UAE Ministry of Finance Opens Public Consultation on Proposed E-Invoicing Regime

The UAE Ministry of Finance published a Public Consultation Document regarding the proposed introduction of an e-invoicing regime. The primary purpose of the consultation is to receive feedback from industry leaders and other key stakeholders on the adopted decentralized continuous-transaction control-and-exchange (DCTCE) five-corner model e-invoicing system.

All interested parties have until February 27, 2025, to submit their comments and opinions on the proposed e-invoicing data requirements.

Key Details of the Proposed UAE E-invoicing Regime

The Public Consultation Document (PCD) emphasizes that under the four-pillar program “We the UAE 2031,” one of the principal government goals is to enhance its performance and improve digital infrastructure. To achieve this goal, the UAE government recognized the importance and effectiveness of e-invoicing.

The comprehensive PCD follows the Ministry of Finance's announcement in October 2024 that it had adopted the DCTCE e-invoicing model as a central part of the national e-invoicing regime. On the same occasion, 2025 was marked as the year when the e-invoicing legislation will be discussed and adopted. The implementation of the e-invoicing system is defined for 2026, when phase one is expected to go live.

This is the first public consultation on the subject, and the Ministry of Finance hopes to develop an e-invoice regime suitable for the UAE business environment.

The primary matter in this consultation is whether the data dictionary covers all the required fields, whether there are any conflicts or issues with the existing fields in the data dictionary, whether industry-specific data elements are correctly represented, and whether there are any noticeable potential issues in reporting any specific transaction through the proposed e-invoicing regime.

Conclusion

Although the main question opened for this public consultation may seem technical, the Ministry of Finance underlined that clarity is needed for all key stakeholders to understand what each field represents and how it is used, regardless of the technical knowledge.  

That is why an additional question in this public consultation is whether stakeholders find any fields or terms confusing or subject to multiple interpretations. From this, it is apparent that the UAE government is approaching the task of implementing e-invoicing strategically to establish a well-functioning and effective system.

Source: UAE Ministry of Finance, eInvoicing Programme Consultation Paper