UAE e-invoicing 2027: phases, deadlines and PINT-AE

UAE e-invoicing explained: who is in scope, Phase 1 and Phase 2 deadlines, ASP appointment, PINT-AE fields, credit notes and CD 106/2025 penalties.

At a glance

From 2027, most UAE business-to-business invoices must travel as structured PINT-AE data through an accredited service provider, not as PDFs. Here is who is affected, when, and what to prepare this quarter.

Every business in the UAE is in scope for B2B and B2G invoices, VAT-registered or not. B2C is out for now.

Revenue under AED 50m (Phase 2): appoint an accredited service provider by 31 Mar 2027, go live 1 Jul 2027.

A PDF is no longer the legal invoice. The legal invoice is the PINT-AE XML file exchanged over Peppol.

Tax invoices carry 51 mandatory fields; commercial invoices from non-registrants carry 49.

Issue within 14 days. Late e-invoices cost AED 100 each, capped at AED 5,000 a month.

Missing the ASP deadline costs AED 5,000 for each month or part month of delay.

Key dates

1 Jul 2026: Pilot starts and voluntary adoption opens

30 Oct 2026: Phase 1 (revenue ≥ AED 50m): appoint ASP

1 Jan 2027: Phase 1 mandatory go-live

31 Mar 2027: Phase 2 (revenue < AED 50m) and government: appoint ASP

1 Jul 2027: Phase 2 mandatory go-live

1 Oct 2027: Government entities go live

What actually changes

Today most UAE businesses email a PDF and call it a tax invoice. Under the electronic invoicing system set up by Ministerial Decision 243/2025, that PDF stops being the legal document. The legal invoice becomes a structured XML file in the PINT-AE format, exchanged over the international Peppol network.

The UAE uses a 5-corner model. You (corner 1) create the invoice in your accounting system. Your Accredited Service Provider (ASP) (corner 2) validates it and sends it to your customer's ASP (corner 3), which delivers it into your customer's system (corner 4). Both ASPs report the tax data to the FTA platform (corner 5).

Both sides need an ASP. The issuer and the recipient must each appoint one (MD 243 Art 5 and 6(7)). You appoint one ASP for both sending and receiving.

Only accredited providers count. The Ministry of Finance publishes the list; accreditation now runs under Ministerial Decision 168/2026, which replaced MD 64/2025 from 1 Oct 2026.

Your Peppol address is your TIN: the first 10 digits of your 15-digit TRN, with scheme code 0235. A tax-group member uses its own TIN, not the representative member's.

No QR code, no PDF as the legal record. You can still send a human-readable copy, but the XML is what counts.

Receiving matters too: E-invoicing is not only about sending. Your ASP will also receive supplier e-invoices, and you must process them through the system (MD 243 Art 6(3)). Plan for the accounts-payable side, not just sales.

Who is in scope, and what is excluded

Scope is wide. MD 243/2025 Art 3 covers every person conducting business in the UAE, for every business transaction, whether or not they are VAT-registered. That means business-to-business (B2B) and business-to-government (B2G) sales. A business below the VAT threshold still issues e-invoices, using the commercial-invoice field set instead of the tax-invoice one.

B2C is out, until a future Minister's decision. A business that sells exclusively to consumers is not in scope (MD 244/2025 Art 5(2)). A café that also invoices corporate catering clients is in scope for those corporate invoices.

Excluded transactions (MD 243 Art 4(1))

Government entities acting in a sovereign capacity and not competing with the private sector.

International passenger air transport issued with an e-ticket, and airline ancillary services issued with an EMD.

International air cargo with an airway bill, for 24 months from system start only.

Financial services that are exempt or zero-rated under the VAT Executive Regulation.

Businesses can also join voluntarily before their phase. Voluntary adopters must comply fully but are not subject to the CD 106/2025 penalties (Art 2(2)).

Timeline: Phase 1, Phase 2 and government

The phases come from Ministerial Decision 244/2025 as amended by MD 66/2026. The May 2026 amendment moved the Phase 1 ASP deadline from 31 Jul 2026 to 30 Oct 2026; the go-live dates did not change.

Phase | Who | Appoint ASP by | Mandatory from

Pilot | Taxpayer Working Group (MoF invitation) | n/a | 1 Jul 2026

Voluntary | Any business | n/a | From 1 Jul 2026

Phase 1 | Revenue ≥ AED 50,000,000 | 30 Oct 2026 | 1 Jan 2027

Phase 2 | Revenue < AED 50,000,000 | 31 Mar 2027 | 1 Jul 2027

Government | Government entities | 31 Mar 2027 | 1 Oct 2027

What "revenue" means

"Revenue" is gross income for your most recent accounting period, as shown in your financial statements or other documents the FTA accepts (MD 244 Art 1). It is not profit and not VAT-taxable turnover.

Example: a Dubai trading company reports gross income of AED 38 million for its last financial year. It is Phase 2: it must appoint an ASP by 31 Mar 2027 and issue e-invoices from 1 Jul 2027. A group company with AED 62 million is Phase 1: its ASP deadline was 30 Oct 2026 and it goes live on 1 Jan 2027.

PINT-AE: the data your invoices must carry

The Ministry of Finance's Mandatory Fields document (v1.0, 23 Feb 2026) lists 51 fields for an electronic tax invoice and 49 for a commercial invoice (issued by a non-VAT-registered seller). Most are familiar. The ones that trip businesses up are about master data and structure.

Seller and buyer identifiers. Your TRN, your TIN-based endpoint (scheme 0235), your legal registration number and type (trade licence, Emirates ID, passport), and the same for each customer.

Emirate codes. Seller and buyer addresses need a country subdivision such as DXB, AUH or SHJ. It is required even for foreign buyers.

Transaction-type flags. Each invoice carries an 8-position code flagging free zone, deemed supply, profit margin scheme, summary invoice, continuous supply, disclosed agent billing, e-commerce and exports. Some flags trigger extra data, such as a beneficiary ID for free-zone supplies.

AED amounts on every line. Each line needs its VAT in AED and its total payable in AED, including VAT. A line of AED 1,000 net plus AED 50 VAT shows a line amount of AED 1,050. Foreign-currency invoices also need the exchange rate and AED totals.

Item name and item description are both mandatory on every line.

Exempt and reverse-charge lines need reason or goods-type codes, or the ASP will reject the invoice.

No more simplified invoices: Once you are in e-invoicing scope (or e-invoicing voluntarily), simplified tax invoices are switched off for those transactions (VAT Executive Regulation Art 59(16), added by Cabinet Decision 100/2025). Every in-scope B2B sale needs the full field set, even small ones under AED 10,000.

Buyers without a TIN use predefined endpoints: one for deemed supplies, one for a buyer not yet on e-invoicing (you still give them a PDF tax invoice), and one for an export buyer without a Peppol ID. Those invoices are reported to the FTA only.

Credit notes, the 14-day rule and storage

Electronic credit notes

You must issue an e-credit note when a transaction is cancelled, the price is reduced, money is refunded in full or in part, or there is an administrative or numerical error (MD 243 Art 6(2)). You cannot edit an issued e-invoice, and negative invoices are not allowed.

Reason code: every credit note carries one, matching VAT Law Art 61(1): cancelled supply, change in tax treatment, consideration altered (including bad debt), goods returned, tax charged in error, or a volume discount.

Reference the original: the credit note must quote the original invoice number. One credit note can reference several invoices. Only volume-discount credit notes can skip the reference.

Timing: within 14 days of the event for VAT registrants (VAT Law Art 62(2)).

The 14-day rule

Every business must issue and transmit the e-invoice within 14 days of the date of the business transaction, which is the earlier of the transaction date and the date you receive payment (MD 243 Art 6(5)). VAT registrants must also meet the VAT Law 14-day deadline from the date of supply. Example: a customer pays a deposit of AED 20,000 on 3 Aug 2027 for goods delivered on 25 Aug. The clock starts on 3 Aug, so the e-invoice for the deposit is due by 17 Aug.

Storage and system failures

Storage: keep e-invoices, credit notes and associated data for the tax-record retention period (generally 5 years; 7 years for real estate). MD 243 Art 11 says "within the State"; the MoF Guidelines v1.1 read this as retrievable and reproducible on FTA request, wherever the server sits. Keeping data in a UAE region is the cautious choice.

System failure: if your system or ASP fails, notify the FTA within 2 business days (MD 243 Art 12). This applies to issuers and recipients.

Data changes: tell your ASP in writing within 5 business days after the FTA confirms a change to your registered details (MD 243 Art 5(3)).

Penalties under Cabinet Decision 106/2025

Cabinet Decision 106/2025 has been in force since 15 Oct 2025. The penalties apply once you are mandatorily in scope; voluntary adopters are excluded.

Violation | Penalty

Failure to implement the system, including not appointing an ASP on time | AED 5,000 per month or part month of delay

E-invoice not issued or transmitted on time | AED 100 per invoice, max AED 5,000 per calendar month

E-credit note not issued or transmitted on time | AED 100 per credit note, max AED 5,000 per calendar month

Issuer or recipient late notifying the FTA of a system failure | AED 1,000 per day or part day

Late notifying your ASP of a registered-data change | AED 1,000 per day

Worked example: a Phase 2 company appoints its ASP on 15 May 2027 instead of 31 Mar. That is one full month plus part of a second, so AED 10,000. In July it sends 30 invoices late: 30 × AED 100 = AED 3,000. If it had sent 80 late, the charge would be capped at AED 5,000 for that month.

VAT penalties can apply as well: Separately from CD 106/2025, failing to issue a tax invoice or credit note, or not following the e-issuance conditions, carries an administrative penalty of AED 2,500 per case under Cabinet Decision 40/2017 as amended by Cabinet Decision 129/2025.

Reporting to the FTA: what is still unconfirmed

MD 243 Art 6(6) says both issuer and recipient must report e-invoices and credit notes to the FTA within a timeline the Minister will set. As of October 2026, that timeline has not been published.

The mechanism is known from the MoF Guidelines v1.1: your ASP reports the tax data to the FTA at the same time it sends the invoice to your customer's ASP, and the customer's ASP reports after it validates the invoice. In practice, reporting happens through the ASPs as part of the exchange. Until the timeline is formally set, confirm the details with your ASP and your adviser.

What to do this quarter (Phase 2 SMEs)

If your revenue is under AED 50 million, you have until 31 Mar 2027 to appoint an ASP. That is about five months. Starting now leaves time to test before 1 Jul 2027.

Confirm your phase. Take gross income from your latest financial statements. Under AED 50m means Phase 2. Run the readiness check if unsure.

Get your TIN. Your TIN is the first 10 digits of your TRN. If you have no TRN and are not registered for corporate tax, register with the FTA to obtain one.

Clean customer and supplier master data. For each B2B counterparty: TRN or TIN, legal registration number and type, emirate code and full address.

Shortlist ASPs from the MoF accredited list. Ask about pricing per document, API integration with your accounting system, receiving and storage.

Map your invoice types. Identify free-zone, export, margin-scheme, summary, agent and e-commerce invoices, plus any exempt or reverse-charge lines that need codes.

Fix your credit-note process. No more editing or voiding issued invoices; every adjustment becomes a credit note with a reason code and a reference to the original.

Plan for the 14-day clock, including deposits and advance payments, which start it early.

Write a short failure procedure: who notifies the FTA within 2 business days if the system goes down.

Common mistake: Assuming "we are not VAT-registered, so this does not apply". E-invoicing scope is not tied to VAT registration. If you invoice other businesses, you are in. See also our UAE VAT guide and the tax calendar.

How Rami handles this

Sami checks each invoice and credit note against the PINT-AE mandatory fields and business rules before it leaves, and flags what is missing.

Approved invoices are sent through your own accredited service provider. Rami is not an ASP and is not FTA-accredited.

Sami tracks the 14-day issue window and drafts credit notes with the right reason code for you to approve.

Customer master data (TIN, TRN, emirate, Peppol endpoint) is checked for gaps so you can fix them before go-live.

Sources

Federal Decree-Law 28/2022 (Tax Procedures Law) Art 4(bis), added by Federal Decree-Law 17/2024

Federal Decree-Law 8/2017 on VAT Art 65(5), 70(4), as amended by Federal Decree-Law 16/2024

VAT Executive Regulation Art 59(16) and 60(8), added by Cabinet Decision 100/2025

Ministerial Decision 243/2025 (e-invoicing system scope and obligations)

Ministerial Decision 244/2025 as amended by Ministerial Decision 66/2026 (implementation phases)

Ministerial Decision 168/2026 (accreditation of service providers; replaced Ministerial Decision 64/2025 from 1 Oct 2026)

Cabinet Decision 106/2025 (e-invoicing penalties)

Cabinet Decision 40/2017 as amended by Cabinet Decision 129/2025 (VAT invoice penalties)

MoF UAE Electronic Invoice Mandatory Fields v1.0 (23 Feb 2026)

MoF UAE Electronic Invoicing Guidelines v1.1 (1 Jun 2026)

OpenPeppol PINT AE Billing 1.0.4

Last updated 2026-10-19. This guide is general information as of October 2026, not legal or tax advice.