Release of UAE E-Invoicing Legislation

30 September 2025 – The implementation of e-invoicing in the United Arab Emirates (UAE) has taken another step forward, with the release of key legislation to enact the framework. Notably, two Ministerial Decisions have been released which provide further details announcing the effective date for UAE e-invoicing and providing clarity on the applicable go-live dates under each wave.  

Importantly, the Ministerial Decisions confirm that, following the initial go-live date of 1 July 2026 for the Taxpayer Working Group, all businesses with revenue exceeding AED 50M must have appointed an Accredited Service Provider (ASP) by 31 July 2026, and must have implemented e-invoicing by 1 January 2027. 

Prior to the appointment of an ASP, businesses must typically have conducted an impact assessment, performed vendor selection based on their identified requirements and have outlined their project plan. As many large-scale businesses will likely require more than six months to effectively comply with the e-invoicing requirements, the release of the legislation is timely to allow organisations sufficient notice to plan and resource projects adequately by beginning preparations now. 

Additionally, a limited number of exceptions have been announced for key industries – in particular for certain financial services transactions and certain services performed by airlines. Further exceptions are not expected to be announced at a later date, and therefore businesses can prepare with certainty that all transactions other than those excluded by the Ministerial Decisions will fall within the scope of e-invoicing.

These details are contained in Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System and Ministerial Decision No. 244 of 2025 on its phased implementation issued by the Ministry of Finance. Together, these decisions establish the legal and operational framework for the UAE’s e-invoicing regime, aligning the UAE with international best practices and enhancing Value Added Tax (VAT) compliance and reporting.

Key highlights

Ministerial Decision No. 243 of 2025 – Electronic Invoicing System

• Scope: Applies to all persons conducting business in the UAE in respect of their business transactions, unless specifically excluded.
• Exclusions:
  • Sovereign activities of government entities which are not in competition with the private sector.
  • Certain international passenger and goods transportation services by airlines (with transitional rules).
  • Certain exempt financial services including when those qualify for zero-rating.
• Obligations:
  • Businesses must issue, transmit, and report electronic invoices and credit notes through the Electronic Invoicing System.
  • Transmission must occur within 14 days from the date of the business transaction (non-VAT registered businesses), or in line with the VAT time of supply rules (VAT registered businesses).
  • Both issuers and recipients must appoint an Accredited Service Provider.
• Reporting: All electronic invoices and credit notes must be reported to the Federal Tax Authority (FTA) within timelines to be prescribed.
• Data and storage: Businesses must retain invoice and credit note data within the UAE in accordance with the Tax Procedures Law.
• System failure: Notification to the FTA is required within two business days of any system outage.

Ministerial Decision No. 244 of 2025 – Implementation Framework

• Pilot programme: Launches 1 July 2026, involving selected businesses (Taxpayer Working Group) to test the system under Ministry/FTA supervision.Voluntary adoption: Any business may opt in from 1 July 2026.
• Mandatory adoption:
  • Businesses with revenue ≥ AED 50 million must appoint a service provider by 31 July 2026 and go live by 1 January 2027.
  • Businesses with revenue < AED 50 million must appoint by 31 March 2027 and go live by 1 July 2027.
  • Government entities must appoint by 31 March 2027 and go live by 1 October 2027.
• B2C transactions: Currently excluded until further notice.

Next steps for businesses

• Assess impact: Determine whether your business falls within the scope of mandatory implementation and which phase applies. Commence impact assessments to determine the extent of work required to adapt systems and processes and to onboard relevant technology.
• Prepare systems: Review ERP and invoicing systems for readiness to issue and transmit structured e-invoices and credit notes and prepare a project plan to make the required changes.
• Engage with service providers: Based on requirements identified during the impact assessment, monitor the Ministry’s publication of Accredited Service Providers, undertake vendor selection and plan for timely onboarding.
• Redesign: Undertake the necessary source system, process and data improvements across the organization and cater for sufficient testing.
• Pilot participation: Businesses may consider early voluntary adoption or participation in the pilot programme to mitigate risks.
• Compliance processes: Establish internal policies for reporting, record retention, and handling system failures.

Deloitte’s view

The introduction of e-invoicing represents a significant step in modernizing the UAE’s VAT compliance framework. The phased timeline provides businesses with an opportunity to prepare, but the technical and operational requirements are substantial. Early planning will be key to ensuring smooth implementation.