E-invoicing for AED 50m+ firms: the 2027 go-live

The short answer

If your business has annual revenue of AED 50 million or more, you must appoint an Accredited Service Provider (ASP) by 30 October 2026 and issue your business-to-business and business-to-government invoices as e-invoices from 1 January 2027. The appointment date was moved from 31 July 2026 in May 2026, but the go-live date did not move. Businesses below AED 50 million appoint by 31 March 2027 and go live on 1 July 2027. Government entities appoint by 31 March 2027 and go live on 1 October 2027.

On 19 October 2026 the Ministry of Finance announced further changes. Transactions between members of the same VAT tax group are excluded for 24 months from 1 January 2027. The requirement to store e-invoice data inside the UAE has been removed. So has the duty to notify the FTA of a system failure within two business days.

What an e-invoice is, and what it is not

An e-invoice is structured data exchanged between the supplier's ASP and the customer's ASP, in the Peppol PINT format adapted for the UAE, and reported to the FTA. The FTA is explicit that a PDF, a Word file, an image, a scan or an email is not an e-invoice. Both sides need an ASP: the supplier to send, and the customer to receive.

The legal base is Ministerial Decisions No. 243 and 244 of 2025 (the system and the phased timeline), Ministerial Decision No. 64 of 2025 (ASP accreditation), Cabinet Decision No. 106 of 2025 (penalties) and Cabinet Decision No. 100 of 2025 (the changes to tax invoices and credit notes).

What is in scope, and what is not

• In scope: business-to-business and business-to-government supplies by VAT-registered and other in-scope businesses, including zero-rated supplies such as exports.
• Out of scope: business-to-consumer sales.
• Excluded by Ministerial Decision No. 243 of 2025: sovereign government activities that do not compete with the private sector; international passenger flights on e-tickets; international air cargo on an airway bill (for 24 months); and exempt or zero-rated financial services.
• Excluded for 24 months from 1 January 2027: transactions between members of the same VAT tax group (announced on 19 October 2026). Advisers are already asking how this works for group members that also sell to outside customers, so expect further guidance.

What changes in your invoicing rules

Once you issue e-invoices, Article 59(16) of the VAT Executive Regulation switches off the simplified tax invoice, the relief from invoicing wholly zero-rated supplies, and the FTA's power to waive invoice particulars. Article 60(8) removes the requirement for an electronic credit note to show the original value, the correct value and the difference. Since the VAT Law amendments of 2024, input tax recovery also depends on holding the tax invoice in line with the e-invoicing system where one is required.

Penalties under Cabinet Decision No. 106 of 2025

Example: a company goes live three months late and issues 400 invoices a month outside the system. That is 3 × AED 5,000 = AED 15,000 for implementation, plus AED 100 × 400 = AED 40,000 a month for the invoices, capped at AED 5,000 a month, so 3 × AED 5,000 = AED 15,000. Total: AED 30,000. The bigger cost is commercial: customers who cannot recover input VAT on a non-compliant invoice will hold payment until it is reissued.

• Not implementing the system, or not appointing an ASP, by your deadline: AED 5,000 for each month of non-compliance.
• An e-invoice or e-credit note not issued or sent in the required form or time: AED 100 each, capped at AED 5,000 a month for each category.
• Registration or master data changes not reported to your ASP on time: AED 1,000 a day.
• System failure not notified to the FTA: AED 1,000 a day. The October 2026 amendment removed the two-business-day notification duty, so confirm how this penalty applies once the amended text is published.

Readiness list for the next ten weeks

• Sign the ASP contract before 30 October 2026, and get its onboarding and testing slots in writing.
• Clean the customer and supplier master data: legal names, TRNs and Peppol identifiers. Bad master data is the first thing an ASP will reject.
• Map your ERP invoice and credit note fields to the Ministry's mandatory e-invoice fields, published in February 2026.
• Decide the process for credit notes, self-billing, and invoices issued by agents on behalf of principals.
• List which entities are in your VAT tax group, which flows are intra-group (excluded until the end of 2028) and which are not.
• Plan the inbound side: your suppliers' e-invoices will arrive through your ASP, so accounts payable intake must read them from there.
• Run a parallel month before go-live, and reconcile e-invoices reported against the VAT return.

How Hysaab applies this

Hysaab is not an Accredited Service Provider. It works upstream of one: it tests every invoice and credit note against the Article 59 and 60 fields, checks the buyer and supplier TRNs against your records, and flags a TRN that changes between invoices. That is the master data an ASP will reject if it is wrong. Use the e-invoicing deadline checker to confirm your own dates.

Questions people actually ask

Keep reading

• Tool: UAE e-invoicing deadline checker
• Guide: Simplified vs full tax invoice: the AED 10,000 rule
• Guide: What makes a valid UAE tax invoice — the Article 59 checklist
• Guide: UAE tax credit notes: when, what and which return
• Guide: VAT tax groups in the UAE: when grouping pays