The UAE Ministry of Finance (‘the MoF’) recently released comprehensive E-invoicing guidelines, underscoring the Government’s dedicated approach to a standardized and timely implementation of new system. The key aspects of the guidelines are summarized below:
E-invoicing Guidelines – Inclusions & Exclusions
| Inclusions | Exclusions |
|
|
Temporary Grace Period
A temporary grace period of 24 months from 1 January 2027 has been granted to implement the e-invoicing regulations with respect to the following transactions:
- Transactions between the companies under the same VAT Group
- International transportation of goods by an Airline, where Airway bill is issued
Type of Invoices and Tax Codes
| Type of Document | Nature of transactions |
| Electronic Tax Invoice and Electronic Tax Credit Note | Eg: Standard Rated Sales, Export Sales (including self-billing arrangements) |
| Commercial Invoice and Electronic Credit Note | Eg: Out of Scope supplies, exempt supplies, supplies by VAT unregistered businesses etc. |
Use of Peppol ID
| Peppol ID | Nature of transactions |
| 235+10-digit TIN | For all businesses registered for e-invoicing Businesses conducting transactions under the purview of E-Invoicing, but not registered for any tax, must register with the FTA to obtain a TIN |
| 0235:9900000098 | Transactions where the buyer is not registered under of E-invoicing system For the Buyer who is not in scope of E-invoicing, the predefined Peppol ID will be used, but a human-readable invoice will be issued to recover input tax credit on the same |
| 0235: 9900000099 | Transactions where the buyer is overseas and does not have a Peppol ID |
| 0235: 9900000097 | Transactions classified as Deemed Supply |
Other Key Aspects
- A detailed guide has been issued on Invoice data fields (mandatory fields with clarification of each fields)
- Key requirement is the Invoice Transaction Type Code, which needs the issuers to explicitly flag include transaction involving Freezone, Deemed supply, Margin Scheme, Summary Invoice, Continuous Supply, Disclosed Agent billing, Supply through E-commerce and Exports
- For a retail business that only carries out B2C, E-invoicing shall (currently) not apply. If the business has both B2B and B2C transactions, E-invoicing applies to the B2B part
- E-Invoicing framework is designed to support both the Arabic and English languages. Whilst Arabic is not mandatory, the FTA has the mandate to request a translation in Arabic of any Tax Records
- A separate Tax Invoice or commercial invoice (i.e., one that is not e-invoice) may be required by the buyers which have not yet implemented e-invoicing to support recovery of input tax credit, corporate income tax deductions, etc.
- E-invoicing data can be stored outside UAE provided it is readily made available whenever required.