UAE e-Invoicing is coming: what businesses must do from July 2026 (and the laws behind it)

The UAE has formally launched its Electronic Invoicing System (EIS) under the Ministry of Finance (MoF). A pilot and voluntary phase begins 1 July 2026, followed by a phased mandatory rollout through 2027. This blog walks you through who’s in scope, key dates, what an “electronic invoice” actually means, how to prepare, and—critically—the legal sources (articles, cabinet and ministerial decisions) you’ll want to cite in your internal policies and contracts.
The legal backbone (at a glance)
- VAT Law: Federal Decree-Law No. 8 of 2017 (notably Article 65 on tax invoices and Article 67 on the 14-day issuance rule; the VAT Law now acknowledges e-invoicing obligations for taxpayers brought into scope).
- VAT Executive Regulations: Cabinet Decision No. 52 of 2017 (as amended). Articles 59 (Tax Invoices) and 60 (Tax Credit Notes) set invoice content; amendments in Cabinet Decision No. 100 of 2025 align these rules with the e-invoicing regime.
- E-Invoicing Decisions (MoF):
- Ministerial Decision (MD) No. 243 of 2025 – defines the Electronic Invoicing System, obligations to issue, transmit, exchange and report e-invoices/e-credit notes (including the 14-day deadline for issuance/transmission via the system).
- MD No. 244 of 2025 – sets the timeline: pilot & voluntary adoption from 1 July 2026; mandatory onboarding deadlines across 2027; temporary exclusion of B2C until a later ministerial decision.
- MD No. 64 of 2025 – eligibility & accreditation of e-invoicing service providers (ASPs) you must connect through.
- MoF programme portal (official): overview, timeline, FAQs, and links to the above decisions. 
What changes for businesses?
1) Scope and documents
If you are conducting business in the UAE, you will be required to issue, transmit, receive, and report invoices and credit notes in a structured electronic format via an Accredited Service Provider (ASP)—for every business transaction—unless a specific exclusion applies (e.g., certain airline and exempt financial services cases). 
Key points from MD 243/2025:
- The issuer must issue and transmit an electronic invoice (or credit note, where applicable) within 14 days from the date of the business transaction, through the Electronic Invoicing System.
- Recipients must process e-invoices and e-credit notes through the system.
- The data fields and particulars of e-invoices/credit notes will follow MoF-prescribed standards.
2) Timeline: when you must be ready
- 1 July 2026 – Pilot programme begins; voluntary implementation is allowed from this date if you comply with all technical requirements.
- Mandatory phases under MD 244/2025:
- Revenue ≥ AED 50 million: appoint an Accredited Service Provider by 31 July 2026 and fully implement by 1 Jan 2027.
- Revenue < AED 50 million: appoint by 31 Mar 2027; implement by 1 Jul 2027.
- Government entities: appoint by 31 Mar 2027; implement by 1 Oct 2027.
- B2C: not yet in scope until a future ministerial decision specifies a date.
3) The VAT rulebook still matters
•VAT Law Article 65 requires registered suppliers to issue tax invoices; the law now recognizes the electronic format for those in scope. Article 67 sets the general 14-day issuance rule, which MD 243/2025 ties directly to e-invoices sent via the system.
- Executive Regulations Articles 59 & 60 (as updated by Cabinet Decision No. 100 of 2025) align invoice/credit note content and remove certain simplifications once a business is under the e-invoicing regime (e.g., simplified invoices where permitted historically).
Who is excluded (for now)?
MD 243/2025 lists Excluded Transactions (e.g., sovereign-capacity supplies by government entities; certain airline passenger services with e-tickets; specified international air cargo for a limited period; exempt/zero-rated financial services per Article 42 of the Executive Regulations). The category of Excluded Persons will be defined separately by ministerial decision. Voluntary e-invoicing remains permitted—if you opt in, the system’s requirements apply to you.
What is an “Accredited Service Provider” (ASP)?
Under MD 64/2025, only MoF-accredited providers can deliver e-invoicing services in the UAE. Businesses must appoint an ASP in line with their phase deadlines. The MoF portal maintains the list of pre-approved providers and provides the accreditation criteria.
Practical implications & readiness checklist
1) Map your transactions and systems.
Identify all billing flows (B2B, B2G, any B2C), ERP/POS touchpoints, and invoice/credit-note scenarios (including reverse-charge adjustments). Confirm which flows fall within scope immediately and which are temporarily excluded.
2) Choose and contract your ASP.
For large businesses (≥ AED 50 m revenue), your appointment deadline is 31 July 2026—don’t leave integration to the last minute. Smaller businesses follow in early 2027; government entities by October 2027.
3) Re-design invoice content and timing.
Ensure every e-invoice carries the mandatory data fields and is issued/transmitted within 14 days of the business transaction, aligning your processes with Articles 59/60 (content) and Article 67 (timing) as read with MD 243/2025.
4) Update internal controls & policies.
Your finance manuals should reference MD 243/2025 (issuing, transmitting, reporting), MD 244/2025 (timeline), Cabinet Decision 100/2025 (Exec Reg amendments), and the VAT Law invoice provisions. Add procedures for system failures and reporting obligations to the FTA.
5) Train teams and counterparties.
Procurement, sales, AP/AR, and IT must understand how e-invoices are exchanged (MoF describes a decentralized CTC-exchange model with reporting to FTA via ASPs). Align customers and suppliers on formats and acknowledgments.
6) Archive & data residency.
Plan compliant storage and data-residency (within the UAE) and retention processes as set by MoF/FTA e-invoicing standards and clarifications.
FAQs we’re already hearing
Is July 2026 a hard “go-live” for everyone?
No. Voluntary adoption and pilot start on 1 July 2026; mandatory onboarding is phased through 2027 based on revenue thresholds and entity type.
Do B2C invoices need to be electronic from July 2026?
Not yet. B2C transactions are temporarily excluded until a future ministerial decision brings them in.
What happens to simplified invoices?
Once you are under the e-invoicing regime, the Executive Regulations (as amended by Cabinet Decision 100/2025) remove certain flexibilities—expect full tax invoice requirements to apply broadly.
What’s the issuance deadline?
Issue and transmit the e-invoice (or e-credit note) within 14 days of the business transaction through the system—this ties the VAT Law’s Article 67 timing to MD 243’s e-invoicing mandate.
Source list you can quote in your documentation
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (definitions; exchange & reporting; 14-day issuance; agent/self-billing; data fields).
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System (pilot start 1 Jul 2026; voluntary from that date; mandatory deadlines by revenue/entity; temporary B2C exclusion).
- Ministerial Decision No. 64 of 2025 (ASP eligibility & accreditation).
- Cabinet Decision No. 100 of 2025 (amendments to Articles 59 & 60 of the VAT Executive Regulations to fit e-invoicing).
- Federal Decree-Law No. 8 of 2017 (VAT Law) – Articles 65 & 67 (issuing tax invoices; 14-day rule), among others.
- MoF e-Invoicing portal – official programme page, FAQs, decisions, ASP information.
How Accruon Auditing LLC can help
- Readiness assessment & roadmap (scope, data gaps, ERP/POS integrations).
- Policy & control updates (invoice/credit-note SOPs, failure contingencies, retention).
- ASP evaluation & onboarding support (RFP, contract review, testing).
- Change management & training (sales, AP/AR, procurement, IT).
- Ongoing compliance monitoring (exception handling, audit-trail reviews, VAT return alignment).
