Executive summary

On 19 March 2025, the United Arab Emirates (UAE) Ministry of Finance (MoF) released Ministerial Decision No. 64 of 2025, confirming the accreditation process and criteria published in the MoF website, for ASPs to become accredited by the MoF, a crucial component of the UAE's electronic-invoicing (eInvoicing) initiative. Accredited Service Providers (ASPs) will act as mandatory access points to the Peppol network (i.e., an electronic-invoicing framework), responsible for validating and transmitting eInvoicing data between suppliers and buyers, as well as reporting to the Federal Tax Authority (FTA).

Though the primary impact of the ASP accreditation process falls on eInvoicing-solution vendors, businesses must prepare to engage an ASP to facilitate compliance with MoF requirements.

Detailed discussion

The ASP accreditation process

The role of the ASP is central to the UAE eInvoicing initiative, as it is mandatory for affected businesses to appoint an ASP. The ASP serves as the access point to the eInvoicing (Peppol) network for businesses and is responsible for validating and transmitting eInvoicing data between suppliers and buyers, in addition to reporting eInvoicing data to the FTA. The accreditation process allows eInvoicing-solution providers to act as ASPs in the UAE if they satisfy a set of predefined MoF requirements, which the MoF will assess and regularly audit.

The initial application process is expected to take up to 90 days (unless the MoF requests additional information). Following a successful application, the service provider will undertake a preapproval process that, if successful, will permit the service provider to operate as an ASP for a limited period of time, during which the ASP must complete the final accreditation requirements. Once fully accredited, the MoF will publish the details of the ASP on its website.

The MoF has also published a detailed User Guide and FAQs on its website.

What is required of each business prior to engaging an ASP?

While the role of the ASP (on behalf of the seller and the buyer) is to receive, validate and transmit the data, the role of UAE businesses is to collect and submit the required data to the ASP. To ensure the correct dataset is provided to the ASP, businesses should undertake preliminary actions, such as:

• Identify the systems currently generating invoices (i.e., billing systems) within the organization.
• Identify the transactions being captured within each billing system and determine whether those transactions are in scope or out of scope for eInvoicing purposes.
• Map each in-scope transaction to the relevant eInvoicing use case to understand the applicable eInvoicing data set for each transaction.
• Compare the current dataset for each transaction (per billing system) against the relevant eInvoicing use case.
• Understand how to remediate the identified gaps, i.e., walk down the data chain to locate the source systems feeding the data to the billing systems.
• Identify the process owner within the organization to remediate the data within each source system.
• Retest the output to help ensure accuracy.

Providing the required eInvoicing data and ensuring its accuracy is a task that remains solely with the business.

Implications

Businesses should prepare to carry out a readiness assessment of their invoicing processes, before engaging an ASP, to identify any business-specific or industry-related challenges that could affect the type of ASP to be selected or the overall eInvoicing implementation process.

Business should also monitor when the MoF will likely publish the first list of ASPs. Although the ASPs will need to adhere to the minimum standards set forth in the MoF accreditation process, it would be beneficial for businesses to evaluate other differentiating factors between the ASPs to understand alignment with their specific needs.