United Arab Emirates Publishes Version 2.0 of E-Invoicing Guidelines
The UAE Ministry of Finance has released Version 2.0 of the UAE Electronic Invoicing Guidelines, dated October 26, 2026. The update builds on the June 2026 edition and reflects recent legislative amendments. It also adds clarifications on taxpayer and buyer identification, invoice classification, advance payments, healthcare and insurance claims, newly established businesses, and data storage, including a new Appendix 6 on key PINT-AE requirements.
The update does not introduce a new e-invoicing model or change the implementation timeline. The mandatory go-live date of January 1, 2027 remains in place, and businesses with annual revenue of AED 50 million or more must appoint an Accredited Service Provider (ASP) by October 30, 2026.
Updated Legal References
The Guidelines now refer to:
- Ministerial Decision No. 168 of 2026 on ASP accreditation, which replaces the reference to Ministerial Decision No. 64 of 2025;
- Cabinet Decision No. 173 of 2026 on e-invoicing penalties, which replaces the reference to Cabinet Decision No. 106 of 2025.
Taxpayer and Buyer Identification
The new Appendix 6 separates the identifier used on the Peppol network from the tax registration details reported in the invoice. The 10-digit Tax Identification Number (TIN) forms the basis of the Peppol Participant Identifier, while the seller’s tax identification field depends on its VAT status: VAT-registered sellers use their 15-digit VAT TRN, and other sellers use their TIN. A Corporate Tax TRN cannot be used in the seller’s VAT identifier field. The Guidelines also stress that the various buyer identification fields serve different purposes and are not interchangeable.
Invoice Classification and Cross-Border Supplies
Code 380 applies to UAE Tax Invoices, while Code 480 is reserved for invoices relating exclusively to supplies outside the scope of UAE VAT. Code 480 must not be used for exempt or zero-rated supplies, which remain within the VAT framework.
Goods supplied directly from one location outside the UAE to another, without entering the country, are now classified as out of scope. This classification is limited to that specific scenario. A foreign buyer alone also does not make a transaction an export, as the nature of the supply and the applicable VAT rules must be considered.
Advance Payments
Where a Tax Invoice has already been issued for an advance, the final Electronic Invoice must cover only the remaining balance and reference the earlier invoice. The advance should be allocated to the invoice lines it relates to, or, if it covers the whole transaction, according to a reasonable method agreed by the parties. The allocation cannot change the VAT treatment of the underlying supplies.
Healthcare and Insurance Claims
When a hospital provides healthcare services to an individual patient and an insurer settles all or part of the bill, the patient remains the recipient of the supply. Payment by the insurer does not, on its own, create a B2B transaction. The insurer is treated as the buyer only when it receives a separate in-scope supply in its own capacity.
Newly Established Businesses
Persons established within the mandatory scope must appoint an ASP and complete onboarding before issuing their first invoice, regardless of their date of establishment. Any invoice they issue must be an Electronic Invoice.
Data Storage
Version 1.1 allowed records to be kept irrespective of the geographic location of servers, databases or cloud solutions. Version 2.0 removes that statement, together with the reference to storage “within the State.” The Guidelines now require only that records are kept for the statutory period, remain accessible and can be promptly provided to the FTA in a complete and readable form. Storage may still be delegated to an ASP by contract, but the Person remains responsible for retention.
VAT Groups
Under Ministerial Decision No. 197 of 2026, transactions between members of the same VAT group are excluded from mandatory e-invoicing for a transitional period from January 1, 2027, to December 31, 2028.
There’s more to know about e-invoicing in the United Arab Emirates – explore the new and upcoming regulations.
