Executive summary

On 29 September 2025, the Ministry of Finance (MoF) of the United Arab Emirates (UAE) published on its website Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (MD No. 243) and Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System (MD No. 244). These decisions introduce significant updates to the e-invoicing framework with which businesses in the UAE must comply.

Both the MDs will be effective upon their publication in the Official Gazette.

Detailed discussion

Background

The MoF initially introduced the concept of e-invoicing during the E-Invoicing Exchange Summit in February 2024, marking the start of public engagement. Following this, a dedicated e-invoicing website was launched in October 2024, providing resources and updates. (See EY Global Tax Alert, UAE formally announces introduction of e-invoicing, launches e-invoicing portal and amends VAT Law provisions, dated 6 November 2024.)

A data dictionary was released for public consultation in February 2025, allowing stakeholders to provide feedback on the proposed data structure for e-invoices. (See EY Global Tax Alert, UAE Ministry of Finance releases consultation document on eInvoicing — detailed review, dated 14 February 2025.) The issuance of MD No. 243 and MD No. 244, which clarify the scope and timelines of the e-invoicing system, is a concrete step in the direction of implementing e-invoicing in the UAE.

Key provisions of MD No. 243 and MD No. 244

Scope of application

E-invoicing will apply to all businesses conducting commercial transactions in the UAE, including nonresidents, unless specifically excluded.

Key exemptions include:

• Business transactions conducted by government entities in their sovereign capacity
• International airline services for which electronic tickets are issued, as well as any related ancillary services provided by the airline
• International transportation services related to goods with airway bills — exempt for 24 months
• Value-added tax (VAT)-exempt or zero-rated financial services
• Any other transactions designated by the Minister of Finance

Implementation timeline

A pilot program (by invitation only) will begin on 1 July 2026, with voluntary adoption available from that date. Mandatory adoption will occur in phases:

• Businesses with revenues of 50 million United Arab Emirates Dirhams (AED50m, approximately US$13.6m) or more must comply by 1 January 2027.
• Businesses with revenues below AED50m must comply by 1 July 2027.
• Government entities must comply by 1 October 2027.

Appointment of Accredited Service Providers (ASPs)

All businesses must appoint an ASP by the specified deadlines to facilitate the e-invoicing system implementation.

Data storage requirements

Article 11 of MD No. 243 clarifies that electronic documents must be stored within the UAE.

Implications

Businesses operating in the UAE should prepare and review their current invoicing practices for compliance with the upcoming e-invoicing requirements. This includes appointing ASPs, implementing necessary changes to invoicing processes and ensuring that data storage complies with UAE regulations.