The UAE E-Invoicing Guidelines

The UAE e-invoicing model involves a decentralized, Peppol-based framework for in-scope transactions, including B2B, B2G, G2B, and G2G, while excluding B2C. Suppliers must appoint one ASP for e-invoices, maintaining compliance responsibility. Onboarding involves understanding requirements, selecting an ASP, and testing exchanges. Six invoice categories exist, with specified regulations for special scenarios. Data retention spans 5 to 7 years based on entity type. ASP selection criteria focus on integration, support, security, and pricing. Specific guidelines outline mandatory fields for electronic invoices.

Main guideline: overall framework, scope, exclusions, rollout, onboarding, invoice categories, special scenarios, tax categories, retention, and penalties.

ASP selection guide: practical criteria to evaluate Accredited Service Providers (integration, support, security, pricing, scalability).

Mandatory fields guide: required data fields for electronic tax invoices and commercial e-invoices.

UAE e-Invoicing model: decentralized + Peppol-based (using “corners”)

Flow:

• Supplier → its ASP (sends data)
• Supplier ASP → validates/converts to UAE standard XML → sends to buyer ASP + reports tax data to authority corner in parallel
• Buyer ASP → validates → forwards to buyer + reports tax data (if valid)
• Confirmations flow back through the chain

Roles and responsibilities

Compliance responsibility stays with the in-scope person (supplier, or buyer in self-billing). ASPs handle operational/transmission tasks but do not shift legal responsibility.

Scope: who and what is in scope

Applies to persons conducting business in the UAE for in-scope business transactions—not limited to VAT-registered businesses (unless excluded).

Main points:

• In-scope persons must appoint one ASP for sending and receiving e-invoices.
• Customer’s onboarding or tax registration status does not remove supplier’s obligation.

Transaction types covered

• B2B, B2G, G2B, G2G.
• B2C (consumer transactions) are out of scope.

Special scope clarifications

• Investment holding companies: out of scope if purely passive revenue/no business transactions; recharges (e.g. management costs) bring them in scope.
• VAT groups: intra-group transactions remain in scope.
• VAT group grace period: 24-month grace for intra-group implementation, starting 1 Jan 2027.
• Non-UAE established persons: must issue e-invoices if required to issue tax invoices under UAE VAT rules.

Onboarding preparation (4-step sequence)

Initiated by the person/entity via EmaraTax (not ASP).

Steps:

• Understand legal/technical requirements; assess ERP/accounting changes.
• Select ASP, onboard via EmaraTax, obtain Peppol participant identifier.
• Test end-to-end exchange and reporting.
• Go-live, define error handling.
• Ongoing change management and offboarding as needed.

Invoice categories & transition

6 categories (standard billing + self-billing). No separate provisional invoice category—use additional invoice or credit note for adjustments.

Transition: If buyer not yet e-invoicing-ready, supplier issues regular invoice (e.g. PDF) alongside e-invoice, using endpoint 0235:9900000098 on the e-invoice.

Special scenarios

Free Zone, Deemed Supply, Margin Scheme, Summary Invoice, Continuous Supply, Agent Billing, e-Commerce, Exports (each with specific field/issuance rules).

Tax categories

Standard rate, Exempt, Outside scope, Reverse charge, Zero-rated, Margin scheme.

Reverse charge specifics

• Imports of “concerned goods/services” (for VAT reporting) are not subject to e-invoicing.
• Domestic reverse charge: for specified UAE domestic goods between VAT registrants; supplier issues e-invoice without VAT, includes narrative explanation + reference to goods type.

Data retention

• 5 years – taxable persons (from relevant tax period)
• 5 years – others (from end of calendar year of creation)
• 7 years – real estate records
• Extra periods in audit, dispute, or certain voluntary disclosure cases

Storage interpretation

Article 11 “store within the State” is functional: records must be accessible, reproducible, and retrievable by FTA on request—regardless of physical server/cloud location—if integrity, security, and accessibility conditions are met.

Official guideline links:

• UAE Electronic Invoicing Guidelines (Main Guide)
• Considerations for Selecting an Accredited Service Provider
• UAE Electronic Invoice Mandatory Fields