Does e-invoicing apply to sales to consumers?

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.

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.