e-Invoicing Implementation in the UAE (A Complete Guide)

𝗲-𝗜𝗻𝘃𝗼𝗶𝗰𝗶𝗻𝗴 𝗜𝗺𝗽𝗹𝗲𝗺𝗲𝗻𝘁𝗮𝘁𝗶𝗼𝗻 𝗶𝗻 𝘁𝗵𝗲 𝗨𝗔𝗘

𝗘𝘅𝗲𝗰𝘂𝘁𝗶𝘃𝗲 𝗦𝘂𝗺𝗺𝗮𝗿𝘆

The MoF has advanced its digital compliance framework with the implementation of Ministerial Decisions No. 64, 243, and 244 of 2025, establishing the regulatory foundation for nationwide e-Invoicing. These decisions collectively define the technical, procedural, and operational standards for real-time invoice reporting and validation, thus marking a transformative milestone in the UAE’s tax system.

Under this framework, all taxable entities are required to issue and transmit structured e-invoices in compliance with the MoF specifications, directions and recommendations, for integrating with the ERP system and selecting Accredited Service Providers (ASPs). The measures ensure authenticity, integrity, and traceability of invoices while reducing manual errors and administrative burdens.

Organizations are required to prepare by keeping the system ready for assessments, control alignment, and compliance testing in accordance with the MoF’s published guidelines. Beyond regulatory adherence, this digital shift enhances operational efficiency, strengthens tax governance, and positions businesses for smarter, data-driven decision-making in a fully connected economy.

This presentation provides a structured roadmap for understanding the regulatory requirements, system integration approaches, and internal control measures essential for successful e-Invoicing implementation in the UAE. It serves as a practical guide for finance and IT leaders to align strategy, compliance, and technology in readiness for the FTA’s digital mandate.

1. Compliance with the Ministerial
Decisions 243 & 244 of 2025
e-Invoicing
in the UAE
Ahmad Tariq Bhatti
FCMA (Pak), ACMA (UK), CGMA (USA), FPFA

2. e-Invoicing initiative supports UAE’s Vision 2031
for the digital economy.
Its benefits include:
Transparency
Fraud reduction
Faster settlements
Compliance with the VAT law

3. Why e-Invoicing?
Scope
Mandatory for the B2B& B2Gtransactions
Exception is given to B2Ctransactions (for at least now)
Not applicable to excluded transactions
Objectives
Improve tax compliance & reduce evasion
Streamline business operations
Minimize errors & disputes
Faster invoice validation & shorter payment cycles
Impact:Increased transparency in transactions
3e-invoicing Initiative

4. The e-Invoicing
system aims to improve
efficiency, transparency, and
accuracy of financial
transactions.
It involves structured and secure
electronic exchange of invoices,
contributing to streamlined
business practices and effective
compliance with the
tax regulations.
Introduction to e-Invoicing

5. What’s e-Invoicing?
Electronic Invoicing (e-Invoicing) is the automated exchange of invoices in
a structured digital format between a supplier and a buyer, in compliance
with the MoFand FTA’s instructions.
Characterized by:
Legally valid, reliable &verifiable
Digital transmission &storage
Reduces manual errors & processing time
Workflow for e-Invoicing system:
Supplier → Supplier’s ASP (validation) → EIS/FTA (registration) → Buyer’s ASP → Buyer
5e-invoicing Initiative

6. 1 3
2
Defines boundaries and exceptions
termed as excluded transactions
Clarity on Exclusions
•Businesses must adapt e-invoicing systems by July 01, 2026
•Ensure alignment with the OECDe-invoicing standards
•Avoid penalties for late or non-compliance
Compliance Challenges
Shifts tax compliance to digital
platforms
Digital Transformation
Significance &Impact

7. Improves regulatory compliance
&accuracyin financial
transactions
Greater Transparency
Minimizes dispatching cost, &
labor costs involved in manual
processes
Cost Reduction
Faster processing &approval of
invoices, reducing payment delays
& disputes
Time Efficiency
Benefits of e-Invoicing

8. 4. Buyer’s ASP processes &accepts
validated invoice
Buyers ASP
Processing
3. Invoice is registered with EIS/FTA for
statutory compliance
EIS/FTA Registration
2. Validated by ASP based on compliance
rules
ASP Validates Invoice
1. Supplier sends invoice electronically for
validation &registration
Supplier Initiates Invoice
End-to-End Workflow

9. Automated ASPsystems
reduce manual entry errors
in buyer’s processes
Error Reduction
Buyer's systems integrate
with ASPsfor seamless
transaction processing
Integration Benefits
Facilitates smooth and accurate receipt of
invoices from suppliers
Role of ASP
Role of the Buyer’s ASP

10. Challenges &Solutions
Challenges Solutions
1. User Resistance Comprehensive Training Programs
2. Integration Issues Use Middleware/Interface Solutions
3. Compliance Understanding Regular Regulatory Updates
4.Technical Glitches & Errors Dedicated IT Support

11. E-Invoicing Process
Here is given a step-by-step workflow for e-invoicing for B2B and B2G under MD243 of 2025:
1.The seller records a transaction in its system (sales order, delivery, etc.)
2.The invoicing module captures all required data fields per the MoFdata dictionary
3.The system generates an electronic invoice(or credit note, if there is an adjustment) in the
structured format (e.g. as per Peppol/PINT AEschema)
4.The invoice is submitted to the business’s appointed ASP
5.The ASPvalidates the invoice against the dictionary rules/schema.
•If errors, rejects or returns error messages to the business for correction
•If valid, forward the invoice data through the EIS
6.The recipient (buyer) receives the e-invoice through its own ASPand processes it via EIS
7.The e-invoice (and any credit notes) is reported to the FTAvia the infrastructure
8.The business retains the invoice data locally (in the UAE) for the required retention period of 7 years
9.If any system outage or failure occurs, the business must notify the FTAwithin 2 business days and
follow fallback procedures
10.If any corrections or amendments are needed after issuance, they must be processed within 5
business days via the ASP/EIS

12. Software & Integration Cost
e-Invoicing software or ERP integration cost (depending on company size)
Compliance & Training
Staff training and compliance setup
Maintenance & Support
Ongoing system updates and support
Note:
•Costs are normally based on ERPsystem’s complexity, invoice volume, and
automation level
Implementation Cost

13. What Companies Need to Do?
Prepare Systems & Processes
Upgrade ERP/accounting systems to support e-invoicing
Register & Comply
•Ensure registration with the FTA portal
•Follow e-invoicing guidelines given by the FTA and format requirements
Staff Training
Educate and train teams on workflow, IRN generation, and reporting
Integration
•Connect internal systems with the FTA for automatic validation
•Conduct pilot tests before the system goes live
13e-invoicing Initiative

14. •Legalities of e-Invoicing
•Applies to: B2Btransactions &
B2Gtransactions
•Excluded B2Cfor the time being
•Businesses must determine its
classification: ≥AED 50M, <AED
50M, Govt, B2C
Legal Implementation
•Government transactions
•International transport of
passengers & goods
•Exempt & zero-rated supplies
under the VATlaw
•Any transaction that the
FTA/MoFwants to exclude
Exclusion Details
Outlines transactions
within and outside the
scope of e-Invoicing
system
Scope Definition
Establishes the EIS's
structural guidelines
Rules & Framework
Understanding Ministerial Decision 243

15. •Possibility of declaring more
exclusions in due course
•Exempt or zero-rated VAT
supplies
Ministerial Discretion
International airlines are excluded
•International passenger flights
•Ancillary services provided
directly to passengers by
airlines
•International transportation of
goods
Air Transport Services
Business transactions by govt entities while acting in a sovereign capacity
•Government activities (not-competing with the private sector)
Government Transactions
Excluded Transactions
Businesses can voluntarily issue, share, and report e-invoices even in the excluded cases.

16. Specifies entities and thresholds for
implementation for different phases
Scope Clarifications
•Details implementation process
•Entities must onboard ASPs
•Phased adoption to allow a smooth
transition
Implementation Details
•Builds on MD 243for execution
•Focuses on rollout deadlines &
obligations
Complementary Decision
Implementation Program
under Ministerial Decision 244

17. B2C transactionsare currently outside the scope of mandatory e-Invoicing
Companies must assess their classification:
large businesses ≥ AED 50 million revenue,
smaller businesses < AED 50 million revenue,
government entities, or
B2C operators
to align them with the applicable implementation deadlines/dates
Early coordination with an ASPis essential to ensure smooth and seamless
integration
Businesses should also evaluate the readiness of their ERP systemsto issue and
transmit structured e-invoices, and begin onboarding and compliance testing well
ahead of deadlines
Workflow Alignment

18. How to Prepare for the Implementation?
1.Businesses must assess when they fall under the mandatory regime (based on revenue
thresholds) and plan the implementation work accordingly.
2.Early adopting or joining the pilot and tax payer working group programthat can help
mitigate risks. It will allow selected participants, upon signing an agreement, to collaborate with
the MoFand FTAto test their e-invoicing system. It will commence on 01/07/26.
3.Internal systems, data capture, mapping, and governance must be adjusted in advance to
meet the required structured format.
4.Appointing an accredited ASPand performing thorough testing before go-live is essential.
The MoFwill publish a list of ASPsin due course.
5.Data retention obligations and cross-checking system resilience (backup, disaster recovery)
become more critical.
6.Businesses should look for any further guidance (e.g. Technical specifications, error code
catalogs) published by the MoFor FTA.

19. Allows time for business adjustments
Gradual Adoption
Applies primarily to the B2B & B2G transactions
B2B &B2G Transactions
Phased implementation is starting from July 01, 2026
Time Frame for Implementation Program
Implementation Process
01
02
03

20. Keep abreast with the latest
compliance guidelines and updates
from the MoF& FTA
Regular Updates
Engage or appoint a FTA-approved
ASP. The list of approved ASPswill be
shared shortly
Partnerships with an ASP
Train teams for new processes,
developments, and updates to
the ERPsystem
Staff Training
Ensure system readiness for changes
and ensure correct adoption of
the e-invoicing system
System Upgrades
Preparation &Compliance Strategies

21. e-Invoicing Phased Rollout of Deadlines
Under MD 244 of 2025
Subject Action Deadlines
1. Scope
Applies to all VAT-registered businesses and
government entities.
Voluntary participation allowed
From 01 July 2026 (voluntary)
2. Pilot Programme
Selected participants ('Taxpayer Working Group')
for early adoption and testing
Launches 01 July 2026
3. Businesses with Revenue ≥
AED 50M(≈$13.6M)
Appoint an ASPand implement the system
ASPby 31 July 2026
Go-live by 01 Jan 2027
4. Businesses with Revenue <
AED 50M(≈$13.6M)
Appoint an ASPand implement the system
ASPby 31 Mar 2027
Go-live by 01 Jul 2027
5. Government Entities Appoint an ASPand implement the system
ASPby 31 Mar 2027
Go-live by 01 Oct 2027
21e-invoicing Initiative

22. 01 02 03
•Data submission to the
FTAis required for
compliance
•Integration with the ERP
systems via ASPs
Reporting to the FTA
•Structured format
mandated
•Invoices must follow a
structured XML/UBL
schema
Schema Compliance
•Evaluate reliable ASPsfor
seamless integration
•Invoices must go through the
FTAapproved ASPs
•The list shall be provided in
due course.
Use of ASPs
Technical &Reporting Obligations

23. 01
02
03
Ensures that all invoicing follows legal and regulatory
standards of the FTA
Compliance Assurance
Entities must register with the FTAfor compliance and
transparency before the deadlines fall
Registration Steps
The Electronic Invoice System (EIS) under surveillance
of the FTAregulates invoicing processes
What is EIS/FTA?
EIS/FTA Registration Process

24. ASP Accreditation Criteria under MD 64 of 2025
1.Eligibility Requirements
•Legally registered entity (UAE or recognized jurisdiction)
•Minimum 2 years' experience in e-invoicing or similar systems
•Valid Corporate Tax & VAT registration
2.Financial & Legal Standing
•Minimum paid-up capital: AED 50,000
•Audited financial statements (within 6 months if new)
•Not under liquidation, bankruptcy, or major legal dispute
•Self-declaration of compliance and ethical conduct
3.Technical & Operational Standards
•Peppol-certified and compliant with UAE PINT AE
•Interoperability, real-time data exchange, and error handling
•Provide 100 free e-invoice transactions annually

25. ASP Accreditation Criteria under MD 64 of 2025
4.Information Security & Data Protection
•ISO/IEC 27001 & ISO 22301 certifications
•Encryption, MFA, and data residency compliance
5.Insurance Coverage (Minimum)
•Professional Indemnity: AED 2.5 million
•Crime: AED 5 million
•Cyber Fraud: AED 5 million
6.Accreditation Process
Reviewed by MoFwithin 90business days; valid for 2 years
7.Suspension & Termination
For non-compliance, data breach, or false declaration

26. General Selection Criteria for ASPs
#Evaluation Area What to Look For
1Accreditation Listed by the FTA/MoF(The list is awaited from the tax authorities)
2ERP Integration Compatible APIs, minimal customization (SAP, Oracle, Tally, Zoho, QuickBooks, etc.)
3Compliance Features XML/UBL, Digital Signature, QR, UIN
4Security Encryption, ISO 27001, UAE data hosting
5Support 24/7 helpdesk, training, updates, monitoring, revisions
6Cost Transparent & scalable
7Reporting Dashboards, analytics, error logs

27. e-Invoicing is mandatory for all VAT-registered companies except the entities
having B2C transactions
It automates invoice processing, reduces errors, ensures tax compliance, and
improves transparency of transactions
It requires investment in software, integration, and staff training
It offers benefits such as audit readiness, tax accuracy, and operational efficiency
Selection criteria for the ASPs as given in the MD 64 of 2025
Step-by-step implementation process for the e-Invoicing system
Takeaways
27e-invoicing Initiative

28. References
Federal Decree-Law No. 17 of 2024
The law relates to the tax procedures. It introduces the definition of the "e-invoicing system"
and grants the Ministerof Financeauthority to implement the system and specify
requirements.
Cabinet Decision 52 of 2017
Article 59 & 60, highlight the transactions where e-invoicing and e-credit note may not apply
Federal Decree-Law No. 16 of 2024
Amends provisions related to the VAT, expanding scope of definitions to include e-invoices
and e-credit notes.
Article 1, 55, 65, 70 & 76 of Law No. 16 of 2024 are relevant to the e-Invoicing regime.
Ministerial Decision64 of 2025
The Ministry sets out the accreditation procedure and eligibility criteria for ASPs.
Ministerial Decisions No. 243 &244 of 2025
Outline the scope of obligations and announce the deadlines for implementing the e-invoicing
system.

29. List of the Abbreviations Used
#AbbreviationFull Form
1ASP Accredited Service Provider
2B2B Business to Business
3B2C Business to Consumer
4B2G Business to Government
5EIS Electronic Invoicing System
6e-Invoicing Electronic Invoicing
7ERP Enterprise Resource Planning
8FTA Federal Tax Authority
9IRN InvoiceReference Number
10MD Ministerial Decision
11MoF Ministryof Finance
12OECD Organization for Economic Cooperation andDevelopment
13VAT Value Added Tax

31. A presentation by
Ahmad Tariq Bhatti
FCMA (Pak), ACMA (UK), CGMA (USA), FPFA
For feedback, queries & support:
[email protected]