Do free zone companies need to use e-invoicing?
The sources don't say free zone companies are treated differently - the e-invoicing rollout applies based on your revenue, starting with large businesses (AED 50 million or more) by 2027, and smaller ones soon after.
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The detail
The Electronic Invoicing System mandate under Ministerial Decision No. 244 of 2025 applies to any 'Person subject to the Electronic Invoicing System', phased by revenue thresholds, without the sources distinguishing free zone from mainland status. Whether a specific free zone entity falls within scope depends on whether it is a 'Person subject to the Electronic Invoicing System' as defined elsewhere, which these extracts do not set out.1
What the law says
- Persons with revenue of AED 50 million or more must appoint an Accredited Service Provider by 30 October 2026 and implement e-invoicing by 1 January 2027.1
- Persons with revenue below AED 50 million have until 31 March 2027 to appoint a provider and must implement by 1 July 2027, with Government Entities on a slightly later timeline.1
- Business-to-Consumer transactions are excluded from the system until the Minister decides otherwise.1
What it depends on
Check before you rely on it
- Check your annual revenue to determine which deadline band applies.
- Confirm whether your transactions are exclusively B2C.
- Check whether your free zone authority or the FTA has issued specific guidance on your entity's scope.
Sources (1) — read the official text
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Article 5 – Mandatory Implementation
Read the article
Article 5 – Mandatory Implementation 1. The Electronic Invoicing System shall be implemented in the following phases : (a) A Person subject to the Electronic Invoicing System and whose Revenue is equal to or exceeds AED 50,000,000 shall appoint an Accredited Service Provider by 30 October 2026 and shall implement the Electronic Invoicing System by 1 January 2027.1 (b) A Person subject to the Electronic Invoicing System and whose Revenue is less than AED 50,000,000 shall appoint an Accredited Service Provider by 31 March 2027 and shall implement the Electronic Invoicing System by 1 July 2027. (c) A Government Entity shall appoint an Accredited Service Provider by 31 March 2027 and shall implement the Electronic Invoicing System by 1 October 2027. 2. Notwithstanding Clause 1 of this Article, Business-to-Consumer Transactions shall not be subject to the Electronic Invoicing System and any Person engaged exclusively in such transactions shall not be subject to the Electronic Invoicing System, until such time determined by a decision issued by the Minister. 3. Any Person or Government Entity who is required to implement the Electronic Invoicing System in accordance with Clause 1 of this Article shall comply with the onboarding process and all the technical requirements established by the Ministry and the Authority for the use of the Electronic Invoicing System.
Written by AI from the FTA sources above and checked before display. Not tax advice or official FTA information - confirm with a tax adviser before you act. Full disclaimer
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