UAE e-invoicing: Accredited Service Provider (ASP) appointment deadline extended, but go-live remains 1 January 2027

What has changed

The MoF has extended the Phase 1 deadline for appointing an ASP from 31 July 2026 to 30 October 2026. This extension applies to businesses with revenue of AED 50 million or more.

What has not changed

The Phase 1 go-live date remains 1 January 2027. Businesses should continue implementation planning on the assumption that e-invoicing obligations will apply from that date.

Why the extension matters

The additional time may help organisations:

• Finalise ASP selection and contracting
• Complete onboarding activities with the chosen ASP
• Allow more time for integration planning and testing

However, the extension does not remove the need to progress readiness activities early, particularly where enterprise resource planning (ERP) changes, data remediation, and multi-entity rollouts are required.

Recommended actions now

To stay on track for go-live, businesses should consider:

• Confirming scope and impacted flows (entities, invoice types, customer/supplier scenarios)
• Performing a data gap assessment against expected e-invoicing requirements
• Selecting and appointing an ASP, then agreeing onboarding and delivery timelines
• Designing and implementing required system and process changes (including controls and governance)
• Running end-to-end testing with the ASP well ahead of go-live

Risks of delaying

Delays in readiness may increase the likelihood of:

• Invoice rejection or payment delays if invoices are not compliant
• Increased scrutiny from the Federal Tax Authority (FTA)
• Value Added Tax (VAT) recovery challenges if invoice requirements are not met
• Potential penalties for missed deadlines or non-compliance

How Deloitte can help

Deloitte is an MoF-accredited ASP and can support e-invoice transmission, validation, and FTA reporting, alongside advisory support such as readiness assessments, implementation support, and testing/go-live planning.