your TRN. If you are in a tax group, it is your own TRN, not the group's.
The six types of e-invoice
The Ministry of Finance guidelines list six categories. There is no separate category for provisional invoices: a provisional invoice must also be an e-invoice, and later changes go on a credit note or an extra invoice.
| Document | Normal billing (supplier issues) | Self-billing (buyer issues) |
|---|---|---|
| Tax invoice (VAT-registered supplier, taxable sale) | Electronic tax invoice | Self-billed electronic tax invoice |
| Tax credit note | Electronic tax credit note | Self-billed electronic tax credit note |
| Commercial invoice (no tax invoice needed: exempt or out-of-scope sales, or a supplier not registered for VAT) | Commercial e-invoice | Not available |
| Credit note for a commercial invoice | Electronic credit note | Not available |
So if you are not VAT registered, your normal invoices become commercial e-invoices. PDF or paper commercial invoices are replaced too.
What goes on an e-invoice
The fields are set by Peppol's PINT-AE specifications and by the list of mandatory fields that the Ministry of Finance publishes. Besides the usual details (seller, buyer, TINs, dates, lines, amounts), every line needs a tax category, and some situations need extra fields. The guidelines describe eight special scenarios, from Free Zone sales to exports. Most accounting software fills these in for you once it is connected to a service provider.
Free Zone companies: one extra detail
Free Zone companies are in scope like any other business. One of the eight scenarios covers sales to, from or within a Free Zone. When your customer is a Free Zone company, the e-invoice also needs the beneficiary: the person or company that actually uses or owns what you supplied. In most B2B sales, that is simply your customer.
If your customer isn't on the system yet
During the rollout, some buyers will still be waiting for their own phase. The guidelines say a buyer that has not implemented e-invoicing yet may still ask you for a separate tax invoice or commercial invoice, for example to recover its VAT. Your obligation to issue the e-invoice stays the same once your own phase starts.
Penalties
Cabinet Resolution No. 106 of 2025 sets the fines for businesses that must use e-invoicing:
| Violation | Fine |
|---|---|
| Not appointing a service provider or not going live on time | AED 5,000 per month |
| Not issuing or sending an e-invoice on time | AED 100 per invoice, up to AED 5,000 a month |
| Not issuing or sending an e-credit note on time | AED 100 per credit note, up to AED 5,000 a month |
| Not telling the FTA about a system failure on time | AED 1,000 per day |
| Not telling your service provider about changed registration data on time | AED 1,000 per day |
Businesses using e-invoicing voluntarily are not fined until their mandatory phase starts.
How to get ready: a checklist for small businesses
- Check your revenue for your latest financial year to know your phase.
- Get your TIN: if you are not registered for VAT or corporate tax, register with the FTA first.
- Check your accounting software: can it produce PINT-AE invoices and connect to a service provider?
- Choose an accredited service provider from the list the Ministry of Finance publishes, and sign before your deadline.
- Clean your customer data: you need each business customer's TIN and Peppol identifier.
- Test a few invoices and credit notes before your go-live date.
- Train whoever issues invoices, and decide who reports system failures.
Clean, up-to-date books make this much easier, because e-invoices come straight out of your accounting system. See our accounting services and VAT guide.
Questions
When does e-invoicing start in the UAE?
Voluntarily from 1 July 2026. It is mandatory from 1 January 2027 for businesses with revenue of AED 50 million or more, and from 1 July 2027 for all other businesses. Government entities follow on 1 October 2027.
Do I need e-invoicing if I am not VAT registered?
Yes, if you sell to other businesses or the government. The Ministry of Finance guidelines say e-invoicing applies regardless of VAT registration status, and you must register with the FTA to get a Tax Identification Number.
Does e-invoicing apply to sales to consumers?
Not yet. Business-to-consumer sales are excluded until the Minister of Finance issues a decision. A business that sells only to consumers is out of scope for now.
Can I keep sending PDF invoices?
Not for business customers once your mandatory phase starts. An e-invoice must be a structured XML file sent through an accredited service provider.
What are the mandatory fields on a UAE e-invoice?
They are set by Peppol's PINT-AE specifications and the Ministry of Finance's published list of mandatory fields. They include the seller and buyer details and TINs, dates, line items, amounts and a tax category for every line, plus extra fields in special cases such as Free Zone sales.
Do Free Zone companies need e-invoicing?
Yes. Free Zone companies are in scope like any other business. When the customer is a Free Zone company, the e-invoice also records the beneficiary of the supply.
What is the fine for missing the e-invoicing deadline?
AED 5,000 for each month you have not appointed a service provider or gone live, under Cabinet Resolution No. 106 of 2025.
How long must I keep e-invoices?
For the record-keeping periods in the Tax Procedures Law, and the data must be stored inside the UAE.
Sources
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (Ministry of Finance)
- Ministerial Decision No. 244 of 2025 on implementation and Ministerial Decision No. 66 of 2026
- Cabinet Resolution No. 106 of 2025 on e-invoicing fines (Ministry of Finance)
- UAE Electronic Invoicing Guidelines, version 2.0, 26 October 2026 (Ministry of Finance)
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