UAE Publishes Version 2.0 of E-Invoicing Guidelines

he UAE has published updated e-invoicing guidance covering practical questions on buyer identification, advance payments and transactions with customers that have not yet joined the system.

Version 2.0 of the Ministry of Finance’s Electronic Invoicing Guidelines, dated 26 October, comes as businesses with annual revenues of AED 50 million or more prepare to implement e-invoicing from 1 January 2027.

The updated guidance sets out how suppliers should handle transactions during the phased rollout, when some customers may not yet have implemented e-invoicing.

Highlights from the guidelines:

• Electronic Invoicing is mandatory for any Person conducting Business in the UAE, regardless of their VAT registration status, unless specifically excluded as per Article 4 of MD No. 243 of 2025 and its amendments.
• The timeline for implementing Electronic Invoicing is as per the phased implementation plan detailed in MD No. 244 of 2025 and its amendments. 
• Your Participant Identifier for Electronic Invoicing will be your Tax Identification Number (“TIN”).
• Taxpayers that have registered with the Federal Tax Authority (“FTA”) for any Tax type, will have been assigned a TIN already as part of this registration process. The TIN is the first 10 digits of the TRN that you have been issued.
• A Person that is within the scope of Electronic Invoicing but is not required to register for any Tax type, must register with the FTA to obtain their TIN.

Provider deadline is 30 October

Separately, the Federal Tax Authority has reminded businesses in the first phase that they must appoint an accredited service provider by 30 October 2026.

In its announcement on 25 October, the authority said an administrative penalty of AED 5,000 for each month or part-month of delay applies to failure to implement the system, including failure to appoint a provider by the prescribed deadline.

Businesses with annual revenues below AED 50 million have until 31 March 2027 to appoint a provider and 1 July 2027 to implement e-invoicing.

Download our UAE E-Invoicing Buyer Guide

Source: Ministry of Finance

This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.