Who Must Comply With the UAE E-Invoicing Mandate?

The UAE e-invoicing mandate applies to any person doing business in the UAE for business-to-business (B2B) and business-to-government (B2G) transactions, whether or not it is registered for VAT, and free zone companies are included. Your revenue only decides when you must start, not whether. Sales to consumers (B2C) and a short list of transactions are excluded for now.

Key facts

• Who: any person conducting business in the UAE, for every B2B and B2G transaction (Ministerial Decision No. 243 of 2025).
• VAT registration doesn't matter: non-registered businesses issue commercial e-invoices within 14 days of the transaction.
• AED 50 million of revenue, from your most recent financial statements, decides your phase: appoint an ASP by 30 October 2026 or by 31 March 2027.
• Excluded for now: B2C sales (until a ministerial decision, no date announced), sovereign government activities, airline e-tickets and EMDs, air cargo airway bills (24 months), VAT-exempt or zero-rated financial services.
• VAT groups: transactions between members get a 24-month grace period from 1 January 2027.

Is e-invoicing mandatory in the UAE?

Before your phase date, e-invoicing is voluntary and penalty-free; from that date, the fines of Cabinet Decision No. 106 of 2025 apply. See the UAE e-invoicing deadlines and timeline for every date.

Who is covered by the UAE e-invoicing mandate?

Not sure what counts as an e-invoice? Read what e-invoicing means in the UAE.

How is the AED 50 million threshold calculated?

The decision says "equal to or exceeds AED 50,000,000", so exactly AED 50 million puts you in the first phase, even though a Ministry presentation uses the word "exceeding".

Groups of companies: the Ministry of Finance FAQ declines to say whether the test applies company by company or to the whole group, and refers businesses to their auditors. If your group is near the line, get written advice from your auditor or an FTA-registered tax agent, and plan for the earlier date meanwhile.

Are free zone companies covered?

Special VAT or Corporate Tax treatment in some free zones does not change this. If you invoice free zone customers, check that your software captures the extra fields.

Do businesses that are not VAT-registered have to comply?

• The 14 days run from the "date of business transaction": the earlier of the transaction date and the date payment is received.
• Identification: businesses are identified on the network by their tax identification number (TIN), the first 10 digits of the TRN. Persons with no tax registration must register with the FTA to obtain one.
• Self-billing is only allowed when both parties are VAT registrants, so it is not open to a non-registered supplier.

Which transactions and businesses are excluded?

Under Article 4, the airway-bill exclusion runs from when the system becomes effective; the financial services are those exempt or zero-rated under Article 42 of the VAT Executive Regulation; and the Minister may exclude other transactions (no such decision found as of 10 October 2026).

Sales to consumers are excluded by Article 5(2) of Ministerial Decision No. 244 of 2025 "until such time determined by a decision issued by the Minister", and the Ministry's FAQ confirms the scope currently covers only B2B and B2G. No date has been announced. If you sell to both consumers and businesses, your business sales are in scope.

What if your business only receives invoices?

A holding company with only passive income has nothing to invoice, but its UAE suppliers, such as auditors and lawyers, will send it e-invoices; a consumer-only retailer still buys stock from UAE businesses. The FAQ covers B2C-only businesses at or above AED 50 million; if yours is smaller, check your position with an FTA-registered tax agent. One ASP handles both sending and receiving: when you compare accredited ASPs, ask how the 100 free e-invoice services per year that each must give every customer (Ministerial Decision No. 168 of 2026) apply to invoices you receive.

How are VAT groups and company groups treated?

The grace period (Guidelines version 1.1, §6.3.2.1) covers only invoices between members of the same VAT group; sales to outside customers follow the member's normal phase. On transactions between branches of a single legal entity, the Ministry declines to advise and refers businesses to their advisers or to a clarification request to the FTA.

What about new businesses and non-resident companies?

The texts we checked set no separate timetable for new businesses, so ask a tax agent how the rule applies to your start date. For exports, your ASP still reports the tax data to the FTA, using a predefined endpoint.

Does the mandate apply to you? A quick check

1. Do you conduct business in the UAE, or must you issue UAE tax invoices? If neither, the mandate doesn't apply. If either, continue.
2. Do you sell to other businesses or to government entities? If you sell only to consumers, you don't issue e-invoices for those sales, but you will probably need an ASP to receive your suppliers' e-invoices.
3. Are all your sales in an excluded category? If so, those transactions are outside the system; any other B2B or B2G sales remain in scope.
4. Was your revenue in your latest financial statements AED 50 million or more? If yes, appoint an ASP by 30 October 2026 and go live on 1 January 2027. If no, appoint one by 31 March 2027 and go live on 1 July 2027. Government entities: 31 March 2027 and 1 October 2027.
5. Are you in a VAT group? Intra-group invoices get the 24-month grace period; your other sales follow your phase.

Next, take the e-invoicing readiness check for your personal dates, or estimate what a delay could cost with the penalty calculator and our guide to UAE e-invoicing penalties. Then see what your invoices must contain in the UAE e-invoicing requirements, compare tools in our e-invoicing software comparison and follow the implementation checklist. Note that Small Business Relief under Corporate Tax does not exempt you.

More in the UAE e-invoicing guide, the e-invoicing FAQ and our full list of e-invoicing guides. This page explains the official texts; it is not tax or legal advice, so check edge cases with an FTA-registered tax agent.