Which businesses must use e-invoicing?

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 65 - Conditions and Requirements for Issuing Tax Invoices28 29 1. A Registrant making a Taxable Supply shall issue an original Tax Invoice and deliver it to the Recipient of Goods or Recipient of Services. 2. A Registrant making a Deemed Supply shall issue an original Tax Invoice and deliver it to a Recipient of Goods or Recipient of Services if available or keep it in his records if there is no Recipient of Goods or Recipient of Services. 3. The Executive Regulation of this Decree-Law shall specify all of the following: a. Data to be included in the Tax Invoice. b. The conditions and procedures required to issue a Tax Invoice by electronic means. c. Instances where the Registrant is not required to issue and deliver a Tax Invoice to the Recipient of Goods or the Recipient of Services. d. Instances where other documents may be issued in place of the Tax Invoice as well as the conditions thereof and the data to be included therein. e. Instances where a Person may issue a Tax Invoice on behalf of the registered 28 Article amended as per Federal Decree-Law No. 18 of 2022. 29 Article amended as per Federal Decree-Law No. 16 of 2024. Federal Decree-Law No. 8 of 2017 and its amendments – As published by the Ministry of Finance 32 supplier. 4. Any Person receiving an amount as Tax or issuing a Tax Invoice in respect of an amount, must pay such amount to the Authority, and this amount shall be regarded as being similar to Due Tax under the provisions of this Decree-Law. 5. For the purpose of this Article, the Registrant subject to the Electronic Invoicing System must issue and transmit Tax Invoices in the form of an Electronic Invoice, in accordance with the Electronic Invoicing System.

Article 6 – Exchange and Reporting Obligation 1. Subject to Article 8, 9 and 10 of this Decision, the Issuer shall issue and transmit an Electronic Invoice to the Recipient in respect of any Business Transaction. 2. The Issuer shall issue and transmit an Electronic Credit Note to the Recipient in the following cases: (a) Where the Business Transaction is cancelled. (b) Where the agreed consideration for the Business Transaction is reduced for any reason. (c) Where the consideration for the Business Transaction is returned in full or in part. Ministerial Decision No. 243 of 2025 – As published by the Ministry of Finance 5 (d) Where an administrative or numerical error has occurred in relation to the Business Transaction. 3. The Recipient shall process Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System. 4. Where the Issuer is a Registrant, the Issuer shall issue and transmit the Electronic Invoice, and the Electronic Credit Note to the Recipient within the timeline prescribed by the VAT Law. 5. Subject to Clause 4 of this Article, the Electronic Invoice or Electronic Credit Note referred to under Clauses 1 and 2 of this Article, must be issued and transmitted by the Issuer through the Electronic Invoicing System within 14 days from the Date of Business Transaction. 6. The Issuer and the Recipient must report Electronic Invoices and Electronic Credit Notes issued under Clauses 1, 2 and 3 of this Article to the Authority within the timeline prescribed by the Minister. 7. The Issuer and the Recipient shall fulfil their obligations under this Article through the appointment of an Accredited Service Provider.