The UAE’s New e‑Invoicing System: A Guide for Importers and Exporters
Transport & Insurance / UAE
The system is based on the international Peppol Interoperability Framework, and UAE-based exporters must ensure all e‑invoices are compliant and reported to the Federal Tax Authority, regardless of the buyer's location.
Law Update: Issue 379 – Saudi Arabia
Sakher AlaqailehSenior Counsel,Transport & Insurance
Bassam Al-AzzehSenior Associate,Transport & Insurance
The United Arab Emirates (UAE) is set to introduce a remarkable reform in the way businesses issue and manage invoices. Beginning in July 2026, the country will implement a new electronic invoicing (e‑invoicing) system, which will be rolled out in phases. This system will apply to all business-to-business (B2B) and business-to-government (B2G) transactions, including those involving importers and exporters.
The framework for this initiative is outlined in Ministerial Decision No. 64 of 2025, issued by the Ministry of Finance, which sets out the eligibility criteria and accreditation process for service providers participating in the e‑invoicing system. This article outlines the key components of the UAE’s e‑invoicing system and highlights what importers and exporters should know to prepare and ensure compliance.
The UAE’s e‑invoicing system is built on a secure digital infrastructure that enables the electronic exchange of invoices between suppliers (such as exporters) and buyers (such as importers) through UAE-accredited Service Providers (ASPs). Each invoice is not only delivered to the buyer but also automatically reported to the Federal Tax Authority (FTA) for compliance and record-keeping.
Although the official list of accredited ASPs is yet to be announced, Ministerial Decision No. 64 of 2025 outlines the eligibility criteria for ASP accreditation. According to the decision:
ASPs must be authorized by OpenPeppol, and
They must be technically capable of accessing and operating within the Peppol Interoperability Framework.
For context, OpenPeppol is an international non-profit organization established in Belgium, responsible for developing and managing the Peppol network and ensuring interoperability between different service providers and platforms globally.
The UAE has formally adopted the Peppol Interoperability Framework as the foundation for its e‑invoicing system. This framework sets the technical and operational standards for exchanging electronic documents (such as e-invoices) across systems and borders. Under this framework, e‑invoicing services include the sending, receiving, and exchanging of:
Electronic Invoices,
Electronic Credit Notes, and
Any related invoicing documents.
The UAE e‑invoicing system does not impose its standards on foreign vendors and suppliers. Invoices received from abroad, even from Peppol-compliant jurisdictions, are not required to be reported through the UAE e‑Invoicing network. Therefore, UAE importers are not obligated to ensure that foreign suppliers use the UAE’s e‑invoicing standards, and there are no additional reporting requirements for such transactions.
When exporting goods out of the UAE, if the foreign buyer is registered on the Peppol network, the UAE exporter must send the invoice using the buyer’s electronic address (known as the Peppol endpoint).
However, if the foreign buyer is not registered on the Peppol network, the UAE exporter must use a dummy endpoint. In this case, the invoice will still be reported to the FTA in the UAE but will not be delivered via the Peppol network. The local exporter may then send the invoice to the buyer through traditional channels, such as email or courier service.
UAE exporters must ensure that all e-invoices generated for exports are compliant with the UAE PINT (Peppol International) framework and are reported to the FTA through their Accredited Service Provider, regardless of the buyer’s jurisdiction.
As of the current guidance provided by the UAE Ministry of Finance and Ministerial Decision No. 64 of 2025, overseas importers and exporters (non-resident businesses) are not required to register with a UAE-accredited Service Provider (ASP) unless they are VAT-registered in the UAE.
The below schedule outlines entities entitled to register in the UAE e‑Invoicing system:
Entity Type
UAE VAT Registered
E-Invoicing Registration Required?
Notes
UAE-based Importer
Yes
Not required
Not required to report foreign invoices through the e‑Invoicing system.
UAE-based Exporter
Required
Must register with a UAE-accredited ASP and report all export e‑invoices to the FTA.
Foreign Supplier to UAE (Exporter)
No
Not subject to UAE e‑invoicing requirements, even if from a Peppol-compliant country.
If they are VAT-registered in UAE, they must use a UAE-accredited ASP and comply with e‑invoicing rules.
Foreign Buyer (Importer from UAE)
Not applicable
No registration needed; invoice can be delivered via email depends.
UAE-based Business (B2B or B2G)
Must issue and report e‑invoices through ASP, including import to local from freezone, transfer within freezone and export transactions.
UAE-based Business (B2C only)
Not required (initially)
B2C is currently outside the first phase; expected in future phases.
Foreign Business (not VAT-registered)
Not entitled/required
Outside the scope of UAE’s e‑Invoicing system.
The UAE’s e‑Invoicing system will be introduced in phases, with businesses onboarded based on specific eligibility criteria. A testing period and a grace period will be provided to help businesses address any initial technical or operational issues. During the transition, companies may continue to use both traditional and electronic invoices.
However, once e‑invoicing becomes mandatory for a business, all in-scope transactions must be processed exclusively through the e‑invoicing network. Failure to issue a compliant invoice with the new e‑Invoicing system when making a taxable supply may result in a penalty of AED 2,500 per detected case.
The UAE’s new e‑invoicing system, in conclusion, represents a major step forward in digitizing tax compliance and streamlining cross-border trade. Importers and exporters must familiarize themselves with the system’s requirements, engage with Accredited Service Providers, and ensure their internal processes and systems are ready for integration. By learning how the new e-invoicing system works, businesses in the UAE can stay compliant, avoid disruptions, and benefit from the time and cost savings of using electronic invoices.
Our firm has extensive experience advising businesses on cross-border trade processes in the UAE and the wider GCC region. We support clients in understanding and implementing the UAE’s new e‑invoicing requirements, including onboarding with accredited service providers, reviewing contractual arrangements, and ensuring operational readiness.
With a presence across key jurisdictions in the Middle East and North Africa, and rights of audience before courts in Bahrain, Egypt, Iraq, Jordan, Kuwait, Morocco, Oman, Qatar, Saudi Arabia, and the UAE, we are well-positioned to assist clients with both local and multi-jurisdictional matters.
For further information,please contact Sakher Alaqaileh and Bassam Al-Azzeh.
Published in August 2025
