News Details

Introduction

Electronic Invoicing (“e-invoicing”) is rapidly becoming a global standard as Tax Authorities adopt structured, real-time compliance systems to improve transparency, reduce fraud, and streamline tax administration. While the UAE has long championed digital transformation, the introduction of structured e-invoicing within the Value Added Tax (“VAT”) regime marks a significant development in the country’s move, toward enhanced transparency and technology-driven tax administration.

This article builds on our earlier analysis of the UAE’s legislative updates to the Tax Procedures Law and the VAT Law, in which we outlined the formal introduction of the e-invoicing regime and the key statutory amendments issued under Federal Decree-Law No. 17 of 2024 and Federal Decree-Law No. 16 of 2024.

The present discussion expands on those developments by examining Ministerial Decision No. 243 of 2025 and Ministerial Decision No. 244 of 2025, which set out the scope of obligations and the phased implementation timelines for the UAE’s new Electronic Invoicing System (“EIS”). Together, these decisions operationalize the legislative foundation introduced last year and form a key part of the UAE’s broader strategy to modernize tax administration, accelerate business digitalisation, and align the VAT framework with international best practices.

Ministerial Decision No. 243 of 2025 – Scope of Obligations

Ministerial Decision No. 243 of 2025 sets out the core framework for determining which entities and transactions fall within the scope of the UAE’s EIS. The Decision suggests that all businesses engaged in business-to-business (“B2B”) and business-to-government (“B2G”) transactions in the UAE are required to comply with the E-invoicing obligations, unless the transaction falls within one of the specified exclusions.

These exclusions clarify the types of activities where traditional invoicing formats or sector-specific documentation will continue to apply. The key categories of excluded transactions are as follows:

1. Sovereign Activities: Business transactions conducted by Government Entities in a sovereign capacity, and not in competition with the private sector, in accordance with the UAE VAT Law.
2. International Passenger Transportation:  International passenger transport services provided by an airline via aircraft, where an electronic ticket (“E-ticket”) is issued to passengers.
3. Ancillary Airline Services: Ancillary services provided directly to passengers by an airline (e.g., baggage fees, seat upgrades), where an Electronic Miscellaneous Document (“EMD”) is issued for such services.
4. International Transport of Goods: International transportation of goods by air, where an Air Waybill is issued.  This exclusion, however, will only apply for a period of 24 months from the date the EIS becomes effective.
5. Financial Services: Financial services that are exempt from VAT or subject to VAT at the zero rate, as provided under the VAT Executive Regulation.
6. Other Transactions Determined by the Minister:  Any other business transaction that may be specified by the MoF through future guidance or decisions.

Under this framework, both the issuer and recipient of invoices are required to appoint an Accredited Service Provider (“ASP”) to facilitate the issuance, transmission, and archiving of e-invoicing and credit notes. The system will adhere to international standards to ensure interoperability, accuracy, and data integrity.

Ministerial Decision No. 244 of 2025 – Implementation Timelines

Ministerial Decision No. 244 of 2025 sets out a phased implementation roadmap for the UAE’s EIS, ensuring businesses have sufficient time to prepare their systems, processes, and compliance functions. The decision establishes a structured approach that begins with a pilot program and progresses through multiple phases based on business size and nature.

A pilot program will commence on 1 July 2026, involving a selected group of taxpayers.
This phase is intended to test the system, identify practical challenges, and allow both the Federal Tax Authority (“FTA”) and participating businesses to refine technical and operational requirements ahead of the full rollout.

Implementation timelines

The e-invoicing will be implemented in following phases:

Category	Annual Revenue Threshold	Appointment of Accredited Service Prover (ASP) by	Implementation of e-invoicing from
Large Business	≥ AED 50 million	31 July 2026	1 January 2027
Other Business	< AED 50 million	31 March 2027	1 July 2027
Government entities	Not Applicable	31 March 2027	1 October 2027

While the EIS is mandatory for B2B and B2G transactions, business-to-consumer (“B2C”) transactions are excluded at this stage. However, entities outside the mandatory scope may voluntarily adopt the system to streamline invoicing processes and ensure readiness for potential future requirements.

What it means for Businesses?

The introduction of e-Invoicing will fundamentally change how businesses issue, exchange, and store invoices in the UAE. Under the new system, invoices will need to be generated electronically through approved platforms and transmitted in real time via an ASP.

This means businesses will need to:

1. Integrate their accounting and enterprise resource practice (“ERP”) systems with E-invoicing technology;
2. Ensure invoice data is accurate, complete, and compliant with the prescribed format;
3. Select an ASP – Engage an ASP once the official list is released by the MoF; and
4. Adapt internal workflows for approvals, record-keeping, and data security.

While implementation may require upfront investment and process adjustment, the system will ultimately reduce manual errors, improve cash flow visibility, and streamline VAT reporting offering long-term operational efficiency and compliance benefits.

Conclusion

The introduction of the EIS represents a major milestone in the UAE’s ongoing digital transformation of tax compliance. As the country moves toward a more connected, transparent, and data-driven tax environment, businesses falling within the scope of the new rules are strongly encouraged to begin preparing without delay.

Proactive steps such as reviewing existing invoicing processes, upgrading ERP and accounting systems, coordinating with an ASP, and training internal teams will be essential to ensure smooth and timely compliance. Early preparation not only mitigates the risk of future non-compliance but also enables businesses to benefit from the operational efficiencies and automation that e-invoicing brings.

By providing clear guidance on both the scope of obligations and the phased implementation timelines, the MoF aims to facilitate a structured and supportive transition for the business community, while enhancing efficiency across the UAE’s tax administration framework and marking an important step toward a modern, fully digital tax ecosystem.

Seek Legal Counsel

Our expertise in tax law and regulations allows us to provide clients with effective and accurate tax advice, taking into consideration their unique circumstances and needs.

Our tax and financial crimes team, led by our Head of Tax and Financial Crimes, Mohamed El Baghdady, has successfully advised and represented clients across various industries, including, but not limited to, consumer goods and retail, services, real estate, oil & gas and banking and finance, before the Government authorities, tax tribunals and courts. Our clients have been successful in multiple tax disputes before the committees and courts.

For further information, please contact, Mohamed El Baghdady, Partner, Head of Tax and Financial Crimes, on mohamed.elbaghdady@habibalmulla.com.

Disclaimer

The content provided in this article is intended for informational purposes only and does not constitute legal advice. While every effort has been made to ensure the accuracy and completeness of this information, the article does not offer a guarantee or warranty regarding its content. The matters discussed in this article are subject to interpretation, and legal outcomes may vary based on specific facts and circumstances. We recommend that readers seek individual legal counsel before making any decisions based on the information provided. If you require specific legal advice, please contact us directly.