Executive summary

The United Arab Emirates (UAE) Ministry of Finance (MoF) has released a 168-page public consultation document, the eInvoicing Programme Consultation Paper (Consultation Document) on the planned introduction of eInvoicing in the UAE, as explained on the MoF website. The Consultation Document outlines the main features of the proposed eInvoicing model, the framework of eInvoicing in the UAE and the expected Data Dictionary, along with specific use cases.

The MoF invites comments on the Consultation Document to be submitted as per the prescribed online submission by 27 February 2025.

Detailed discussion

Background

In October 2024, the UAE MoF formally announced that eInvoicing will be implemented in the UAE from June 2026 and launched the eInvoicing portal providing key information on the new digital requirements for businesses in the UAE. EInvoicing in the UAE is part of the country's broader digital transformation and tax compliance initiatives.

Consultation objectives

The Consultation Document provides information to help businesses assess the impact of the proposed eInvoicing data fields on their processes and billing systems. The objective of the MoF in issuing the Consultation Document, is to gather targeted feedback from stakeholders (businesses and service providers) to refine the eInvoicing Data Dictionary document. The Consultation Document is intended to provide an understanding to the MoF on the practical requirements of businesses and processes, and to identify any gaps or additional data fields. Further, the consultation process aims to obtain diverse perspectives, including from industry experts, accounting firms, and eInvoicing service providers, to create a holistic and widely accepted electronic invoicing framework.

Consultation framework

The consultation framework encompasses the following:

Likely targeted business: EInvoicing requirements are expected to apply to all businesses operating in the UAE, regardless of their VAT registration status.

Data dictionary overview and contents: In the era of eInvoicing, businesses must ensure that eInvoices comply with all data requirements outlined in the Data Dictionary. This Dictionary serves as the foundation of eInvoicing and, within this consultation, details the expected key data elements (fields) and their attributes for the most commonly used invoice types by businesses in the UAE. This includes tax invoices, tax credit notes, self-billing and other applicable scenarios. The minimum mandatory fields required when issuing tax invoices (50 fields) or commercial invoices (49 fields) in XML format are also specified, many of which are not currently covered by the UAE value-added tax (VAT) legislation.The Consultation Document confirms that more conditional fields exist in the full Data Dictionary, which is yet to be released.

Use cases: The Consultation Document illustrates 16 use cases representing typical and common scenarios for generating tax invoices and tax-credit notes in the UAE. Of these, five are identified as mandatory (e.g., standard tax invoice/tax-credit note, commercial invoice, and self-billing tax invoice/tax-credit note), while the remaining serve as additional requirements (e.g., supplies subject to the reverse-charge mechanism, zero-rated supplies, summary tax invoices, disclosed-agent billing invoices and credit notes).

Implementation rollout: While further details on the rollout strategy are pending, it is reconfirmed that eInvoicing will be implemented in a phased manner.

In responding to the Consultation Document, stakeholders are requested to provide feedback on a set of questions.

Implications

Interested parties can take the opportunity to participate in refining the eInvoicing framework and enhancing the Data Dictionary by providing feedback on the Consultation Document by the 27 February 2025 deadline, considering the feedback submission requirements.