Who Needs to Submit an E-Invoice in UAE?

The UAE is rapidly transitioning from traditional paper and PDF invoices to a fully integrated e-invoicing system as part of its nationwide digital tax transformation. Following the Ministry of Finance’s official e-invoicing legislation introduced in 2025, e-invoicing in the UAE is being implemented in phases to enhance VAT compliance, improve transparency in B2B and B2G transactions, prevent invoice fraud, and enable real-time reporting and audit readiness. As this shift directly impacts all VAT-registered businesses, understanding who needs to submit e-invoices in the UAE , along with the applicable timelines, has become essential for companies to remain compliant, avoid penalties, and ensure smooth financial operations in the evolving UAE tax environment.

What is E-Invoicing in the UAE?  

E-Invoicing in the UAE refers to the issuance, transmission, and storage of invoices in a structured electronic format through an approved electronic invoicing system, as per the UAE Ministry of Finance and Federal Tax Authority regulations. Unlike a simple PDF or scanned invoice sent by email, a compliant UAE e-invoice must be generated in a machine-readable format such as XML, based on international standards like UBL and the UAE-specific PINT AE framework . It must contain all mandatory data fields defined by the MoF, including the seller and buyer TRN , invoice number, date, taxable amount, VAT amount, and total value. These invoices must be exchanged through a MoF-approved Accredited Service Provider (ASP) , and any corrections must be issued as e-credit notes in the same structured format. Additionally, all e-invoice data must be securely stored within the UAE in compliance with tax laws. In simple terms, e-invoicing in the UAE is a fully digital, tamper-proof, standardized invoicing system designed for real-time compliance, VAT transparency, and audit readiness.

Is E-Invoicing Mandatory in the UAE?  

Yes, e-invoicing in the UAE is being implemented in a phased manner. In September 2025, the Ministry of Finance (MoF) issued two official ministerial decisions Decision No. 243 of 2025 and Decision No. 244 of 2025    which clearly define the scope, technical framework, and timelines for the mandatory adoption of the UAE e-invoicing system across businesses and government entities.

Timeline of Implementation:  

• A pilot programme starts 1 July 2026 , involving a select group of taxpayers (Taxpayer Working Group).
• Voluntary e-invoicing is allowed from 1 July 2026  businesses can begin early adoption if they wish.
• Mandatory implementation   (phase-wise):

Who Needs to Submit an E-Invoice in UAE?  

Based on the official e-invoicing rules, the following categories are required to submit e-Invoices:

1. VAT-registered Businesses Engaged in B2B or B2G Transactions  
    
   • All businesses registered under VAT that issue invoices to other businesses (B2B) or to government entities (B2G) are in scope.
   • This includes both large enterprises and small/medium enterprises though the compliance date depends on the annual revenue threshold.
      
2. Large Businesses (Revenue ≥ AED 50 Million)  
    
   • These are the first group that must comply. They must appoint an ASP by 31 July 2026 and start e-invoicing from 1 January 2027.
      
3. Small and Medium Businesses (Revenue < AED 50 Million)  
    
   • Even SMEs are included. They must appoint an ASP by 31 March 2027 and begin e-invoicing by 1 July 2027.
      
4. Government Entities (B2G)  
    
   • Government departments and bodies engaging in business transactions under scope must also comply. They need to appoint an ASP by 31 March 2027, and start issuing e-invoices by 1 October 2027.
      
5. Any Other Person the MoF Includes Later

• The legislative framework allows the MoF to expand the scope over time. 
  
   

Who Does NOT Need E-Invoicing (For Now)?  

• Currently, businesses in the UAE that operate solely in Business-to-Consumer (B2C) transactions are temporarily exempt from the mandatory e-invoicing requirements. This means companies selling only to end customers, rather than other businesses or government entities, are not immediately required to issue compliant e-invoices. However, the Ministry of Finance (MoF) may expand the scope in the future, so staying informed and preparing for eventual compliance is recommended.
   
• Certain transactions are exempt from mandatory e-invoicing under UAE regulations. These primarily include businesses operating in VAT-exempt or zero-rated sectors, such as specific financial services, certain international airline services, and non-commercial or sovereign government activities. Essentially, if a transaction falls outside the standard B2B or B2G taxable activities, e-invoicing is not immediately required. However, voluntary adoption is permitted, allowing businesses to align with UAE e-invoicing compliance ahead of the mandated timelines.

Note :  “Exemption” does not mean you cannot or should not voluntarily adopt e-invoicing. The law explicitly allows voluntary adoption from 1 July 2026 and doing so can give businesses a head start in compliance readiness. 

How Do I Prepare an E-Invoice in UAE? Step by Step Process?  

Choose an MoF-Approved E-Invoicing Software    

• Select a software or Accredited Service Provider (ASP) certified by the UAE Ministry of Finance.
• Ensure it supports structured formats and integrates with your business workflows.
  
   

Integrate with Accounting Systems    

• Connect your ERP or POS system with the e-invoicing platform.
• Integration ensures smooth generation, transmission, and record-keeping of invoices.
  
   

Use the Correct Invoice Format    

• Generate invoices in a structured format (XML) or as PDF-A3 with an embedded XML file.
• This format is mandatory for compliance and machine readability.
  
   

Include All Mandatory Fields    

• Key fields include: TRN, invoice number, invoice date, taxable amount, VAT amount, and QR code.
• Correct fields ensure the invoice is accepted by the FTA and valid for VAT purposes.
  
   

Apply Digital Signatures    

• Add a digital signature to prevent tampering and guarantee authenticity.
• Ensures the e-invoice is secure and legally valid.
  
   

Validate the Invoice Before Issuance    

• Check for errors using the e-invoicing software.
• Ensure data accuracy to avoid rejection or compliance issues.
  
   

Maintain Electronic Archiving    

• Store all e-invoices digitally for the mandatory retention period defined by UAE VAT law.
• Proper archiving makes audits easier and keeps your business compliant.

How Reyson Badger Helps Businesses Become E-Invoicing Ready?  

Reyson Badger supports businesses across the UAE in smoothly transitioning to the new e-invoicing system. Our experts start by conducting a thorough compliance assessment to identify gaps in your current invoicing processes. We then help you select and implement a Ministry of Finance-approved e-invoicing software that integrates seamlessly with your existing accounting, ERP, or POS systems. From structuring invoices in the required XML or PDF-A3 format to adding digital signatures and QR codes, we ensure every invoice meets UAE regulations. We also provide staff training, ongoing support, and guidance on electronic archiving, making sure your business stays compliant, efficient, and audit-ready. Whether you are an SME, startup, or large enterprise, Reyson Badger simplifies e-invoicing so you can focus on growing your business while staying fully compliant.
 

Conclusion  

E-invoicing in the UAE is no longer optional for most VAT-registered businesses. Large enterprises, SMEs, and government entities dealing with B2B or B2G transactions are required to adopt a MoF-approved electronic invoicing system within the specified deadlines, while purely B2C businesses are currently exempt. Preparing early is essential; it ensures smooth compliance, reduces errors, and makes your invoicing process more efficient and audit-ready. Reyson Badger helps businesses navigate the UAE e-invoicing journey with end-to-end support, from selecting and integrating compliant software to staff training and ongoing guidance. With Reyson Badger , VAT-registered businesses in the UAE can confidently meet all e-invoicing requirements while focusing on growth and operational efficiency.