Introduction
The United Arab Emirates (UAE) is advancing towards digitization by adopting e-invoicing, a trend gaining momentum worldwide. Taking cues from the Kingdom of Saudi Arabia (KSA), the UAE government is committed to optimizing invoicing procedures and refining financial transaction management for businesses and public entities nationwide.
The e-invoicing landscape in the UAE is evolving, with a strong focus on digital transactions and paperless processes. This initiative aims to modernize invoicing procedures nationwide, simplify and automate the filing of tax returns, improve tax compliance, and reduce instances of tax evasion. This effort reflects the UAE’s commitment to innovation and efficiency in financial operations.
Initiation of E-invoicing in the UAE: An Overview
The United Arab Emirates (UAE) embraced VAT in 2018, drawing inspiration from Europe’s taxation system. This move naturally triggers the planned digitization of taxpayers’ transactions with public entities, phasing out paper documentation. Bolstered by a fully digital public procurement platform (DPP) facilitating B2G contract processes, this digitization drive aims to bolster efficiency and transparency.
Following the VAT law, the UAE’s Federal Tax Authority (FTA) acknowledges digital or electronic invoicing as a valid modality for generating and utilizing “invoices” or “Fatoorah.” Supported by “Federal Law No. 1 of 2006 on Electronic Commerce and Transactions,” electronic records, documents, and signatures are afforded legal recognition. This law establishes uniform standards for authenticating all electronic communications, including electronic invoicing, through electronic signatures, ensuring their validity.
E-invoice exchanges between businesses are already viable with mutual consent in the realm of electronic invoicing. Yet, to further streamline operations, the impending requirement of mandatory e-invoicing for the B2B sector stands as the logical progression. The UAE’s Ministry of Finance (MOF) unveiled a roadmap on July 11, 2023, outlining the enforcement of B2B e-invoicing from July 2025 onwards.
E-invoicing Implementation Phase
The UAE government has disclosed its plan to implement e-invoicing, initially focusing on B2B (business-to-business) and B2G (business-to-government) transactions and later expanding it to B2C (business-to-customer) Transactions. The implementation timelines are as follows:
| Time | Particulars |
| Q3 2024 | Developing requirements and procedures for accredited service providers’ certification and development of UAE data dictionary. |
| Q2 2025 | Release of e-invoicing legislation, establishing the legal framework. Taxpayers can select ASP and exchange e-invoices under the 4-corner model before they become subject to mandatory requirements. |
| December 2025 | Announcement of the rollout strategy based on taxpayers’ turnover in a phased manner. |
| July 2026 | Implementation of Phase-1 based on the size of the taxpayer. At the same time, taxpayers who do not fall under the mandatory phase can follow e-invoicing regulations voluntarily. |
E-invoicing Framework
The UAE government will establish its own PEPPOL Authority by adopting the POPPOL PINT format. This initiative mirrors the practices of nations like Singapore, Malaysia, and Australia, aiming to streamline cross-border trade and adhere to international e-invoicing protocols.
The CTC e-invoicing framework was introduced on 14th February 2024. The UAE will adopt a “Decentralized CTC and Exchange Model” (DCTCE), which initially operates on a 4-corner model and later transitions to a 5-corner model. This approach enables trading parties to exchange e-invoices directly without needing pre-clearance from the Ministry. The system will rely on the Peppol PINT format and Accredited Service Providers (ASPs), also known as e-invoicing agents.
These ASPs will validate basic invoice information and forward it to the customers through their agents. Additionally, the agents will send the invoices to the Federal Tax Authority (FTA), serving as the fifth corner in the model. Notably, there will be no requirement for pre-clearance from the FTA, making the invoicing process more efficient and aligned with international standards.
Further, there will not be a portal for SMEs; rather, as part of the ASP accreditation criteria, the authority is considering limited free-of-charge ASP service for SMEs.
Compliance Requirements
E-invoicing in UAE is gradually evolving. However, the UAE government has yet to announce detailed regulatory requirements for compliance with e-invoicing. But as the UAE is inspired by the KSA e-invoicing implementation, based on, we can consider the following criteria that the UAE authority may impose:
- Participation in the initial voluntary phase from July 2025.
- Generation of QR code-embedded B2B e-invoices and B2C e-notes (not required for VAT regulations) using an “E-invoice Generation solution” approved by the tax authority.
- UBL-XML or PDF with embedded XML formats are used for these transactions.
- Integration with tax authority validation platform as a part of CTC for basic check and digital signature of customer approval.
Further, according to UAE VAT law, all VAT-registered sellers must issue tax invoices for transactions exceeding AED 10,000. These invoices must comply with specific formats and standards to ensure readability, authenticity, and adherence to VAT regulations.
Outlined rules include:
- Compliance with E-Invoices:
- VAT-registered businesses must use electronic documents in the same format for generating, sending, or receiving e-invoices.
- They must ensure the invoice content remains unchanged and relevant controls are in place.
- Integrity and Timestamping:
- Each e-invoice must have a timestamp to ensure it has not been altered since creation.
- The e-invoice should be ready for online viewing and printing.
- Readability and Access:
- Electronic invoices should be in an easily readable format.
- Secure online access must be provided for downloading e-invoices as PDFs.
- Authenticity and Verification:
- The origin of the electronic invoice must be verifiable.
- Each e-invoice should have an original file that can be downloaded anytime.
- A certified e-signature must authenticate the issuer and verify the data.
For UAE government entities, the federal law allows:
- Electronic Document Management:
- Electronic creation, filing, and preservation of documents are accepted.
- Electronic Transactions:
- Electronic records can be used to issue licenses and permits.
- Electronic payments and fees are accepted.
- Tenders and bids can be submitted electronically in the public sector.
Tax invoices are recognized under Federal Legislative Decree No. 8 of 2017 on VAT, whether printed or electronic.
Right Choice of e-invoicing Tool and e-invoicing provider
Choosing the right e-invoicing tool and provider is crucial for compliance and efficiency in the UAE’s evolving VAT landscape. An ideal e-invoicing tool should offer robust features like seamless integration with existing ERPs and tax authority platforms, user-friendly interfaces, and secure data handling.
The E-invoicing tool should also provide real-time validation, reporting, and automated error-checking to ensure compliance with e-invoicing regulations. Additionally, features like bulk e-invoice generation, scalability, availability reliability, secure digital signatures, and easy access to electronic records are essential.
As per UAE’s requirement, an ideal e-invoicing provider must be a PEPPOL-approved accredited service provider, which ensures the seamless transfer of e-invoices among tax authorities and trading parties.
The UAE mainly adopts its e-invoicing system based on the successful model implemented in Saudi Arabia, so selecting a provider with extensive experience in the KSA market is advantageous.
Cygnet, for instance, is an experienced provider in the KSA e-invoicing sector, making it an ideal choice. Their proven track record and familiarity with regional compliance requirements can ensure a smooth transition and reliable implementation of the e-invoicing system in the UAE. By leveraging such expert solutions, businesses can stay ahead of the curve, ensuring they are well-prepared for the future of digital transactions.
Conclusion
As the UAE advances towards a comprehensive e-invoicing system, businesses must be ready to adapt to this significant shift in financial transaction management. Implementing e-invoicing will ensure compliance with new regulations and enhance invoicing processes’ efficiency, transparency, and accuracy.
This initiative is a crucial step towards modernizing financial operations, simplifying tax return filings, improving tax compliance, and reducing instances of tax evasion. By embracing e-invoicing, businesses can streamline their operations and contribute to a more efficient and transparent economic environment in the UAE.
Staying informed and prepared for these changes will enable businesses to navigate this transition smoothly and effectively, ensuring they remain compliant and competitive in the evolving digital landscape.
Komal Vithalani
Content Writer
Komal Vithalani, a Chartered Accountant and Commerce graduate, is a dedicated professional committed to delivering value with years of expertise in navigating the complexities of indirect tax laws. Her practical excellence includes managing perplexed litigations, dispensing tactical tax advice, conducting thorough compliance checks, supervising audits, and crafting articulate and insightful content. At Cygnet, Komal seamlessly blends her profound understanding of tax regulations with cutting-edge tax technology. Leveraging her competence, she adeptly transforms complex tax tech jargon into concise, impactful, and engaging content. This not only aids readers in comprehending tax-related topics with enlightening clarity but also ensures the delivery of narratives that resonate broadly.
