What changed in UAE e-invoicing: a dated log

What is the latest change?

The newest documents are two dated 28 October 2026: version 1.1 of the Electronic Invoice Mandatory Field Requirements and version 1.1 of the Ministry's Considerations for selecting an Accredited Service Provider. Version 2.0 of the UAE Electronic Invoicing Guidelines is dated 26 October 2026. When we compared the Ministry's e-invoicing page on 4 November 2026, it listed nothing newer.

The Guidelines V2.0 refer to MD 168/2026 for accreditation (§3) and to CD 173/2026 for penalties (§11.2). They also explain two items of MD 197/2026 in detail, the tax-group grace period (§6.3.2) and the financial-services exclusion (§7.3), both covered below.

Sources: ^{[7][8][6][12]}

What changed in 2026?

Cabinet Decision No. 173 of 2026 sets the e-invoicing penalties and repeals Cabinet Decision No. 106 of 2025 (Art. 4). It comes into force the day after its publication in the Official Gazette (Art. 5). The Arabic text on the Ministry's site is signed and dated 6 October 2026; neither PDF gives the Gazette date, and we have not confirmed it yet. Not implementing e-invoicing, including not appointing an ASP, or a recipient not keeping up its obligations: AED 5,000, plus AED 5,000 for each month or part of a month it continues, capped at AED 50,000 in any 12 consecutive months. Not issuing and transmitting an e-invoice or an electronic credit note: AED 100 each, up to AED 5,000 a calendar month. Not telling your ASP about changes to your data registered with the FTA: AED 250 a day, up to AED 5,000 a calendar month. Voluntary users are outside it (Art. 2(2)), and a person who is both issuer and recipient pays one penalty for the same violation (Art. 3(2)). The penalties page explains each row.

Ministerial Decision No. 197 of 2026, in force from 1 October 2026, amended MD 243/2025. It replaced the exclusions in Article 4: government transactions in a sovereign capacity that do not compete with the private sector; international airline passenger transport with an electronic ticket, and ancillary services on an Electronic Miscellaneous Document; international air cargo with an airway bill, for 24 months; financial services that are VAT-exempt or zero-rated under Article 42 of the VAT Executive Regulation; and, new, transactions between members of the same tax group for 24 months from 1 January 2027. The Guidelines V2.0 call the tax-group item a grace period that changes the timing only and does not take those transactions out of scope (§6.3.2), and they exclude zero-rated financial services only where the service would be exempt for a resident customer (§7.3).

MD 197/2026 also changed "14 days" to "14 Business Days" in Article 6(5), which remains "subject to Clause 4" of the same article; replaced Article 11, which no longer says "within the State" and now asks you to keep e-invoices for the Tax Procedures Law period and produce them to the FTA on request; deleted the definition of a system failure; and repealed Article 12, the duty to notify the FTA of a system failure within 2 business days.

Ministerial Decision No. 168 of 2026, also in force from 1 October 2026 (Art. 20), sets the eligibility criteria and accreditation procedure for ASPs and repealed MD 64/2025 and its amendments (Art. 18). Providers pre-approved under MD 64 had 30 days to complete accreditation, or lose the pre-approval (Art. 19). An accreditation lasts two years (Art. 13(3)), and each ASP declares that it is committed to giving every end user 100 free e-invoice exchange and reporting services a year (Art. 9(4)). More on accredited service providers.

Ministerial Decision No. 66 of 2026, posted in May 2026, replaced Article 5(1)(a) of MD 244/2025: businesses with revenue of AED 50 million or more had to appoint an ASP by 30 October 2026 instead of 31 July 2026, and must still implement e-invoicing by 1 January 2027 (Art. 1). It comes into force the day after its Gazette publication (Art. 3). The other groups kept their dates: under AED 50 million, appoint by 31 March 2027 and implement by 1 July 2027; government entities, by 31 March 2027 and 1 October 2027. See the deadlines for every group.

Ministerial Decision No. 56 of 2026, posted in May 2026, amended the ASP eligibility rules of MD 64/2025: a provider may use a product owned by a third party and outsource parts of its service while keeping full responsibility, and the experience requirement is met when the product has been in operation for at least two years (Art. 1 and 2). MD 168/2026 carried both rules into its Article 4(2) and repealed MD 64 with its amendments.

Sources: ^{[1][2][6][3][4][5]}

What was set in 2025?

Ministerial Decisions No. 243 and 244 of 2025, signed on 12 and 17 September 2025 (the dates are in the Arabic texts of MD 243 and MD 244), set up the system. MD 243 covers who is in scope (any person doing business in the UAE, Art. 3), the exclusions (Art. 4), the appointment of an ASP by issuer and recipient (Art. 5), the exchange and reporting duty (Art. 6) and storage (Art. 11). MD 244 sets the pilot and voluntary use from 1 July 2026 (Art. 3 and 4), the phases by revenue (Art. 5(1)), and keeps business-to-consumer transactions outside until the Minister decides (Art. 5(2)).

Ministerial Decision No. 64 of 2025 set the ASP eligibility criteria and accreditation procedure, with a pre-approval stage. MD 168/2026 repealed it from 1 October 2026 (Art. 18 to 20).

Cabinet Decision No. 106 of 2025, posted in December 2025, was the earlier penalties decision, with six violations. Two of them, AED 1,000 a day for an issuer or a recipient not notifying the FTA of a system failure, have no counterpart in CD 173/2026. The fine for not telling your ASP about data changes went from AED 1,000 a day to AED 250 a day, now capped at AED 5,000 a calendar month, and not implementing e-invoicing cost AED 5,000 for each month or part of a month, with no cap in the table. CD 173/2026 repeals it (Art. 4).

Sources: ^{[9][10][3][11][1]}

How is this log kept current?

We compare this log with the Ministry of Finance e-invoicing page, which the Ministry calls the only official source of information on the introduction of e-invoicing in the UAE, and add an entry only after reading the official text. Dates follow one rule: a date written in the text, such as an effective date, a document date or a signing date in the English or the Arabic version, is shown as it is; where neither version gives the signing date, we show the month the Ministry posted the file, marked "posted". A signing date is not the date of publication in the Official Gazette. The "Last checked" date at the top is the day of the last comparison, and we repeat it every month. If you see a change we have not logged, tell us.

Sources: ^[12]

Where Vattora fits, and when you do not need it

Vattora is connector software, not an ASP. When a change touches invoice data, such as a new version of the mandatory fields, the checks Vattora runs on each invoice before it goes to your ASP have to follow it. You do not need Vattora to follow these changes: every official text above is public and linked.