e-Invoicing in UAE: Key Requirements, Implementation Timeline & Latest Updates

By Rajan Rauniyar

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Updated on: Oct 15th, 2025

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29 min read

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The UAE has announced a phased rollout of mandatory e-invoicing under its new Electronic Invoicing System (EIS), beginning with a pilot in July 2026 and full implementation for VAT registered businesses in stages from 2027 onward.

Key Takeaways on UAE e-Invoicing

  • e-Invoicing in UAE applies to all VAT-registered entities for B2B and B2G transactions, excluding B2C and certain exempt sectors.
  • Large businesses with revenue ≥ AED 50 million must appoint an ASP by 31 July 2026 and implement mandatory e-invoicing from 1 January 2027.
  • Only machine-readable formats (XML/JSON using UBL or PINT) are valid; paper or PDFs won’t qualify.
  • Accredited Service Providers (ASPs) are mandatory for transmitting, validating, and storing invoices.
  • Federal Tax Authority (FTA) will monitor, regulate, and store all e-invoices for compliance.

What is e-Invoicing in UAE?

E-invoicing in the UAE refers to the electronic creation, exchange, and storage of invoices in a structured digital format under the government’s new Electronic Invoicing System (EIS). This move is part of the UAE’s wider strategy to digitize tax administration, enhance VAT compliance, and align with international best practices.

Unlike traditional paper or PDF invoices, a valid UAE e-invoice must:

  • Be issued in structured digital formats such as XML or JSON using standards like UBL or PINT.
  • Be transmitted through an Accredited Service Provider (ASP) using the Peppol-based DCTCE model (5-corner model).
  • Be reported and stored within the Federal Tax Authority’s (FTA) e-Billing System for monitoring and compliance.
  • Exclude manually created or unstructured formats (PDFs, JPGs, or paper invoices), which will not qualify as valid e-invoices.

e-Invoicing Implementation Timeline

The UAE government has released updated regulations through Ministerial Decision No. 243 of 2025 and Ministerial Decision No. 244 of 2025 on 28th September, which officially set out the phased rollout of the Electronic Invoicing System. 

The new implementation roadmap is as follows:

Phase

Category

Deadline to Appoint ASP

Mandatory Implementation Date

Pilot Programme

Selected businesses (Taxpayer Working Group)

Not Applicable

1 July 2026

Voluntary Adoption

Any business (optional)

Flexible

From 1 July 2026

Phase 1

Large businesses with revenue ≥ AED 50 million

31 July 2026

1 January 2027

Phase 2

Businesses with revenue < AED 50 million

31 March 2027

1 July 2027

Phase 3

All UAE Government Entities

31 March 2027

1 October 2027

e-Invoicing Requirements in UAE

To comply with the UAE’s new e-invoicing system, businesses must follow these key requirements:

  • Digital Format Only: Invoices must be created in XML or JSON formats (PDFs or paper invoices are not valid).
  • Structured Standards: Use recognized standards like UBL (Universal Business Language) or PINT (Peppol Invoice Standard).
  • Transmission Through ASP: All invoices must be sent and received via an Accredited Service Provider (ASP) approved by the Ministry of Finance.
  • Real-Time Submission: Invoices and credit notes must be transmitted through the system within 14 days of the transaction.
  • Mandatory Data Fields: Invoices must include all fields prescribed by the Ministry of Finance (seller details, VAT number, tax breakdown, etc.) in the Data Dictionary.
  • Digital Credit Notes: Credit notes must also be issued electronically in the same format and system as invoices.
  • Data Storage in UAE: All invoice and credit note data must be stored within the UAE, in line with the Tax Procedures Law.
  • System Failures: Any technical failure must be reported to the FTA within 2 business days, using the process it defines.

e-Invoicing Process in UAE

To comply with the UAE’s e-Invoicing mandate, businesses will need to follow a structured process supported by their ERP systems and Accredited Service Providers (ASPs). Here’s how it works in practice:

  1. Hire an Accredited Service Provider (ASP): Businesses must appoint an FTA-accredited ASP. The ASP works with your technical/ERP team to customize your ERP so that it can capture all relevant invoice data fields required by the FTA (often called the “data dictionary”).
  2. Map ERP Data to Standard Fields: Each e-invoice requires specific information such as seller/buyer details, VAT registration number, item description, taxable amount, VAT rate, total invoice value, etc. The ASP ensures your ERP is aligned with this data dictionary and maps the captured fields correctly.
  3. Convert to Required Format: Once details are entered in your ERP, the ASP’s core system converts the invoice into the mandatory digital format (XML or JSON) using approved standards like UBL or Peppol PINT.
  4. Validate and Enrich: Before sending, the ASP validates the data, corrects errors if any, and enriches the invoice with missing mandatory fields (such as standardized codes or unique identifiers) to ensure compliance.
  5. Real-Time Transmission: The ASP then transmits the invoice simultaneously to
  • The FTA’s e-Billing system, for monitoring and compliance.
  • The buyer’s ASP, so the recipient receives the invoice in a processable format.
  1. Secure Storage and Access: Both the issuer and recipient must securely store the e-invoice and related data inside the UAE as per FTA rules. Invoices remain accessible through the ERP or ASP portal for audits, reconciliations, and VAT filings.

e-Invoicing Framework in UAE

The UAE’s CTC e-invoicing framework, known as the "DCTCE" model, is based on the Peppol "5-corner" model. The "5-corner" model involves five main components:

  • Issuer: The party generating the invoice.
  • Receiver: The party receiving the invoice.
  • E-Billing System by FTA: Integrates with the Peppol PINT (Peppol Invoice Standard) for data exchange. The e-billing platform acts as an invoice repository but does not validate the invoices.
  • Sender Accredited Service Provider (ASP): Verifies the data and transmits the invoice to the tax authority and the receiver ASP
  • Receiver ASP:  Verify the received data and transmit the e-invoice to the purchase party (receiver) 

e-Invoicing Framework in UAE

Scope of e-Invoicing in UAE

The scope of e-invoicing in the UAE is defined under Ministerial Decisions No. 243 and 244 of 2025. The Electronic Invoicing System applies broadly to most business transactions carried out in the UAE, with certain exclusions and phased implementation requirements.

  • All VAT-registered persons engaged in taxable business transactions are required to issue and exchange electronic invoices and credit notes through the Electronic Invoicing System.
  • Both business-to-business (B2B) and business-to-government (B2G) transactions fall under the scope.

e-Invoicing Exemptions in UAE

Certain categories of transactions are excluded from mandatory e-invoicing under Article 4 of Ministerial Decision No. 243/2025:

  • B2C transactions are not subject to mandatory e-invoicing
  • Transactions conducted by government entities in a sovereign capacity that are not in competition with the private sector.
  • International passenger air transport services where electronic tickets are issued.
  • Ancillary airline services linked to passenger transport when an Electronic Miscellaneous Document (EMD) is issued.
  • International transport of goods by air, where an airway bill is issued. This exclusion applies for a limited period of 24 months from the system’s effective date.
  • Financial services that are VAT-exempt or zero-rated.
  • Any other transactions determined by the Minister of Finance.

Role of Accredited Service Providers (ASPs) in UAE e-Invoicing

As per UAE regulations, all taxpayers subject to the e-invoicing mandate must appoint an Accredited Service Provider (ASP) prior to implementation deadlines (July 2026: January/October 2027, depending on revenue and entity type). This requirement reflects the UAE’s decision to adopt a Peppol-based Continuous Transaction Control (CTC) model, where ASPs are central to ensuring compliance, accuracy, and secure transmission of e-invoices.

Key Functions of ASPs in UAE e-Invoicing

  • Data Mapping: Align invoice data from business ERP/accounting systems to FTA’s required structured formats (XML/JSON using UBL or PINT).
  • Validation: Check invoices against UAE’s e-invoicing schema, VAT law requirements, and Peppol standards before submission.
  • Data Enrichment: Add missing or required information (such as digital signatures, tax details, identifiers) to ensure compliance.
  • Format Conversion & Correction: Convert invoices from internal formats (e.g., PDF, CSV, Excel) into accepted machine-readable formats; correct errors before submission.
  • Transmission: Route invoices securely through the Peppol network to the Federal Tax Authority (FTA) and recipient ASP in real time.
  • Compliance Reporting: Ensure invoices and credit notes are reported to FTA within statutory deadlines (e.g., 14 days of transaction).
  • Security & Authenticity: Apply digital signatures, encryption, and tamper-proofing to maintain integrity and authenticity.
  • Integration Support: Provide APIs, middleware, and onboarding support for seamless ERP/business system integration.
  • Monitoring & Notifications: Track invoice status, provide real-time alerts for failures, and ensure fallback procedures during system downtime.
  • Archival & Storage: Enable secure storage of e-invoices and related data within UAE, as per retention requirements.

e-Invoicing Penalties for Non-Compliance

At present, the UAE government and the Federal Tax Authority (FTA) have not yet issued a dedicated schedule of fines for e-invoicing violations. However, the recent ministerial decisions indicate that enforcement will follow the existing administrative penalties regime under the Tax Procedures Law, which already governs VAT compliance breaches.

Businesses failing to comply with e-invoicing requirements will likely face the following penalties:

Violation / Non-Compliance

Anticipated Penalty

A taxpayer fails to issue an e-invoice for a B2B transaction

AED 2,500 per instance under “failure to issue electronic invoice” rules.

Repeated failure to issue e-invoices (e.g. multiple transactions)

AED 5,000 per instance (repeat offense).

Failure to maintain or retain e-invoice records in the approved manner

AED 10,000, rising to AED 20,000 for recurrence.

Delayed transmission of e-invoices leading to VAT misreporting or unpaid tax

Subject to late payment penalties: 2% of unpaid tax immediately, plus 4% monthly thereafter, capped at 300%.

Fraud, deliberate concealment, or repeated non-compliance

Exposure to criminal penalties or higher monetary fines beyond the standard administrative regime.

Note: Businesses must notify the Federal Tax Authority (FTA) of any system failure within 2 business days of occurrence. Failure to communicate such disruptions may itself constitute a compliance breach.

How ClearTax Can Help Your Business with e-Invoicing in UAE?

ClearTax is a pre-approved FTA and MoF-compliant Accredited Service Provider(ASP) that can help your business comply with the UAE’s e-invoicing requirements. ClearTax offers a Peppol-ready solution that seamlessly integrates your business system with the FTA portal, ensuring secure and compliant transmission of invoice data.

Here’s how ClearTax can assist:

  • Integration with the FTA Portal: ClearTax integrates your business system with the FTA’s e-billing system, ensuring that e-invoices are submitted in real-time, using the specified formats like XML or JSON.
  • Peppol-Ready: ClearTax follows the Peppol specifications for data exchange, ensuring compliance with the UAE’s Continuous Transaction Controls (CTC) model.
  • End-to-End E-Invoicing Solution: ClearTax provides a complete solution for issuing, submitting, and receiving e-invoices. It tracks the status of submitted invoices sends email notification for e-invoices.
  • Web-Based Portal: ClearTax offers a user-friendly web-based portal that allows you to manage the entire e-invoicing process in one place, from generating invoices to tracking their submission and status.
  • 100% E-Invoicing Compliance: With ClearTax, your business can achieve 100% compliance with the UAE’s e-invoicing regulations.

Conclusion

The UAE is advancing its tax digitization agenda with the introduction of mandatory e-invoicing through the Electronic Invoicing System (EIS). Set to begin with a pilot in July 2026, the system will be rolled out in stages starting 2027, initially targeting large businesses before expanding to all VAT-registered entities for B2B and B2G transactions. 

Accredited Service Providers (ASPs) will play a central role in transmitting and validating invoices through the FTA’s e-Billing platform, ensuring compliance, authenticity, and secure storage within the UAE. With strict compliance measures and penalties for violations, businesses are urged to begin preparations early, upgrading ERP systems and aligning operations with the new requirements.

UAE Government E-Invoicing Resources

References

Details

MoF e‑Invoicing Programme Portal mof

Central hub for UAE e‑invoicing updates and documents

MoF e‑Invoicing FAQs mof

Official FAQs on scope, rules, and processes

Accreditation of e‑Invoicing Service Providers mof

How ASPs apply and eligibility criteria

MoF Tax Legislation Portal mof

Repository of ministerial decisions and tax laws

FTA EmaraTax Portal eservices.tax

FTA’s platform for tax services and filings

FTA Guides, References & Clarifications tax

Official VAT guides and reference materials

UAE Gov: Digital invoicing

Government overview of digital invoicing

Ministerial Decision No. 243 of 2025 mof

Establishes scope, duties, exclusions, ASP appointment

Ministerial Decision No. 244 of 2025 mof

Phased rollout timeline and key deadlines

Public Consultation Document (Feb 2025) mof

Technical framework and data dictionary detail

Frequently Asked Questions

Is e-invoicing mandatory in UAE?

Not yet. Mandatory e-invoicing begins in phases from 1 January 2027 for large businesses (revenue ≥ AED 50M) and expands to all VAT-registered businesses by July 2027. A pilot programme starts in July 2026.

Can you invoice without a VAT number in UAE?

No. VAT-registered businesses must issue tax invoices with their VAT number. If a business is not VAT-registered, it cannot issue a valid VAT invoice.

What are the requirements for a valid e-invoice in the UAE?

Invoices must be generated in XML or JSON using structured standards like UBL or PINT, transmitted via an Accredited Service Provider (ASP), and reported to the FTA’s e-Billing system. PDFs, scans, or paper invoices are invalid.

What is the e-invoicing model used in the UAE?

The UAE has adopted a Peppol-based Continuous Transaction Control (CTC) "5-corner" model, where invoices pass through ASPs before being submitted to the FTA and shared with buyers.

Which transactions are exempt from mandatory e-invoicing?

Exemptions include B2C transactions, government activities in a sovereign capacity, certain airline and international transport services, exempt/zero-rated financial services, and others defined by the Ministry of Finance.

What are the key preparation steps for implementing e-Invoicing in the UAE?

  • Upgrade ERP/accounting systems for XML/JSON formats.
  • Select and onboard an FTA-accredited ASP before deadlines.
  • Test compliance during the voluntary phase (July 2026 onward).
  • Train staff on new invoicing workflows.
  • Budget for integration, digital signing, and storage costs.
What penalties apply for non-compliance?

Businesses may face fines such as AED 2,500 per missing e-invoice, escalating for repeated violations, AED 10,000–20,000 for improper record-keeping, and tax penalties for delays. Fraudulent practices may lead to criminal liability.

What is the best e-invoicing solution for UAE?

The best solution depends on your business needs. ClearTax is an excellent choice for businesses seeking 100% compliance with UAE's e-invoicing regulations, offering minimal lag time and seamless integration with the FTA portal.

What is Peppol FTA UAE?

Peppol FTA UAE refers to the UAE's adoption of the Peppol e-invoicing system to manage B2B and B2G invoices under the FTA's regulations.

Do small businesses need to comply with e-invoicing?

Yes. Even small VAT-registered businesses (with revenue < AED 50M) must comply from July 2027. Only purely B2C businesses are excluded.

Can I still send invoices via email?

Yes, but only after creating a valid e-invoice (XML/JSON) via an ASP and transmitting it through the FTA system. The emailed copy is just for reference; the structured digital invoice is the official record.

What is the standardized format for Peppol e-Invoicing?

Peppol e-invoicing uses digital formats like XML or JSON with structured standards such as UBL and PINT.

Will credit notes also need to be electronic?

Yes. Credit notes must be issued in the same structured digital format (XML/JSON) and transmitted through the FTA system within 14 days.

What happens if the ASP or FTA system goes down?

Businesses must notify the FTA within 2 business days of system failure. Invoices should be transmitted once the system is restored to remain compliant.

Do businesses need to store e-invoices locally?

Yes. All invoice and credit note data must be stored within the UAE in compliance with the Tax Procedures Law. Cloud storage outside the UAE is not acceptable.

Can existing ERP systems be used?

Yes, but they must be integrated with an ASP to ensure invoices are mapped, validated, digitally signed, and transmitted in the correct format.

How long must e-invoices be retained?

Invoices must be archived and retained for at least 5 years (or longer if specified under VAT law), and businesses must ensure secure, tamper-proof storage.

About the Author
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Rajan Rauniyar

Senior Content Writer- International
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I’m a Senior Content Writer at ClearTax, specializing in e-invoicing, VAT, and Tax compliance. Over the years, I’ve researched and written everything from blog posts to whitepapers and product guides, helping ClearTax expand in Malaysia, KSA, UAE, Singapore, Belgium, France and beyond. My goal is to write the most comprehensive, understandable, readable, and accurate content on any topic that has ever existed on the internet. Read more

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