UAE - E-invoicing Data Dictionary release for consultation

19 March 2025 – the United Arab Emirates (UAE) Ministry of Finance (MoF) released the electronic invoicing (e-invoicing) Data Dictionary for consultation, marking a pivotal move towards mandatory e-invoicing in the UAE. This document is crucial for businesses as it provides detailed technical specifications and (mandatory) data fields required for compliance. 

The purpose of the consultation is to gather feedback from businesses and e-invoicing service providers on the proposed elements of the UAE e-invoicing framework. The deadline to respond is 27 February 2025.

Join us for an informative webinar to discuss the data dictionary and its potential impact on your business on Thursday, 13 February 2025 at 13:00 UAE time. Please register using the following this link.
 

What is the Data Dictionary?
 

The Data Dictionary is a comprehensive document that outlines the specific data fields required for e-invoicing. It includes definitions, data types, mandatory requirements, and the structure for each data field that will be required to issue valid tax invoices and tax credit notes. The Data Dictionary enables companies to assess their systems’ capabilities, understand the nature of data gaps, and complete impact assessments, to enable a smooth transition and alignment with the MoF’s regulatory standards.

Tax considerations:

• Mandatory fields: The data dictionary specifies mandatory fields that must be reported to the FTA, some of which align with current Value Added Tax (VAT) invoicing requirements, while others are new and will require system updates.
• Human readable format: Some fields are mandatory only in the human-readable format (PDF), while others are required solely in the machine-readable format (XML), necessitating careful implementation to ensure compliance.

Technical considerations:

• UAE E-Invoicing Framework: The UAE plans to implement the Peppol 5 Corner model, known as the Decentralized Continuous Transaction Control and Exchange (DCTCE). This framework uses the Peppol International (PINT) data model, customized to “PINT AE” for UAE specifications.
• Invoice scenarios: It captures 16 different invoice scenarios with respective mandatory, conditional, and optional data fields, such as standard tax invoice, local reverse charge invoice, supply within Free Zone and continuous supply invoice. 
• Invoice type code: There are 3 main e-invoice type codes: commercial invoice, credit note, out of scope of tax.
• Total fields (business terms): There are 135+ fields, classified as mandatory, conditional or optional analyzed according to each transactional scenario.

Who is affected?
 

• All businesses issuing invoices B2B/B2G in the UAE.
• Service providers offering e-invoicing solutions.

Actions required for businesses
 

1. Review data: Businesses should examine their current invoicing data against the requirements outlined in the Data Dictionary to ensure alignment.
2. Ascertain gaps: Identify discrepancies between existing data and the new standards. Pay particular attention to new mandatory fields, as these may not be currently captured within your system. 
3. Consider responding to MoF consultation: Businesses should provide feedback by 27 February 2025.
4. Complete impact assessments: Evaluate how these changes will affect business processes (both AP & AR), systems, and IT infrastructure. Assess the effort needed to update systems and potentially manually intervene to capture and link new data fields.
5. Prepare for implementation:
   • Systems: Identify your functional and technical requirements for the e-invoicing solution of the ASP and ensure your billing, charging & ERP systems & processes are updated and compliant with the new e-invoicing requirements.
   • Train staff: Educate your team on the new procedures and data requirements for e-invoicing. 

How Deloitte can help
 

Deloitte offers a comprehensive 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 and preparing the consultation response to MoF
• Regulatory compliance and strategy development
• Functional and technical impact assessment
• Implementation of e-invoicing solution
• Go-live and post go-live support

Conclusion
 

The release of the e-invoicing Data Dictionary for consultation by the MoF is a pivotal step towards achieving a standardized and efficient invoicing framework in the UAE. Companies must act now to review their current data, ascertain process gaps, complete impact assessments, and prepare for implementation for a smooth transition to the new e-invoicing landscape. Business should also consider whether they are planning to respond to MoF consultation.

For further assistance or to discuss the specifics of your implementation strategy, please feel free to contact us.