UAE Introduces Nationwide Electronic Invoicing System

Phased Rollout Begins January 2027

Issuance of Ministerial Decisions:

On 29 September 2025, the UAE Ministry of Finance (MoF) issued two Ministerial Decisions introducing the Electronic Invoicing System:

Ministerial Decision No. 243 of 2025 – Outlines the scope, framework, and obligations of the system.
Ministerial Decision No. 244 of 2025 – Sets out the rollout plan and implementation timelines.

Scope of Application:

The Electronic Invoicing System applies to all Persons conducting Business in the UAE for every Business Transaction, except where transactions or persons are specifically excluded. The Minister may also extend its application to other persons or transactions as deemed necessary.

Excluded Transactions:
The following are exempt from mandatory electronic invoicing (“Excluded Transactions”):
Business transactions carried out by Government Entities in a sovereign capacity that are not in competition with the private sector, as defined under the VAT Law.
International passenger transportation services provided by an airline, including ancillary services provided directly to passengers.
International goods transportation services provided by an airline where an Airway Bill is issued, with this exclusion limited to a 24-month period from the effective date of the Electronic Invoicing System.
Financial services that are either VAT-exempt or zero-rated.
Any other Business Transactions as may be determined by the Minister.

Excluded Persons:
The category of persons exempt from the system (“Excluded Persons”) will be specified through a separate ministerial decision.

Voluntary Participation:
Excluded Persons and persons engaging in Excluded Transactions may voluntarily implement electronic invoicing if they choose.

Pilot Programme:

A Pilot Programme will begin on 1 July 2026, involving participants from the Taxpayer Working Group, subject to their written consent to join.

Mandatory Implementation Phases of the UAE Electronic Invoicing System

The Electronic Invoicing System will be introduced in three phases, based on the category of the Person and their revenue levels, as outlined below:

Phase	Category	*Accredited Service Provider appointment**	Go-Live Date
1	Person whose revenue* is equal to or exceeding AED 50 million	31 July 2026	1 January 2027
2	Person whose revenue* is less than AED 50 million	31 March 2027	1 July 2027
3	Government Entity	31 March 2027	1 October 2027

Key Notes:

*Accredited Service Provider refers to an Accredited Service Provider, who must be appointed by the relevant deadline to facilitate compliance with the system.
**A “Person” refers to any individual or entity subject to the Electronic Invoicing System.
***Revenue means the gross income earned during the most recent Accounting Period, as reflected in financial statements prepared in accordance with UAE legislation.

If financial statements are unavailable, revenue may be determined using other acceptable documentation approved by the Federal Tax Authority (FTA).

Additional Key Provisions of the UAE Electronic Invoicing System:

Voluntary Early Adoption:

Any Person may voluntarily implement the Electronic Invoicing System starting from 1 July 2026, even if not yet required to do so.

Exclusion of Business-to-Consumer (B2C) Transactions:

Business-to-Consumer Transactions are not subject to the Electronic Invoicing System until a later date to be determined by a ministerial decision.
A Business-to-Consumer Transaction is defined as a Business Transaction carried out between:

A Person conducting Business, and
A recipient who is a natural person not conducting Business.

Persons engaged exclusively in B2C transactions remain outside the system’s scope until further notice.

Issuance Deadline:

Electronic invoices and credit notes must be issued and transmitted within 14 days from the date of the underlying business transaction.
For any questions or clarifications regarding e-invoicing compliance, our in-house VAT experts are available to provide guidance and support.