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Does e-invoicing apply to sales to consumers?

Answered by FinTaxIQ - TI from the Federal Tax Authority’s own law · 11 October 2026. Guidance, not tax advice: rely on the official text.

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No, not yet. Sales to individual consumers (B2C) are excluded from mandatory e-invoicing until the Minister issues a decision bringing them into scope.

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The detail

Under Article 5(2) of Ministerial Decision No. 244 of 2025, Business-to-Consumer transactions are not subject to the Electronic Invoicing System, and a Person engaged exclusively in such transactions is excluded, until a further Ministerial decision sets a date for their inclusion. This is separate from the list of Excluded Transactions (e.g. certain government, airline and exempt/zero-rated financial services) in Article 4 of Ministerial Decision No. 243 of 2025, which remain excluded regardless of B2C status.12

What the law says

  • B2C transactions are not subject to the Electronic Invoicing System until the Minister issues a decision bringing them into scope (Article 5(2), Ministerial Decision No. 244 of 2025).1
  • Separately, Article 4 of Ministerial Decision No. 243 of 2025 excludes certain Business Transactions (government sovereign activities, international air passenger/cargo transport, and exempt or zero-rated financial services) from e-invoicing entirely.2
  • A business may still choose to voluntarily issue e-invoices for excluded transactions, in which case the e-invoicing rules apply to it mandatorily going forward.2

What it depends on

  • The B2C exclusion only applies where the person is engaged exclusively in Business-to-Consumer transactions; mixed B2B/B2C businesses remain subject to e-invoicing for their B2B supplies.1
  • The exclusion lasts only until the Minister issues a decision specifying when B2C transactions must be brought into the system.1

Check before you rely on it

  • Check whether any of your sales are actually to VAT-registered business customers (B2B), which are not covered by this exclusion.
Sources (2) — read the official text
  1. 1Ministerial Decision 244/2025Article 5Ministerial Decision
    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.
    Official PDF, p. 3Captured from the FTA website on 9 Sep 2026
  2. 2Ministerial Decision 243/2025Article 4Ministerial Decision
    Article 4 – Exclusions
    Read the article
    Article 4 – Exclusions 1. The following Business Transactions shall be considered as Excluded Transactions: a) Any Business Transactions conducted by Government Entities in a sovereign capacity, and which are not in competition with the private sector, in accordance with the VAT Law. b) International passenger transportation services provided by an Airline via an Aircraft, where an Electronic Ticket is issued to the passengers. c) Any services provided directly to the passengers by an Airline, that are ancillary to the services mentioned in clause (b) of this Article, where an Electronic Miscellaneous Document is issued for such services. d) International transportation services in respect of goods, provided by an Airline, where an Airway Bill is issued for such services, provided that this exclusion shall apply only for a period of twenty-four (24) months from the date on which the Electronic Invoicing System becomes effective. e) Financial services that are exempt from VAT or subject to VAT at the zero rate, in accordance with Article 42 of the VAT Executive Regulation. f) Any other Business Transaction as may be determined by the Minister. Ministerial Decision No. 243 of 2025 – As published by the Ministry of Finance 4 2. The category of Excluded Persons shall be determined by a decision issued by the Minister. 3. Notwithstanding the exclusions under Clauses 1 and 2 of this Article, a Person may voluntarily issue, transmit, share, exchange and report Electronic Invoices and Electronic Credit Notes for Business Transactions. In such cases, the provisions of this Decision and all related decisions regarding the Electronic Invoicing System shall apply to them mandatorily, except the decisions related to the violations and administrative penalties.
    Official PDF, pp. 4–5Captured from the FTA website on 9 Sep 2026
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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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