Expert Answers to Your Questions: GCC E-Invoicing Roadmap

Published 20 Jul 2026
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For multinational companies operating across the GCC, e-invoicing compliance is turning into a fragmented puzzle. Saudi Arabia's ZATCA framework is already mature, Oman is advancing rapidly under the Oman Tax Authority in line with Oman Vision 2040, and the UAE is finalizing the legislative details of its own mandate.

During our on-demand webinar GCC E-Invoicing Roadmap: Navigating Mandates in KSA, the UAE, and Oman, Jakub Krawczyk, Senior Legal Compliance Expert at Comarch, and Nishi Jabeen, Tax Technology Lead at Alvarez & Marsal, compared the region’s mandate structures, scope, and timelines side by side. The session generated a wide range of questions, which we’ve compiled and answered below.

1. What e-invoicing software must hotels with revenues under 50M implement for property management by March 31, 2027? Is integration with the FTA Portal mandatory?

Under Ministerial Decision No. 244 of 2025, any business (including a hotel or property management company) with an annual revenue of less than AED 50,000,000 falls under Phase 2 of the mandatory e-invoicing rollout. For these entities:

The deadline to officially select and appoint an Accredited Service Provider (ASP) is March 31, 2027.
The deadline to fully implement and go-live with the e-Invoicing System is July 1, 2027.

By these dates, you are required to obtain the services of an ASP that will be integrated with the e-invoicing system set up by MoF and FTA.

2. Are there any special rules for entities based in free zones (like harbors or airports)?

Yes, though these are technical adjustments rather than major exceptions to the overall system. In the UAE e-invoicing framework, any transaction involving a free zone entity must activate the free trade zone flag in the invoice file. Due to the technical nature of this topic, we recommend scheduling an exploratory call with our consultants.

3. How firm are the timelines? The UAE go-live has already slipped once, and much of the Oman schedule is “anticipated.” How should companies plan around confirmed vs. anticipated dates?

We are certain the UAE timelines are firm, as the MoF and FTA are very advanced in the system development.

4. Are non-established entities in scope for the UAE mandate?

Yes, non-established (non-resident) entities are within the scope of the UAE e-invoicing mandate if they conduct business in the UAE and make transactions subject to UAE tax laws.

5. What are the mandatory requirements for the PDF format of an e-invoice?

Under the UAE e-invoicing framework, there is no official or mandatory visual PDF layout prescribed by the Ministry of Finance (MoF) or the Federal Tax Authority (FTA). The legal original is strictly XML. The legally binding e-invoice is exclusively the structured electronic data payload in PINT-AE (UBL 2.1) XML format.

6. As an unincorporated joint venture (JV) in the UAE with valid VAT Corporate Tax TRNs, will I be required to comply with the UAE e-invoicing mandates?

While the provided guidelines and legislation do not explicitly address the specific term “unincorporated joint venture” (JV), you will likely be liable to comply with the UAE e-invoicing mandates based on your active tax registrations. Under the regulatory framework, any entity conducting business in the UAE that is registered for VAT or Corporate Tax falls within the scope of the system.

7. What happens if a company’s ERP upgrade is still in progress by January 2027? Will there be a temporary option to process e-invoices outside ERPs, or will all e-invoicing be required to be processed through an ERP-integrated solution?

Companies undergoing digital transformation are not legally required to have a fully integrated, automated ERP-to-ASP solution in place by the January 1, 2027, Phase 1 deadline. For ERP systems that are not yet upgraded or capable of direct system-to-system transmission, businesses can utilize a non-integrated Web EDI or Web Portal provided by the ASP.

8. Can countries actually enforce cross-border e-invoicing, or do these mandates strictly apply to domestic invoice flows only?

While it is technically true that a country cannot enforce its local technical specifications (such as unique database structures or data dictionaries) on foreign vendors residing outside its legal jurisdiction, the belief that countries only mandate domestic e-invoice flows is not entirely accurate. In the UAE, outbound export transactions are strictly in scope under the e-invoicing mandate. If a UAE-based supplier sells goods or services to an international buyer, they must follow highly regulated procedures depending on the buyer’s technical capabilities.

9. How will e-invoicing work for the construction company, where it can take 3 to 4 months for a main contractor to certify a progress claim before an invoice is generated?

Be advised – this is a strictly tax-related topic, and Comarch is not a tax advisory company. For binding analysis, please reach out to your licensed tax advisor.

The Federal Tax Authority (FTA) has clarified that the e-invoicing process begins once the invoice is issued. Draft claims, estimated calculations, or non-certified valuation requests do not enter the e-invoicing network or trigger government tax reporting to Corner 5.

In practice, this means that:

Senders can continue to exchange draft progress sheets or PDF/paper application claims directly with the contractor outside the network.
Once the main contractor evaluates and issues a certified Payment Certificate, the final legal tax invoice is generated within the ERP (Corner 1).
Senders must transmit this finalized, certified invoice through the Accredited Service Provider (ASP/Corner 2) within 14 days from the date of the business transaction (which, under continuous supply VAT rules, aligns with the milestone certification/payment trigger).

10. Will a UAE branch of a foreign entity with minimal business activities be subject to the e-invoicing obligation? Is the threshold based on the branch’s turnover or the entire group’s turnover?

Yes, the UAE branch of a foreign entity will be covered under the e-invoicing mandate, regardless of how minimal its business activities are.

The UAE electronic invoicing system applies an exceptionally broad scope of application:

E-invoicing will be mandatory for any person conducting business in the UAE, in respect of every business transaction, regardless of whether they are established in the UAE.
All persons who conduct a business transaction in the UAE, regardless of their VAT registration status, are subject to electronic invoicing.
The only case in which registration may not be required immediately is when the business is entirely dormant and has no inbound or outbound transactions. In such cases, the authorities defer strictly to “applicable laws and legislation”.
There is no minimum transaction volume or minimum turnover below which active business operations are completely exempt.

11. What is the scope of the UAE e-invoicing mandate? Is it domestic invoices only, or are international (intercompany) invoices in scope of the current mandate?

At an executive level, the material scope of the mandate is defined as follows:

In-Scope Transactions: All domestic and outbound cross-border B2B and B2G transactions.
Out-of-Scope Transactions: B2C transactions, purely inbound cross-border imports (where the UAE buyer accounts for VAT under the reverse charge mechanism), and non-commercial, sovereign government activities.
Specific Exclusions: VAT-exempt financial services and international airline passenger transport (where electronic tickets or electronic miscellaneous documents are issued) are excluded. Additionally, international airline cargo transport (under airway bills) is granted a temporary 24-month exclusion.
VAT Group Treatment: Intra-group transactions are technically in-scope but are granted a temporary 24-month implementation grace period commencing January 1, 2027.

Have more questions or need help navigating varying regional compliance laws across the MEA region? Reach out to our team