19 June 2025 – The United Arab Emirates’ (UAE) Ministry of Finance (MoF) has officially released the first version of the UAE Peppol International (PINT AE) specifications. This foundational documentation establishes the technical framework for businesses and service providers to align their systems with the UAE’s e-invoicing requirements, which will be rolled out in phases as part of the country’s broader digital transformation strategy.

The PINT AE specifications, which closely mirror the anticipated data dictionary, provide comprehensive guidance on the structure of e-invoices and credit notes. They detail the invoice fields, the technical validations and rules governing these fields, their classification as mandatory, conditional, or optional based on specific scenarios, and the overall technical requirements for compliance. This release builds upon the initial draft of the data dictionary shared for public consultation earlier this year, offering businesses a clearer roadmap to meet the standards necessary for seamless integration with the UAE’s e-invoicing ecosystem.

Businesses should now prioritize reviewing their current invoicing processes and systems against the PINT AE specifications. Conducting impact assessments and identifying gaps will be critical to ensuring readiness for compliance. Engaging with potential Accredited Service Providers (ASPs) early will help businesses streamline their implementation efforts and avoid disruptions as the mandatory requirements come into effect. 

Key Insights from PINT AT

While the documentation addresses numerous technical and practical topics previously pending from the perspective of ASPs, it also highlights several key points relevant to businesses, such as:

• Six (6) invoice document types are introduced to reflect the announced use cases:
  • 380 - Commercial invoice
  • 480 - Invoice out of scope of tax
  • 381 - Credit note
  • 81 - Credit note related to goods or services (Ed. note: applies for out of scope of tax)
  • 389 - Self-billed invoice
  • 361 - Self-billed credit note
• Classification of Special transaction types has been confirmed as mandatory, and businesses must indicate whether an invoice falls under any of the following categories:
  • Free trade zone
  • Deemed supply
  • Profit margin scheme
  • Summary invoice
  • Continuous supply
  • Disclosed agent billing
  • Supply through e-commerce
  • Exports
• Intercompany transactions remain unaddressed in the context of their potential inclusion in e-invoicing; however, the UAE framework already specifies requirements for member-specific details, including TIN and separate Peppol endpoints for each group member.
• Imports remain outside the scope of e-invoicing obligations, as the MoF has clarified that it cannot impose its standards on foreign vendors and aims to avoid additional reporting requirements.

For this release of PINT AE, businesses can refer to Peppol UAE electronic document specifications here.

Technical Considerations

While the PINT AE specifications lay out the technical foundation for the UAE e-invoicing system in detail, certain aspects remain open for further clarification in the future, including:

Human readable format: The PINT AE specifications do not explicitly define which mandatory, or conditional fields must be visible on the human-readable format (e.g., PDF) of the e-invoice. 

Tax data document: Although it is established that certain fields in the Data Dictionary are designated for inclusion in the Tax Data Document (TDD), the precise list of these fields has not been explicitly outlined in the currently available documentation.

Attachments in invoices: are allowed and may include supportive documents (e.g., work reports, certificates) but not invoice copies or images (e.g. PDF). Receivers must be able to receive and convert such files (from embedded objects into usable formats) but are not required to handle or process their content, as these documents are purely informative.

Field conditions per use case: The PINT AE specifications do not provide a direct list of mandatory and conditional fields for each use case. Instead, compliance must be deduced by compiling and applying the various rules outlined in documentation. In contrast, the draft Data Dictionary for public consultation clearly identified mandatory fields for each use case.

Sample values & field data types: Like the field conditions per use case, PINT AE provides multiple e-invoice samples in XML format. However, a comprehensive and unified list of all e-invoicing fields, accompanied by sample values, field data types, and limitations, may still be expected in future updates or announcements.

Given these circumstances, an official announcement by MoF regarding the finalized Data Dictionary—potentially addressing the points above—may still be forthcoming.

For the latest information on the e-invoicing program, businesses should refer exclusively to the official MoF website here.

How Deloitte can help

Deloitte offers a range of services to assist businesses in managing the implementation of e-invoicing effectively, including but not limited to:

• Support with reviewing impacts on business 
• Regulatory compliance and strategy development
• Functional and technical impact assessment
• Implementation of e-invoicing solution
• Go-live and post go-live support

Notice

This alert has been written in general terms and does not constitute any form of advice or recommendation by Deloitte and, therefore, cannot be relied on to cover specific situations; application of the principles set out will depend upon the particular circumstances involved and we highly recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Deloitte accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action due to any material in this publication.

Deloitte Middle East would be happy to help readers understand how to apply the principles set out in this publication to their specific circumstances.

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Contact us

Our Tax experts listed below would be happy to discuss the above matters in more detail or support you through a further discussion on your specific requirements. 

Marjolein van Delft
marvandelft@deloitte.com

Mark Junkin
majunkin@deloitte.com

Kenneth Lei
kelei@deloitte.com

Jack Sims
jacksims@deloitte.com