UAE Electronic Invoicing System: Key amendments

The UAE Ministry of Finance (MoF) has announced targeted amendments to the ministerial decisions governing the UAE Electronic Invoicing System, including an extension of the deadline for certain large businesses to appoint an Accredited Service Provider (ASP). The announced changes follows the MoF’s assessment of the market readiness and business feedback on the need for broader technical options and more competitive pricing, while perceiving the mandatory implementation timeline for the first implementation phase.

Key Changes for Large Businesses:

Under Ministerial Decision No. 244 of 2025, the first mandatory phase applies to persons subject to Electronic Invoicing System who’s Revenue equal to or exceeding AED 50,000,000. MoF has announced that the ASP appointment deadline for persons with annual revenues exceeding AED 50,000,000 will be extended from of 31 July 2026 to 30 October 2026, while the mandatory implementation date remains 1 January 2027.

Business below the AED 50,000,000 Revenue threshold and Government Entities Remain subject to later statutory milestone under Ministerial decision No. 244 of 2025, Businesses with revenue below AED 50 million must appoint an ASP by 31 March 2027 and implement by 1 October 2027. Business to consumer transactions, and persons engaged exclusively in such transactions, are outside the Electronic Invoicing System until a further decision is issued by the Minister.

Broader ASP market and accreditation framework:

The MoF has also announced changes to the service provider accreditation framework intended to allow UAE-based companies to deliver technology solutions in collaboration with third-party providers, including international service providers. The MoF stated that 32 service providers have already been approved, with additional providers in the final stage of accreditation, and expects the changes to support a more integrated and competitive technical eco system.

Next steps

The extended ASP appointment deadline should not be treated as a deferral of the mandatory go-live date. At this stage it is advisable that businesses confirm whether they are subject to the Electronic Invoicing System, verify their revenue for the most recent accounting period, identify any transaction flows that may fall outside the current scope as business to consumer transaction, select and contract with an ASP within the applicable statutory deadline, and begin onboarding system-integration and technical-readiness work early enough to meet the relevant implementation date. Large businesses with Revenue equal to or exceeding AED 50,000,000 should proceed on the basis that mandatory implementation remains required by 1 January 2027, notwithstanding the announced extension of the ASP appointment deadline to 30 October 2026.

Webinar

To support clients in preparing for the implementation of the UAE Electronic Invoicing System, we are considering hosting a dedicated webinar covering the key legal requirements, implementation timelines, and practical steps businesses should be taking now. Please click here if you would be interested in attending.