UAE MoF Releases e-Invoicing Guidelines for Business and Government Entities

As anticipated in the late evening of February 23, 2026, the UAE Ministry of Finance (MoF) released the official Electronic Invoicing Guidelines (hereinafter: “e-Invoicing Guidelines”) on February 24, 2026.This comprehensive reference document – 46 pages long – is designed to support businesses in efficiently preparing for the implementation of the e-invoicing system across the UAE as part of the broader “We the UAE 2031” vision.The e-Invoicing Guidelines build upon various legislation released in the last few months, such as:

• Ministerial Decision (MD) No. 243 of 2025 on the Electronic Invoicing System.
• Ministerial Decision (MD) No. 244 of 2025 on the Implementation of the Electronic Invoicing System.
• Ministerial Decision (MD) No. 64 of 2025 on the eligibility criteria and Accreditation procedure for Service Providers under the Electronic Invoicing System.
• Cabinet Decision (CB) No. 106 of 2025 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System.

Implementation timeline and identification number The implementation timeline for e-Invoicing provides that a pilot program (by invitation only) will commence on July 1, 2026, with voluntary adoption available from the same date, followed by phased mandatory implementation as follows:

Persons within scope will be required to appoint an Accredited Service Provider (ASP) to facilitate both the issuance (accounts receivable) and receipt (accounts payable) of e-Invoices. Importantly, responsibility for compliance remains with the supplier, including obtaining the buyer’s Peppol participant identifier, in collaboration with the ASP. It is important to note that persons or Government Entities may face penalties for failing to issue or process e-Invoices. Penalties include administrative fines for breaching VAT and tax invoicing laws, as well as specific e-Invoicing penalties. The latter do not apply to voluntarily issued e-Invoices.

The ASP onboarding process must be initiated by the taxpayer via the EmaraTax portal. For identification purposes under the e-Invoicing framework, the participant identifier will comprise “0235” followed by the Tax Identification Number (TIN), corresponding to the first 10 digits of the TRN issued by the FTA. For tax groups, the representative member’s TRN will be disregarded, and each member’s TIN will be used instead. Persons within the scope of e-Invoicing but not registered for any tax in the UAE will be required to register with the FTA to obtain a TIN.

Scope and Coverage

Upon full implementation, e-Invoicing will apply to all persons conducting business in the UAE, irrespective of their VAT registration status or place of establishment, unless specifically excluded per MD No. 243 of 2025.

E-Invoicing applies to all in-scope business transactions between Persons and Government Entities, unless specifically excluded. It also applies to supplies to Government Entities. However, it does not apply to supplies involving natural persons acting outside a business capacity, including where billing agents are used. Notably, no e-Invoice is required for consumer supplies (i.e., B2C transactions). The e-Invoicing Guidelines clarify that investment holding companies fall outside the scope of e-Invoicing, since they typically earn only passive income, unless they recharge operational or other costs to third or related parties. In such cases, they must register for e-Invoicing.

The e-Invoicing Guidelines clarify that transactions between members of the same VAT group fall within the scope of e-Invoicing. However, a 24-month transitional relief applies from 2027, during which intra-group transactions between VAT group members will be exempt from e-Invoicing, after which standard e-Invoicing obligations will apply. Non-resident persons required to issue Tax Invoices under the UAE VAT Decree-Law must issue such invoices as Electronic Invoices. However, Imports of “Concerned Goods” and “Concerned Services” subject to the reverse charge mechanism under Article 48 of the VAT Decree-Law are not subject to e-Invoicing requirements.

E-invoicing categories and invoicing rules 

E-Invoicing rules differ from VAT tax invoice requirements. Taxable persons must continue to issue tax invoices and credit notes in XML format, and may need to issue separate invoices where the buyer has not yet implemented e-Invoicing. In such cases, where the buyer does not have a Participant Identifier, suppliers must include the predefined endpoint (0235:9900000098) on the Electronic Invoice.

Section 10 of the e-Invoicing Guidelines outlines six e-invoice categories, such as Electronic Tax Invoice, Electronic Tax Credit Note, Commercial Invoice, Electronic Credit Note, and their self-billed equivalents. It is important to emphasize that e-Invoicing encompasses both VAT-related invoices and commercial invoices, i.e., invoices relating to goods that are exempt or out of scope for VAT purposes, or supplies made by Persons who are not registered for VAT.

Provisional invoices, i.e., invoices issued before the final transaction details (such as quantity, price, or applicable taxes) are fully determined, must also be issued as e-Invoices, with adjustments made through credit notes or additional invoices. The e-Invoicing Guidelines also emphasize the distinction between standard billing and self-billing, noting that self-billing is permitted only under VAT rules for registered parties and is not available for commercial invoices.

Administrative exceptions granted under the VAT Executive Regulation for issuing tax invoices or tax credit notes do not apply to Electronic Invoices or Electronic Credit Notes.

Special Invoicing Scenarios

The e-Invoicing Guidelines further detail eight specific scenarios – (1) Free Zone transactions, (2) Deemed supplies, (3) Margin scheme supplies, (4) Summary invoices, (5) Continuous supplies, (6) Agent billing, (7) e-Commerce transactions, (8) Exports – each with particular data and reporting requirements. For instance, where the customer is a Free Zone entity, the Electronic Invoice must also include beneficiary details in addition to customer details.

The e-Invoicing Guidelines emphasize that when multiple scenarios apply to a supply, the specific requirements for each scenario must be included in the e-Invoice issued for that transaction. Additionally, the following mandatory tax categories are explained: standard rate, exempt, out-of-scope, reverse charge, zero-rated, and margin scheme, including clarification of domestic reverse charge obligations for specified goods.

Record retention requirements

Electronic invoices must be issued, transmitted, and received in XML format and will not include QR codes or barcodes.

Persons subject to the e-Invoicing system must store electronic invoices, credit notes, and associated
data in accordance with the retention requirements under the UAE Tax Procedures Law. The requirement is considered met where records are securely stored in an electronic system that preserves their integrity and allows prompt retrieval and reproduction by the FTA.

While the legislation refers to storage “within the State”, this requirement is intended to ensure that records remain accessible, verifiable, and reproducible by the FTA, regardless of the physical location of servers or cloud-based storage infrastructure.

“Associated data” refers only to information necessary to validate the authenticity and integrity of the electronic invoice or electronic credit note, and does not extend to broader commercial documentation.

Additional Guidance Issued

The e-Invoicing Guidelines also contain three Appendices:

• Appendix 1 covers a step-by-step guide for businesses to get ready for e-Invoicing.
• Appendix 2 provides a high-level, indicative checklist for businesses and government entities to ensure their readiness for e-Invoicing.
• Appendix 3 lists the various business and government entities involved in the process and their respective responsibilities.

Together with the e-Invoicing Guidelines, the UAE MoF released two other documents relating to:

• Considerations for selecting an ASP. This document provides a list of considerations for a Person or Government Entity to consider when deciding which ASP to onboard for UAE e-Invoicing. These considerations require scrutiny at various levels, including evaluating the Company History, Geographical Reach, Product Ownership, Integration and Data Management, Compliance and Security, Customer Support and Service Level Agreements (SLAs), Pricing Structure, Scalability, and future proofing.
• UAE Electronic Invoice Mandatory Fields. This document provides a list of mandatory fields for both an electronic Tax Invoice and a commercial Electronic Invoice (XML), including Invoice Details, Seller Details, Buyer Details, Document Totals, Tax Breakdown, and Invoice Line.

Conclusion

With the release of the e-Invoicing Guidelines, the implementation of the UAE e-Invoicing system has entered a significant operational phase. Businesses should begin assessing system readiness, evaluating ASP providers, and reviewing transaction flows and invoicing processes to ensure compliance with the upcoming requirements.

Please do not hesitate to contact us if you would like to discuss the implications of the new e-Invoicing framework or assess your organisation’s readiness for the upcoming UAE e-Invoicing.