United Arab Emirates e-Invoicing Guide

The United Arab Emirates is rolling out one of the most ambitious e-invoicing programs in the Gulf region. Under Cabinet Decision No. 100/2025, all VAT-registered businesses will be required to issue structured electronic invoices through a 5-corner DCTCE model — a framework where Accredited Service Providers handle invoice exchange while the Federal Tax Authority receives tax data as the fifth corner in near real-time.

Unlike simpler PDF-based systems, the UAE mandate requires invoices in the PINT AE format, built on UBL 2.1. This means businesses need compliant software capable of generating, transmitting, and receiving structured XML data through the Peppol network.

The UAE is taking a phased approach, starting with a pilot in July 2026 for the largest enterprises and progressively expanding to smaller businesses through 2027. Each wave is grouped by annual revenue threshold, giving businesses clear preparation windows before their mandatory go-live date.

All VAT-registered entities conducting B2B transactions will eventually fall under the mandate. The rollout is revenue-based: businesses with the highest annual turnover are in the first wave, with subsequent phases lowering the threshold progressively.

B2C transactions are currently excluded from the mandatory scope. Entities that voluntarily adopt e-invoicing before their mandatory date are not subject to penalties during the voluntary period, making early adoption a low-risk strategy.

The UAE uses a decentralized 5-corner model. Businesses do not connect directly to a government platform. Instead, they send and receive invoices through Accredited Service Providers who handle validation, routing, and delivery via the Peppol network.

The FTA sits as the fifth corner, receiving tax-relevant data from ASPs in near real-time. This means the tax authority has visibility into transactions without being a bottleneck in the invoice exchange process. Businesses must appoint an ASP and ensure their ERP or accounting software can generate PINT AE-compliant invoices.

The UAE has published a detailed penalty framework under Cabinet Decision No. 106/2025. Penalties are structured by violation type, with the heaviest fines targeting businesses that fail to implement the system entirely or fail to appoint an Accredited Service Provider.