UAE Announces Phased Rollout of National E-Invoicing System
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The end of September saw the publication of two critical Ministerial Decisions by the Ministry of Finance, updating the e-invoicing framework. The Ministerial Decisions are the culmination of the previous work undertaken on the UAE's e-invoicing journey, officially outlining the scope, timeline, and technical requirements for implementing e-invoicing nationwide.
Scope of Application and Implementation Timeline
The Ministerial Decisions state that e-invoicing will apply to nearly all businesses operating in the UAE, including non-resident or foreign taxable persons. However, there are some exemptions provided for government entities acting in a sovereign capacity, international airline and transportation services, VAT-exempt or zero-rated financial services, and any other activities excluded by the Minister of Finance.
The Ministry of Finance set the phased rollout approach. The first phase is a pilot phase, which will begin on July 1, 2026, for selected participants, followed by voluntary adoption from the same date. As of January 1, 2027, companies with annual revenues of AED 50 million (around USD 13.6 million) or more will be subject to mandatory e-invoicing. The mandatory e-invoicing will be extended to smaller businesses on July 1, 2027, and will finally include government entities from October 1, 2027.
Additionally, every business subject to mandatory e-invoicing will be required to appoint an Accredited Service Provider (ASP) to manage the e-invoicing process. It is also essential to bear in mind that under the e-invoicing rules and requirements, all electronic documents must be stored within the UAE.
Conclusion
In practice, the e-invoicing system includes B2B and B2G transactions, whereas B2C transactions are currently exempt from these requirements. Regarding the transactions that fall under the scope of mandatory e-invoicing, both the issuers and recipients will have to appoint an ASP to comply with the rules. Considering the official implementation timeline, early preparation will be crucial for achieving a smooth integration and full compliance once the regulations take effect.
Source: Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System, Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System

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