Who has to use e-invoicing in the UAE

Does e-invoicing apply to my business?

Yes, if you do business in the UAE. Ministerial Decision No. 243 of 2025 applies to any person conducting business in the State, for every business transaction, unless the person or the transaction is excluded under its Article 4 (MD 243/2025, Art. 3). The Ministry's Guidelines repeat that e-invoicing is mandatory regardless of VAT registration status, and regardless of whether the business is established in the UAE (Guidelines V2.0, §2 and §6).

The definitions are wide (MD 243/2025, Art. 1). A person is any natural or juridical person, so a sole trader or a freelancer counts as much as a company. Business is any activity conducted regularly, on an ongoing and independent basis, such as industrial, commercial, agricultural, professional, vocational, service or excavation activity, or anything related to the use of tangible or intangible property. A business transaction is any transaction conducted, in full or in part, in the course of that business.

Being in scope does not mean starting today; your phase sets the dates. With revenue of AED 50 million or more you implement by 1 January 2027, under AED 50 million by 1 July 2027, and government entities by 1 October 2027 (MD 244/2025, Art. 5(1), as amended by MD 66/2026, Art. 1). Revenue means the gross income of your most recent accounting period, from your financial statements or, where there are none, other documents the Federal Tax Authority accepts (MD 244/2025, Art. 1).

Sources: ^[1][5][3][4]

B2B, B2G and B2C: which sales are in scope today?

Sales to other businesses (B2B) and to government (B2G) are in scope. The Guidelines spell out that goods and services supplied to government entities, for example under contracts tendered on UAE government procurement portals, are subject to e-invoicing (Guidelines V2.0, §6.2). Government entities are in scope as sellers too, on their own dates (MD 244/2025, Art. 5(1)(c)), except for their sovereign activities (MD 243/2025, Art. 4(1)(a), as replaced by MD 197/2026).

Sales to consumers (B2C) are not, for now. MD 244/2025 keeps business-to-consumer transactions outside the system, and a person engaged only in such transactions is not subject to it, until the Minister decides otherwise (MD 244/2025, Art. 5(2)). A consumer here is a natural person who is not carrying on business (MD 244/2025, Art. 1). The Guidelines add that the same holds when a billing agent invoices or collects for such a sale (Guidelines V2.0, §6.2).

If you sell both ways, each sale follows its buyer. A trading company with a shop counter issues e-invoices for its sales to companies and to government, while its sales to consumers stay outside e-invoicing until the Minister decides.

Sources: ^[5][2][3]

What if we are not registered for VAT?

You are still in scope: VAT registration does not decide who e-invoices (Guidelines V2.0, §2; Mandatory Fields V1.1, §2). What changes is the document. A person that is not registered for VAT issues commercial invoices, not tax invoices, and under e-invoicing a PDF or paper commercial invoice must be replaced by an electronic one, exchanged and reported through the five-corner model (Guidelines V2.0, §10.2.1).

You also need a Tax Identification Number (TIN), because your Peppol Participant Identifier is 0235 followed by it. The Guidelines define the TIN as the first 10 digits of your TRN, and say that a person in scope that is not required to register for any tax must register with the Federal Tax Authority to get one (Guidelines V2.0, §2 and §3). The Mandatory Fields V1.1 word it around Corporate Tax: the TIN is the first 10 digits of a Corporate Tax TRN, and a person not required to register for Corporate Tax registers with the FTA to receive it (Mandatory Fields V1.1, §2). If you are unsure which applies to you, ask your ASP or the FTA.

Sources: ^[5][6]

Do government entities and their suppliers follow the same rules?

The rules are the same, but the dates differ, and government entities have one exclusion of their own. A Government Entity, as MD 243/2025 defines it, means ministries, government departments and agencies, authorities, and public institutions and bodies, federal or local, plus any entity the Cabinet treats as one for VAT purposes (MD 243/2025, Art. 1). Government entities have their own phase: appoint an ASP by 31 March 2027 and implement by 1 October 2027 (MD 244/2025, Art. 5(1)(c)).

Their transactions in a sovereign capacity that do not compete with the private sector are excluded, and all three conditions must be met (MD 243/2025, Art. 4(1)(a), as replaced by MD 197/2026; Guidelines V2.0, §7.1). The conditions are set out on the exclusions page.

A private company does not become a government entity by selling to government. Its own revenue sets its dates, under Article 5(1)(a) or (b) of MD 244/2025, and its sales to government are in scope (Guidelines V2.0, §6.2).

Sources: ^[1][3][2][5]

We are in a tax group: are transactions between members in scope?

Yes, with a grace period. MD 197/2026 lists business transactions between members of the same Tax Group, for 24 months starting 1 January 2027, among the excluded transactions (MD 243/2025, Art. 4(1)(f), as replaced by MD 197/2026). The Guidelines explain that this grace period affects the timing only: intra-group transactions stay within the scope of the system, and when the period ends the rules apply to them in full, under the applicable phase (Guidelines V2.0, §6.3.2).

The grace period covers transactions between members only; each member's sales to customers outside the group follow the normal dates (Guidelines V2.0, §6.3.2). Inside a group, each member uses its own TIN, the first 10 digits of its own TRN, not the TIN of the group's representative member (Guidelines V2.0, §2; Mandatory Fields V1.1, §2). More on the window on the exclusions page.

Sources: ^[2][5][6]

Do exempt and out-of-scope sales need e-invoices?

Yes, unless the transaction itself is on the exclusion list. A sale that needs no tax invoice under the VAT law, such as an exempt or out-of-scope supply, is made on a commercial invoice, and the Guidelines say traditional PDF or paper commercial invoices must be replaced by e-invoices exchanged and reported through the five-corner model (Guidelines V2.0, §10.2.1). An electronic tax invoice may also carry non-taxable lines next to taxable ones, with no separate e-invoice for them (Guidelines V2.0, §10.2.2).

The one place where an exemption takes a sale out is financial services: those exempt from VAT under Article 42 of the VAT Executive Regulation are an excluded transaction (MD 243/2025, Art. 4(1)(e), as replaced by MD 197/2026). No other exempt supply is on the list, so a VAT exemption alone does not take a sale out of e-invoicing.

Sources: ^[5][2]

Is an investment holding company in scope?

Not if its revenue comes only from passive income and it has no business transactions; the Guidelines place such a company outside the scope. Recharges change that. If the holding company recharges management costs or other operational costs to third parties or related parties, those recharges are business transactions, and it must register for e-invoicing and issue e-invoices for them in line with the phased plan (Guidelines V2.0, §6.3.1).

Sources: ^[5]

Does it apply to foreign businesses without a UAE establishment?

It can. The Guidelines describe e-invoicing as mandatory for any person conducting business in the UAE, whether or not it is established here (Guidelines V2.0, §6). Where a person with no place of residence in the UAE must issue tax invoices under the VAT Decree-Law, those tax invoices should be issued as e-invoices (Guidelines V2.0, §6.3.3). The Guidelines say no more on this point, so confirm the practical steps with your ASP or tax adviser.

Sources: ^[5]

Does receiving e-invoices bring obligations too?

Yes. MD 243/2025 asks the issuer and the recipient each to appoint an accredited service provider, and the recipient must process e-invoices and e-credit notes through the system (MD 243/2025, Art. 5(1), 6(3) and 6(7)). The Guidelines add that a business appoints only one ASP, for both sending and receiving (Guidelines V2.0, §6.1). The Ministry publishes the list of accredited providers (MD 243/2025, Art. 5(2); the MoF list).

Your customers' status does not change your duty either: a customer's onboarding status or tax registration status does not affect the e-invoicing obligations for a transaction (Guidelines V2.0, §6.1).

Sources: ^[1][5][7]

Which transactions are left out?

A short list, set by MD 197/2026 from 1 October 2026 (MD 197/2026, Art. 2 and 4): government transactions in a sovereign capacity that do not compete with the private sector; international airline passenger transport on an electronic ticket, and the ancillary services on an EMD; air cargo on an airway bill, for 24 months; financial services exempt from VAT (and some zero-rated ones); and transactions within a tax group, as a 24-month grace period from 1 January 2027. The Minister can add others by decision. The conditions and time limits are on the exclusions page.

Sources: ^[2]

Where Vattora fits, and when you do not need it

Vattora is connector software, not an accredited service provider, and it does not decide whether you are in scope: that is for you, your ASP or your tax adviser. If you are in scope, Vattora takes the posted invoices and credit notes from your accounting system (each system on our list shows its real status), checks each one against PINT AE and hands it to the ASP you appointed. Vattora connects to the ASP you choose through that provider's API; each link is built and tested in the provider's test environment before your first real invoice. You do not need Vattora if all your sales are to consumers, if your ASP already takes invoices straight from your system, or if you issue so few invoices that entering them with your ASP by hand is simpler.