UAE E-Invoicing: A Buyer's Checklist

What the rules require

Ministerial Decision No. 243 of 2025 applies to any person doing business in the UAE, for every business transaction, except the exclusions in its Article 4. The main duties are:

Issue an electronic invoice for each business transaction, in a structured format that a computer can process (Article 6(1)).
Issue an electronic credit note when a transaction is cancelled, its price is reduced, money is refunded in full or in part, or an administrative or numerical error occurs (Article 6(2)).
Recipients process the invoices and credit notes they receive through the same system (Article 6(3)).
Issuers and recipients report them to the Federal Tax Authority within the timeline the Minister sets (Article 6(6)).
Meet all of these duties through an accredited service provider (Article 6(7)).
Carry the data fields the Ministry prescribes (Article 7). The current list is the Ministry's mandatory fields document, version 1.0, dated 23 February 2026.

Who must comply, and how fast

The clock starts on the date of the business transaction. That is the earlier of the transaction date and the date payment is received (Article 1).

A business that is registered for VAT follows the timeline in the VAT law (Article 6(4)). Any other issuer must send the e-invoice within 14 business days of that date (Article 6(5), as amended by Decision 197 of 2026, in force from 1 October 2026). Business days exclude weekends and official federal holidays (Article 1). The rules apply whether or not a business is VAT-registered (Article 3).

The decision excludes government entities acting in a sovereign capacity that do not compete with the private sector, some airline services, and financial services that are exempt from VAT or zero-rated (Article 4(1)). From 1 January 2027, business deals between members of the same Tax Group are excluded for 24 months (Article 4(1)(f), added by Decision 197 of 2026). A Tax Group is two or more persons registered for VAT as a single taxable person (Article 1). The Minister can add exclusions (Article 4(1)(g)). A business may also issue e-invoices voluntarily. The rules then apply to it, except the penalty rules (Article 4(3)).

The decision covers every business transaction. The Ministry's announcement of 29 September 2025 names business-to-business and business-to-government transactions. Ask your accountant how sales to consumers are treated.

The dates published so far

These dates come from the Ministry's announcement of 29 September 2025, as amended for the largest businesses by Ministerial Decision No. 66 of 2026. Decision No. 197 of 2026, in force from 1 October 2026, changed some of the rules above, but not these deadlines. The Ministry's e-invoicing page can change, so check it before you rely on a date.

Pilot: from 1 July 2026, with a selected group of taxpayers. Businesses may also issue e-invoices voluntarily (Article 4(3)).
Revenue of AED 50 million or more: appoint an accredited service provider by 30 October 2026, and go live by 1 January 2027.
Revenue below AED 50 million: appoint a provider by 31 March 2027, and go live by 1 July 2027.
Government entities: appoint a provider by 31 March 2027, and go live by 1 October 2027.

Accredited service providers

The issuer and the recipient each appoint an accredited service provider (Article 5(1)).
The Ministry publishes the list of accredited providers (Article 5(2)). Check that your provider is on it.
If your registered details change, tell the provider in writing within five business days of the Federal Tax Authority confirming the change (Article 5(3)).

What your software must do

Create each invoice and credit note as structured data, not only as a PDF.
Use the mandatory data fields in the current version of the Ministry's list.
Send each document through the provider within 14 business days of the transaction date, or within the VAT Law timeline if you are registered.
Produce a credit note for each of the four cases in Article 6(2), linked to the original invoice.
Record the date of each transaction as the earlier of the transaction date and the payment date.
Keep every invoice, credit note and associated data for the period the Tax Procedures Law sets, and be able to produce them for the Federal Tax Authority on request (Article 11). Storage in the UAE is no longer required.
Show clearly which invoices are not yet sent or processed, so that nobody misses the 14-business-day window.

Questions to put to every vendor, in writing

Are you an accredited service provider, or connected to one? Which one, and from which date?
Which version of the mandatory fields does your product use, and how quickly do you update it when the Ministry changes them?
What happens when the system is down, and how do we avoid losing a sale or missing a deadline?
Can you keep every invoice and credit note for the full retention period, and produce them for the Federal Tax Authority on request (Article 11)? Where is the data held?
Can you produce a credit note for a cancellation, a price reduction, a refund and an error, each linked to the original invoice?
Can we export every invoice and credit note, with its status, in a usable format?
How do you handle agents and self-billing, where the rules allow them (Articles 8 and 9)?

What to confirm with your accountant

Confirm whether your business must use the system now, and from which date. Confirm your VAT status and which timeline applies to you. Confirm how sales to consumers are treated, whether a Tax Group or any other exclusion applies, and whether you issue or receive invoices for other businesses. Then write the answers into your accounting policy.

Penalties

Cabinet Decision No. 106 of 2025 sets the penalties, as its annex table shows. AED 5,000 for each month, or part of a month, of delay in implementing the system or appointing a provider. AED 100 for each e-invoice or e-credit note sent late, up to AED 5,000 a calendar month for each type. AED 1,000 for each day of delay in notifying a provider of a change to registered data. The annex also sets AED 1,000 a day for late notice of system failures. Decision No. 197 of 2026 repealed the two-business-day notice to the Federal Tax Authority, so check with the Ministry whether those penalties still apply. The resolution does not apply to businesses that adopt the system voluntarily (Article 2(2)).

Where SSByte stands

We do not describe BYTE, or any other SSByte product, as compliant with or connected to the UAE e-invoicing system. BYTE is coming soon. Ask us in writing for the current status of any feature before you decide.

If you also do business in Jordan, our JoFotara checklist covers the Jordan system. For the ledger questions that apply to any vendor, read the accounting checklist.

Questions people ask

Do I need an accredited service provider?

If the rules apply to your business, yes. The issuer and the recipient each appoint one, and the duties are met through it (Articles 5 and 6(7)).

Does this apply to businesses with revenue below AED 50 million?

Yes, on a later timeline: appoint a provider by 31 March 2027 and go live by 1 July 2027, under the Ministry's announcement of 29 September 2025. Decision 197 of 2026, in force from 1 October 2026, did not change these deadlines.

Does it apply if my business is not VAT-registered?

Yes. The decision applies to any person doing business in the UAE. A business that is not VAT-registered has 14 business days from the date of the transaction to send its e-invoice (Article 6(5), as amended by Decision 197 of 2026).

Does the system cover sales to consumers?

The decision covers every business transaction, but the Ministry's announcement names business-to-business and business-to-government deals. Ask your accountant how sales to consumers are treated.

Do I still have to store the data in the UAE?

Not since 1 October 2026. Decision 197 of 2026 removed the storage requirement. You must keep the records for the period the Tax Procedures Law sets, and produce them for the Federal Tax Authority on request (Article 11).

Is SSByte's software connected to the UAE system?

We do not describe BYTE, or any SSByte product, as connected to the UAE system. Ask us in writing for the current status, and we will not describe a connection as live until it is.

Sources

This guide is general information, not legal or tax advice. The rules and dates are changing, so confirm them with your accountant and the Ministry of Finance before you decide. Talk to us for a written answer to any question here.

Read the JoFotara checklist → Read the accounting checklist → Talk to us