Who must comply
Who must use e-invoicing in the UAE?
UAE e-invoicing requirements apply to any person doing business in the UAE, for each business transaction, unless the person or the transaction is excluded. Sales to businesses and to government are in scope whatever your size or VAT registration. Sales to consumers are out of scope for now. Your revenue sets your dates, not whether you are in scope.
UAE e-invoicing requirements start with the transaction
Ministerial Decision 243 of 2025 sets the scope. It applies to any person conducting business in the UAE, for every business transaction, unless Article 4 excludes the person or the transaction. A business is any activity carried on regularly, on an ongoing and independent basis.
Government source: Decision 243 of 2025, Articles 1 and 3.
Ministerial Decision 197 of 2026 amended Decision 243 from 1 October 2026, and this article uses the amended text. The Ministry of Finance (MoF) guidelines, version 2.0 of 26 October 2026, add that scope does not depend on VAT registration, or on whether the person is established in the UAE. Your customer’s onboarding or tax status does not change your obligation either.
Government source: MoF Guidelines v2.0, sections 6 and 6.1.
So “we are a startup”, “we issue only a few invoices” and “we are below AED 50 million” are not exemptions. Revenue decides when you start, not whether you are in.
First, which of your transactions are covered? Then, which revenue group are you in, and what are your dates?
B2B, B2G and consumer sales
The guidelines sort transactions by who sells and who buys. Sales between businesses and government entities are in scope, unless excluded. Supplies to or from natural persons who are not in business are not, even when a billing agent issues the invoice.
| Seller | Buyer is a business | Buyer is a government entity | Buyer is a consumer |
|---|---|---|---|
| Business | In scope (B2B) | In scope (B2G) | Not in scope for now (B2C) |
| Government entity | In scope (G2B) | In scope (G2G) | Not in scope (G2C) |
Government source: MoF Guidelines v2.0, section 6.2.
Decision 244 of 2025 defines a business-to-consumer (B2C) transaction as one with a natural person who is not carrying on business. These transactions, and any person engaged only in them, are not subject to the system until the Minister decides otherwise. No date has been set.
Government source: Decision 244 of 2025, Article 1 (page 1) and Article 5(2) (page 2).
The buyer’s status decides it, not the size of the sale:
- Sole traders. An MoF FAQ answer on sole establishments registered as natural persons says that where the contract is signed with a business, it is B2B.
- Government buyers. Supplies to government entities, for example through government procurement portals, are in scope.
- Mixed bills. In MoF guidance on a hospital bill paid partly by an insurer and partly by the patient, the payment split alone does not decide the treatment. Only the part that is a business transaction is in scope. A supply to a person in a personal capacity is not, for now.
Government source: MoF Guidelines v2.0, section 6.3.4.
Government source: MoF FAQ, e-invoicing: Foundational and Policy sections.
Sell to both? Your business sales stay in scope. See mixed retail and business sales.
Buying counts too: you are also a recipient
Decision 243 requires the issuer and the recipient, as applicable, to appoint an accredited service provider (ASP). The recipient must process the e-invoices it receives through the system. The guidelines say one ASP handles both sending and receiving.
Government source: Decision 243 of 2025, Articles 5(1) and 6(3).
This matters if you sell only to consumers. An MoF FAQ answer says a business in a mandatory phase whose sales are all B2C must still appoint an ASP and be able to receive e-invoices. Decision 244 says a person engaged only in B2C transactions is not subject to the system. The texts point different ways, so get your position confirmed in writing. Our article on free-zone and no-TRN businesses covers this too.
Government source: MoF FAQ, Policy section: business with only B2C sales.
Revenue sets your dates, not your scope
| Group | Appoint an ASP by | Implement by |
|---|---|---|
| Revenue of AED 50 million or more | 30 October 2026 (this date has passed) | 1 January 2027 |
| Revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities | 31 March 2027 | 1 October 2027 |
Government source: Decision 244 of 2025, Articles 4 and 5(1).
Government source: Resolution 66 of 2026, Article One.
Revenue means gross income in your most recent accounting period, from your financial statements or other documents the FTA accepts. Asked whether that means UAE or group revenue, the MoF FAQ points back to this definition and leaves it to the business and its auditors.
Government source: Decision 244 of 2025, Article 1: revenue.
Government source: MoF FAQ, Policy section: revenue threshold.
- Voluntary start. Open since 1 July 2026. The guidelines say penalties apply only from your mandatory date, and Cabinet Decision 173 of 2026 leaves voluntary users outside its penalties.
- After the phases. Any person subject to the system must then appoint an ASP and implement, so a business set up later is still covered.
- The first date has passed. Resolution 66 of 2026 moved the appointment date for the AED 50 million group from 31 July 2026 to 30 October 2026. If this is your group and you have not appointed an ASP, speak to your adviser now.
Government source: MoF Guidelines v2.0, sections 8.2 and 8.3.
Government source: Cabinet Decision 173 of 2026, Article 2.
To plan backwards from your date, see UAE e-invoicing deadlines.
Exclusions are short and transaction-based
Article 4 of Decision 243, as replaced by Decision 197 of 2026, excludes these transactions, under conditions:
- Sovereign government activity that is not in competition with the private sector.
- International airline passenger tickets, and extras sold with an electronic miscellaneous document.
- International air cargo with an airway bill, for 24 months from when the system becomes effective.
- Financial services that are VAT exempt or zero-rated under Article 42 of the VAT Executive Regulation.
- Transactions between members of the same Tax Group, for 24 months from 1 January 2027.
Excluded persons are to be named by a separate decision. The MoF e-invoicing page, last updated on 2 November 2026, lists none. A person who is excluded may still use e-invoicing voluntarily. The decisions then apply to them, except the penalty decisions.
Government source: Decision 197 of 2026, Article Two (Article 4 as replaced).
Government source: MoF e-invoicing page: legislative documents.
The guidelines call the Tax Group point a grace period and say the system applies in full once it ends. Free zones, small businesses and businesses without a TRN are not on the list. See UAE e-invoicing exemptions for each case.
Government source: MoF Guidelines v2.0, sections 6.3.2.1 and 7.
A yes/no scope check, with a branch for unclear cases
Run this for each type of sale. It is a first review, not a legal ruling.
- 1. Do you carry on a business?Yes: go to 2. No, only passive income such as dividends: the guidelines say you are not in scope, but an MoF FAQ answer adds a receiving duty. Use the unclear branch.
- 2. Is the sale made in the course of that business?Yes: go to 3. Being based outside the UAE does not take you out on its own.
- 3. Is the buyer a business or a government entity?Yes: go to 4. A consumer: out of scope for now. Part of each: split the sale.
- 4. Is the sale on the Article 4 list, with every condition met?Yes: excluded. No: in scope. Not sure: use the unclear branch.
- 5. In scope?Find your revenue group and dates, and make sure you can receive as well as send.
- Unclear branchThe MoF says it does not advise on whether a specific transaction is in scope. It points to the FTA’s paid clarifications service or a tax adviser. Record the facts, the provision and the date you checked.
Government source: MoF FAQ, Policy section: no advice on specific scenarios.
Here is the check applied to example businesses. The first five come from MoF guidance. The last one is fictional.
| Example | Result | Basis |
|---|---|---|
| Hospital bill paid partly by an insurer and partly by the patient (MoF guidance) | Depends on who receives the supply. The payment split alone does not decide it. Only the part that is a business transaction is in scope. | Guidelines s.6.3.4; MoF FAQ, Policy |
| Investment holding company with only passive income (MoF guidelines) | Not in scope without business transactions. A recharge of management costs is a business transaction, so it is in scope. An MoF FAQ answer says it must still engage an ASP to receive. Unclear: confirm. | Guidelines s.6.3.1; MoF FAQ, Policy |
| Supplier to a government entity through a procurement portal (MoF guidelines) | In scope. The sovereign exclusion covers what the government does, not what it buys. | Guidelines s.6.2; Decision 243, Art. 4(1)(a) as replaced |
| UAE wholesaler exporting cosmetics to a retailer in Kuwait (MoF guidelines) | In scope. The tax invoice is an e-invoice, with a fixed placeholder address if the buyer has no Peppol ID. | Guidelines s.10.4, scenario 8 |
| Sales between two branches of one company (question to the MoF FAQ) | Unclear. The MoF did not answer and referred it to advisers. | MoF FAQ, Policy |
| Al Safa Home Furnishings LLC (fictional): shop sales to the public, office fit-outs for companies, revenue AED 6 million | Shop sales out for now. Fit-out invoices in scope. Appoint an ASP by 31 March 2027, implement by 1 July 2027. | Decision 244, Art. 5(1)(b) and 5(2) |
Government source: MoF Guidelines v2.0, sections 6.2, 6.3.1, 6.3.4 and 10.4.
The examples come from official texts or are fictional. None was run on a live system. This is general information, so ask your accountant to confirm how it applies to your business. For exports and imports, see cross-border e-invoicing.
Legal scope is not software readiness
Scope is a legal question, answered by the decisions above. Readiness is a practical one: can your accounting or ERP system produce the data and connect to your ASP?
- Software does not decide scope. A “ready for e-invoicing” label does not tell you which of your sales are in scope.
- A PDF is not an e-invoice. The MoF and the FTA both say PDF, Word, image, scanned and emailed invoices are not e-invoices. See PDF invoice or e-invoice.
- Readiness is your work. The guidelines ask in-scope businesses to run a gap analysis and check that their system can produce every required data point.
- Only an accredited provider. The MoF publishes the ASP list. From 1 October 2026, Decision 168 of 2026 allows only accredited providers to offer the service, and it repealed Decision 64 of 2025. See what an ASP does.
Government source: MoF e-invoicing page: what is an eInvoice.
Government source: FTA: UAE e-Invoicing.
Government source: MoF Guidelines v2.0, Appendix 1, section 13.1(c).
Government source: Decision 168 of 2026, Articles 3, 18 and 20.
StarterKit is not an accredited provider. Our guidance is general information, not legal or tax advice.
What to prepare once you are in scope
- List each legal entity’s types of sale and buyers, and mark each in scope, out of scope or unclear.
- Record your revenue figure, accounting period and evidence.
- Find your Tax Identification Number (TIN): the first 10 digits of your own TRN, even in a VAT group. With no FTA registration, get one in EmaraTax.
- Choose one ASP from the MoF list and start onboarding through EmaraTax.
- Name the person who will watch exchange and reporting results.
Government source: MoF Guidelines v2.0, section 2 and Appendix 1, step 2.
Does my customer’s delay change my obligation?
No. If you issue tax invoices to a buyer not yet on e-invoicing, the guidelines say to send the e-invoice with a fixed placeholder address and also give a regular tax invoice, such as a PDF.
Government source: MoF Guidelines v2.0, sections 6.1 and 10.2.2.
Use our readiness checklist to give each task an owner, and the UAE e-invoicing guide for the whole process.
Prepared by the StarterKit team. Regulatory statements link to UAE government sources. Examples and suggested work plans are labelled separately; they do not determine your business’s legal or tax position. Check the linked decisions for the full conditions and later changes.