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Which businesses must use e-invoicing?

Answered by TI from the Federal Tax Authority’s own law · 15 September 2026. Guidance, not tax advice: rely on the official text.

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VAT-registered suppliers that the FTA has made subject to the e-invoicing system must issue their tax invoices electronically through an accredited provider. Which specific businesses are in scope, and from when, is set by FTA/Ministerial notices that are not in the extracts supplied here.

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The detail

Under Article 65(5) of the VAT Decree-Law, a Registrant subject to the Electronic Invoicing System must issue and transmit its tax invoices as Electronic Invoices through that system; the Executive Regulation then disapplies the simplified-invoice and related exceptions for such invoices (Article 59(16) ER). Ministerial Decision 243 of 2025 imposes the practical obligations: issue and transmit electronic invoices and credit notes within 14 days of the transaction, through an Accredited Service Provider, and report them to the Authority in line with the Minister's prescribed timeline. The extracts do not state which registrants the Minister has brought into scope or from which date, so that fact has to be confirmed against the FTA's implementation schedule.123

What the law says

  • Federal Decree-Law No 8 of 2017, Article 65(5): a Registrant subject to the Electronic Invoicing System must issue and transmit tax invoices in the form of an Electronic Invoice in accordance with that System.3
  • Ministerial Decision No 243 of 2025, Article 6: the Issuer (registrant) must issue and transmit Electronic Invoices and Credit Notes through the System, do so within 14 days of the business transaction, use an Accredited Service Provider, and report issued and received documents to the Authority.2
  • Executive Regulation, Article 59(16): where a tax invoice is required or voluntarily issued as an Electronic Invoice, the provisions on simplified tax invoices, zero-rated-supply invoicing relief and the related exceptions do not apply.1

What it depends on

  • Only a Registrant (VAT-registered supplier) that is subject to the Electronic Invoicing System is required to issue e-invoices; the determination of which registrants, and from which date, lies with the Minister/FTA and is not stated in the supplied extracts.23
  • Electronic invoices and credit notes must still be issued and transmitted within 14 days from the date of the business transaction.2
  • The Issuer must appoint an Accredited Service Provider and report issued and received electronic invoices and credit notes to the Authority within the timeline the Minister prescribes.2

Check before you rely on it

  • Confirm the FTA has formally designated your tax registration as subject to the Electronic Invoicing System, and note the applicable go-live date - this is not in the extracts supplied.
  • Confirm you have appointed an Accredited Service Provider for issuing and receiving electronic invoices.
Note: The FTA's phasing, turnover thresholds and go-live dates for who must e-invoice are outside the supplied extracts - check the FTA's separate implementation announcements.
Sources (3) — read the official text
  1. 1VAT Executive RegulationArticle 59Executive Regulation
    Article 59 – Tax invoices 43,44
    Read the article
    Article 59 – Tax invoices 43,44 1. A Tax Invoice shall contain all of the following particulars: a. The words “Tax Invoice” clearly displayed on the invoice. b. The name, address, and Tax Registration Number of the Registrant making the supply. c. The name, address, and Tax Registration Number of the Recipient where he is a Registrant. d. A sequential Tax Invoice number or a unique number which enables identification of the Tax Invoice and the order of the Tax Invoice in any sequence of invoices. e. The date of issuing the Tax Invoice. f. The date of supply if different from the date the Tax Invoice was issued. g. A description of the Goods or Services supplied. h. For each Good or Service, the unit price, the quantity or volume supplied, the rate of Tax and the amount payable expressed in AED. i. The amount of any discount offered. j. The gross amount payable expressed in AED. k. The Tax amount charged under the provisions of the Decree-Law expressed in AED, together with the rate of exchange applied where the currency is converted from a currency other than the UAE dirham. l. Where the invoice relates to a supply under which the Recipient of Goods or Recipient of Services is required to account for Tax, a statement that the Recipient is required to account for Tax, and a reference to the relevant provision of the Decree-Law. 43 Article amended as per Cabinet Decision No. 100 of 2024. 44 Article amended as per Cabinet Decision No. 100 of 2025. Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 51 2. A simplified Tax Invoice shall contain all of the following particulars: a. The words “Tax Invoice” clearly displayed on the invoice. b. The name, address, and Tax Registration Number of the Registrant making the supply. c. The date of issuing the Tax Invoice. d. A description of the Goods or Services supplied. e. The total Consideration and the Tax amount charged expressed in AED. 3. If there are or will be sufficient records available to establish the particulars of a supply, a Registrant is not required to issue a Tax Invoice for the supply where the supply is a wholly zero-rated supply. 4. Where a Registrant is required to issue a Tax Invoice, the Tax Invoice must meet the requirements of Clause 1 of this Article. 5. As an exception to Clause 4 of this Article, and in cases other than where the reverse charge mechanism applies in accordance with Article 48 of the Decree-Law, the Registrant may issue a simplified Tax Invoice that meets the requirements of Clause 2 of this Article in either of the following two situations: a. Where the Recipient of Goods or Recipient of Services is not a Registrant. b. Where the Recipient of Goods or Recipient of Services is a Registrant and the Consideration for the supply does not exceed AED 10,000 (ten thousand dirhams). 6. A Registrant shall not issue separate Tax Invoices in respect of supplies where he makes more than one supply of Goods or Services to the same Person and those supplies are included on a summary Tax Invoice issued and delivered to the Recipient of Goods or Recipient of Services. 7. Where the Authority considers that there are or will be sufficient records available to establish the particulars of any supply or class of supplies, and that it would be impractical to require that a Tax Invoice be issued by the Registrant, the Authority may determine that, subject to any conditions that the Authority may consider necessary: a. Any of the particulars specified in Clauses 1 or 2 of this Article shall not be contained in a Tax Invoice. b. A Tax Invoice is not required to be issued or delivered in certain cases. 8. The Registrant may issue a Tax Invoice by electronic means provided that: a. the Registrant must be capable of securely storing a copy of the Tax Invoice in compliance with the record keeping requirements. b. the authenticity of origin and integrity of content of the Tax Invoice should be guaranteed. Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 52 9. Where a Recipient agrees to raise a Tax Invoice on behalf of a Registrant Supplier in respect of a supply of Goods or Services, that document shall be treated as if it had been issued by the supplier if the following conditions are met: a. The Recipient of the Goods or Services is a Registrant. b. The supplier and the Recipient agree in writing that the supplier shall not issue a Tax Invoice in respect of any supply to which this Clause applies. c. The Tax Invoice shall contain the particulars required under Clause 1 of this Article. d. The words “Tax Invoice raised by buyer” are clearly displayed on the Tax Invoice. 10. Where a Tax Invoice is issued pursuant to Clause 9 of this Article, any invoice issued by the Supplier in respect of that supply shall be deemed not to be a Tax Invoice. 11. Where an agent who is a Registrant makes a supply of Goods or Services for and on behalf of the principal of that agent, that agent may issue a Tax Invoice in relation to that supply as if that agent had made the supply, provided that the principal shall not issue a Tax Invoice, subject to: a. the agent retaining sufficient records in such a manner as to determine the name, address and Tax Registration Number of the principal supplier, and b. the principal supplier retaining sufficient records in such a manner as to determine the name, address and Tax Registration Number of the agent. 12. Where the Supply of Goods or Services is considered as supplied in an Implementing State, the Registrant must include the following additional particulars in the document issued: a. the tax registration number of the Recipient of Goods or Recipient of Services issued to him by the competent authority of the Implementing State in which the supply is treated as taking place, b. a statement identifying the supply as between a supplier in the State and a Recipient of Goods or Recipient of Services in an Implementing State, and c. any other information specified by the Authority. 13. For the purposes of Clause 2 of Article 67 of the Decree-Law, the Registrant shall issue the Tax Invoice within 14 (fourteen) days from the date of the supply provided for in Article 25 or 26 of the Decree-Law, except in the following cases: a. where the Tax Invoice is issued in accordance with Clause 2 of this Article, the Registrant shall issue the Tax Invoice on the date of supply, b. for the purposes of Clause 6 of this Article, the Registrant shall issue a summary of the Tax Invoice and deliver it to the Recipient of Goods or Recipient of Cabinet Decision No. 52 of 2017 and its amendments – As published by the Ministry of Finance 53 Services within 14 (fourteen) days of the end of the calendar month within which the date of supply occurs for such supplies. c. any other cases specified by the Authority. 14. Where the Authority grants approval under Clause 7 of this Article, such approval may be withdrawn at any time where the Authority considers that the conditions of approval are no longer met. 15. As an exception to Clause 5 of this Article, the Authority may specify the cases in which a Tax Invoice that meets the requirements of Clause 1 of this Article must be issued, even if one of the cases provided for in Clause 5 of this Article applies. 16. Where a Registrant is required to issue a Tax Invoice in the form of an Electronic Invoice pursuant to Clause 5 of Article 65 of the Decree-Law or where the Registrant issues a Tax Invoice in the form of an Electronic Invoice on a voluntary basis, Clauses 2, 3, 5, 7, 8, 15 of this Article and any other Clause as determined in a decision issued by the Minister shall not apply.
    Official PDF, pp. 51–54Captured from the FTA website on 10 Sep 2026Found by following a reference in another source
  2. 2Ministerial Decision 243/2025Article 6Ministerial Decision
    Article 6 – Exchange and Reporting Obligation
    Read the article
    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.
    Official PDF, pp. 5–6Captured from the FTA website on 9 Sep 2026
  3. 3VAT LawArticle 65Law
    Article 65 - Conditions and Requirements for Issuing Tax
    Read the article
    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.
    Official PDF, pp. 32–33Captured 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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