Regulatory updates - United Arab Emirates

Scope

The Decisions, outline that the Electronic Invoicing System must be used by all entities conducting business in the UAE for all business-to-business (B2B) and business-to-government (B2G) transactions, with only a few exceptions. Businesses not within the scope may voluntarily comply.

In-scope businesses must send and receive their electronic invoices and credit notes through the system compliant with the required data fields, using their appointed accredited service provider (ASP).

Timeline

The roll-out will adhere to the following timelines:

• July 1, 2026: Pilot Program begins with selected taxpayers

Mandatory obligations then extend to large businesses with annual revenues equal to or exceeding AED 50,000,000 (approximately 11.59 million EUR):

• July, 31, 2026: Deadline to appoint an ASP
• January, 1, 2027: Mandatory implementation

For other businesses with annual revenue below AED 50,000,000 (approximately 11.59 million EUR), the following dates apply:

• March 31, 2027: Deadline to appoint an ASP
• July 1, 2027: Mandatory implementation

Lastly, the requirement extends to in-scope government entities:

• March 31, 2027: Deadline to appoint an ASP
• October 1, 2027: Mandatory implementation

Taxpayers in scope are advised to appoint an ASP ahead of their deadlines and familiarize themselves with the technical requirements.

In its announcement on September 29, 2025, the UAE Ministry of Finance released the list and contact details of pre-approved e-invoicing service providers, naming Pagero as one of the pre-approved providers.

The inclusion of Pagero on the list acknowledges fulfillment of the legislative requirements and capabilities in supporting taxpayers subject to the upcoming UAE e-invoicing and CTC obligations.

Stay connected with Pagero to receive timely updates as further details about the UAE e-invoicing mandate are released.

The Federal Tax Authority has issued Cabinet Decision No. 100 of 2025, effective from 29 September 2025, introducing major amendments to the tax invoices and credit notes articles of the VAT Executive Regulations. 

Main changes include: 

• Simplified tax invoices are no longer an option with e-invoicing: 

If a business is required or opts to issue electronic invoices, it must provide a full tax invoice. This applies regardless of the previous cases where simplified tax invoices were permitted (i.e., when the recipient is not tax registered or when the invoice value is less than AED 10,000). 

• Mandatory e-invoicing for zero-rated transactions: 
  The previous regulation stated that if a supply is zero-rated and the taxpayers keep sufficient records, they may not need to issue any tax invoice at all. The new amendments change this: if you are required (or choose) to issue electronic invoices, a tax invoice must be issued for this transaction. 

• Revised requirements for credit notes: 
  The old regulation required businesses to include the original total invoice amount, the corrected total invoice amount, and the difference between the two. When e-invoicing is adopted, it will be sufficient to only disclose the credit note amount along with the applicable VAT.

• Old exceptions to issuing tax invoices may not apply when e-invoicing is rolled out: 
  The amendments indicate that the Federal Tax Authority (FTA) will not grant exceptions from issuing e-invoices or credit notes. It is likely that current exceptions already given to businesses will be withdrawn once e-invoicing takes effect, this however, is subject to more clarification from the FTA.  

What is next? 

• The official list of Accredited Service Providers, who will facilitate the implementation of the 5-corner model, is expected to be published soon. 

• Details on rollout timelines for the phased implementation are yet to be announced. 

• Regulations or guidelines are expected to be published soon to give more clarity on implementation rules, transitional periods, and other practical aspects.