E-Invoicing System Decision

Defines the scope of the Electronic Invoicing System: every person conducting business in the UAE must issue and transmit electronic invoices and credit notes through an Accredited Service Provider, which issuers and recipients must both appoint, with exclusions for sovereign government activities, certain airline services and exempt or zero-rated financial services; amended by Ministerial Decision No. 197 of 2026.

Official title
Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System
Instrument
Ministerial Decision No. 243 of 2025
Issued by
Minister of Finance
Jurisdiction
UAE Federal
Dates
issued 12 September 2025
Status
in force (amended)
Amended by
Ministerial Decision No. 197 of 2026
Topics
E-invoicing · VAT
Official source
tax.gov.ae · official text (PDF)
Verified
25 October 2026

Summary

Ministerial Decision No. 243 of 2025 is the founding instrument of the UAE Electronic Invoicing System. It defines the system, says who must use it, what must be issued and when, and who may stay outside it. It was issued on 12 September 2025, came into force on publication in the Official Gazette, and is in force as amended by Ministerial Decision No. 197 of 2026 with effect from 1 October 2026. The roll-out dates are in a separate instrument, Ministerial Decision No. 244 of 2025.

Article 3 sets the scope: any Person conducting Business in the UAE, in respect of every Business Transaction, unless excluded under Article 4, plus any other Person or transaction the Minister determines. Scope is tied to doing Business, not to VAT registration.

Article 4 lists the Excluded Transactions: sovereign activities of Government Entities not in competition with the private sector; international passenger transport by an Airline where an Electronic Ticket is issued, and ancillary services covered by an Electronic Miscellaneous Document; international air cargo under an Airway Bill, for 24 months from the date the system becomes effective; financial services exempt from VAT or zero-rated under Article 42 of the VAT Executive Regulation; and, added by the 2026 amendment, transactions between members of the same VAT Tax Group for 24 months from 1 January 2027. Excluded Persons are to be designated by the Minister. Anyone excluded may opt in, and is then bound by all e-invoicing rules except the penalty decisions.

Article 5 requires the Issuer and the Recipient each to appoint an Accredited Service Provider from the Ministry's published list, and to tell the provider in writing of any change to their FTA-registered data within 5 Business Days. Article 6 sets the core obligation: the Issuer issues and transmits an Electronic Invoice for every Business Transaction, and an Electronic Credit Note on cancellation, reduction or refund of the consideration or correction of an error; the Recipient processes them through the system; a VAT Registrant keeps to the VAT Law timeline, and otherwise the document must be issued within 14 Business Days of the Date of Business Transaction (as amended; originally 14 days). Both sides report to the FTA within the timeline the Minister sets, through their provider.

Article 7 leaves the data fields to the Ministry. Articles 8 and 9 allow agents to issue for principals and self-billing between Registrants. Article 10 gives the FTA access to all system data and power to share it with other government bodies and foreign authorities under international agreements. Article 11, as amended, requires e-invoice data to be retained for the Tax Procedures Law period and producible on request; the original in-UAE storage rule and the Article 12 System Failure notice were removed in 2026. Article 13 leaves phasing to the Minister.

Who it applies to

Any natural or juridical Person conducting Business in the UAE, in respect of every Business Transaction, whether or not registered for VAT, as both Issuer and Recipient of invoices, unless excluded under Article 4 or designated an Excluded Person by the Minister. Business-to-consumer transactions are deferred under Ministerial Decision No. 244 of 2025.

Key provisions

Article 1Defines the Electronic Invoicing System, Electronic Invoice and Electronic Credit Note (structured electronic documents enabling automatic processing), Issuer, Recipient, Business, Date of Business Transaction (earlier of transaction date and payment), Accredited Service Provider and, since the 2026 amendment, Tax Group and Taxable Person by reference to the VAT Law.
Article 3The decision applies to any Person conducting Business in the UAE in respect of every Business Transaction, except where the Person or transaction is excluded under Article 4, and to any other Person or transaction the Minister determines.
Article 4(1)Excluded Transactions: sovereign Government Entity activities; Airline passenger transport under Electronic Tickets and ancillary services; Airline cargo under Airway Bills for 24 months from the system's effective date; VAT-exempt or zero-rated financial services under Article 42 of the VAT Executive Regulation; and (from the 2026 amendment) transactions within a VAT Tax Group for 24 months from 1 January 2027.
Article 4(2)–(3)Excluded Persons are set by decision of the Minister; an excluded Person may opt in voluntarily and is then bound by all e-invoicing decisions except those on violations and administrative penalties.
Article 5The Issuer and the Recipient each appoint an Accredited Service Provider from the Ministry's published list, and notify the provider in writing within 5 Business Days of any change to their data registered with the FTA under Article 6(4) of Cabinet Decision No. 74 of 2023.
Article 6(1)–(3)The Issuer issues and transmits an Electronic Invoice for every Business Transaction and an Electronic Credit Note on cancellation, reduction or refund of consideration, or an administrative or numerical error; the Recipient processes both through the system.
Article 6(4)–(5)A VAT Registrant issues within the VAT Law timeline; otherwise, as amended from 1 October 2026, the Electronic Invoice or Credit Note must be issued and transmitted within 14 Business Days from the Date of Business Transaction.
Article 6(6)–(7)Issuer and Recipient report the documents to the FTA within the timeline the Minister prescribes and fulfil all Article 6 obligations through their Accredited Service Provider.
Articles 8–9An agent may issue and transmit Electronic Invoices and Credit Notes on behalf of a principal; a Recipient may self-bill on behalf of the Issuer where both are Registrants, under the VAT Executive Regulation conditions or as the Minister determines.
Article 10The FTA may access and use all data processed, received and stored in the system and, subject to the Tax Procedures Law, share it with other Government Entities or foreign government bodies under international agreements.
Article 11As amended, every Person in the system retains all Electronic Invoices, Credit Notes and associated data for the Tax Procedures Law retention period and must be able to produce them to the FTA on request.
Articles 13–15Implementation is phased by decision of the Minister; conflicting provisions are repealed; the decision came into force on publication in the Official Gazette.

Obligations and deadlines

  • Appoint an Accredited Service Provider, as Issuer and as Recipient, by the deadline for your phase under Ministerial Decision No. 244 of 2025.
  • Issue and transmit an Electronic Invoice for every Business Transaction and an Electronic Credit Note for cancellations, reductions, refunds and corrections.
  • VAT Registrants: issue within the VAT Law timeline; others within 14 Business Days of the Date of Business Transaction.
  • Report issued and received documents to the FTA within the timeline the Minister prescribes.
  • Notify the provider within 5 Business Days of any change to FTA-registered data.
  • Retain all e-invoice data for the Tax Procedures Law period and produce it to the FTA on request.

Penalties

The decision itself sets no penalties; it states that persons opting in voluntarily are exempt from the penalty decisions. Administrative penalties for failing to appoint a provider, to issue or transmit electronic invoices and credit notes, or to report and retain data are set in Cabinet Decision No. 106 of 2025.

In practice — how Polaris handles it

Almost every client company we administer will fall within this system, because scope turns on conducting Business in the UAE rather than on VAT registration: a holding company issuing one management fee invoice a year is in, as is a consultancy below the VAT threshold. We are preparing their invoicing and bookkeeping for it now. For each client we identify who issues and who receives invoices, since both sides must appoint a provider, and we check whether any transactions fall in the Article 4 exclusions; for groups under common ownership we note that the Tax Group exclusion only covers VAT groups and only for 24 months from 1 January 2027. Our bookkeeping work is shifting from recording invoices after the fact to controlling the invoice data at source, so that the 14-Business-Day transmission window and the FTA reporting timelines can be met through the provider without a parallel manual process.

Related instruments

E-Invoicing System Amendment (October 2026)

MD 197/2026 · UAE Federal · in force

From 1 October 2026 revises the e-invoicing system decision: replaces the Accredited Service Provider definition, adds Tax Group and Taxable Person definitions, deletes t…

E-Invoicing Implementation Timeline Decision

MD 244/2025 · UAE Federal · in force (amended)

Sets the e-invoicing roll-out: pilot from 1 July 2026; businesses with revenue of AED 50 million or more appoint an Accredited Service Provider (by 30 October 2026 under …

E-Invoicing Timeline Amendment (May 2026)

MD 66/2026 · UAE Federal · in force

Replaces paragraph (a) of Article 5(1) of the implementation decision: businesses with annual revenue of AED 50 million or more now have until 30 October 2026 to appoint …

E-Invoicing Penalties Decision

CD 106/2025 · UAE Federal · in force

Fixes the penalties for e-invoicing breaches: AED 5,000 for each month of delay in implementing the system, including failing to appoint an Accredited Service Provider on…

VAT Law Amendment (E-Invoicing, 2024)

FDL 16/2024 · UAE Federal · in force

Inserts the legal basis for e-invoicing into the VAT Law: new definitions of the Electronic Invoicing System, electronic invoice and electronic credit note, revised defin…

VAT Law

FDL 8/2017 · UAE Federal · in force (amended)

Imposes value added tax at a standard rate of 5% on supplies of goods and services and imports in the UAE from 1 January 2018, with zero-rated and exempt categories, regi…

VAT Executive Regulation

CD 52/2017 · UAE Federal · in force (amended)

The detailed VAT rules: the AED 375,000 mandatory and AED 187,500 voluntary registration thresholds, tax groups, place and date of supply, zero-rating and exemption condi…

Tax Procedures Executive Regulation

CD 74/2023 · UAE Federal · in force (amended)

Implements the Tax Procedures Law: which accounting records must be kept and for how long (generally five years, seven for real estate records), form and language of docu…

Related Polaris services

Source and verification. This page was written from the official text published at mof.gov.ae, read on 25 October 2026. Quoted from that text: “Any Person conducting Business in the State in respect of every Business Transaction, except where the Person or the Business Transaction is excluded under Article 4 of this Decision.”
This summary is published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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