Regulatory updates - United Arab Emirates

The Cabinet Decision specifies violations subject to penalties, and the corresponding fines. According to the Decision, the following penalties will apply:

• Failure to implement the e-invoicing system or to appoint an Accredited Service Provider: 5,000 AED (approximately 1,175 EUR) for each month of delay or part thereof
• Failure by the issuer to issue and transmit an e-invoice or electronic credit note to the recipient through the e-invoicing system: 100 AED (approximately 23 EUR) per e-invoice, capped at 5,000 AED (approximately 1,175 EUR) per calendar month
• Failure by the issuer or recipient to notify the Federal Tax Authority of a system failure: 1,000 AED (approximately 235 EUR) for each day of delay or part thereof
• Failure by the issuer or recipient to notify the appointed Accredited Service Provider of updates to the data registered with the Authority: 1,000 AED (approximately 235 EUR) for each day of delay or part thereof

The penalties apply from the prescribed timelines of adherence to the e-invoicing obligations.

However, the penalties do not apply to entities who issue, transmit, share, exchange or report e-invoices and electronic credit notes voluntarily.

Scope

The Decisions, outline that the Electronic Invoicing System must be used by all entities conducting business in the UAE for all business-to-business (B2B) and business-to-government (B2G) transactions, with only a few exceptions. Businesses not within the scope may voluntarily comply.

In-scope businesses must send and receive their electronic invoices and credit notes through the system compliant with the required data fields, using their appointed accredited service provider (ASP).

Timeline

The roll-out will adhere to the following timelines:

• July 1, 2026: Pilot Program begins with selected taxpayers

Mandatory obligations then extend to large businesses with annual revenues equal to or exceeding AED 50,000,000 (approximately 11.59 million EUR):

• July, 31, 2026: Deadline to appoint an ASP
• January, 1, 2027: Mandatory implementation

For other businesses with annual revenue below AED 50,000,000 (approximately 11.59 million EUR), the following dates apply:

• March 31, 2027: Deadline to appoint an ASP
• July 1, 2027: Mandatory implementation

Lastly, the requirement extends to in-scope government entities:

• March 31, 2027: Deadline to appoint an ASP
• October 1, 2027: Mandatory implementation

Taxpayers in scope are advised to appoint an ASP ahead of their deadlines and familiarize themselves with the technical requirements.

In its announcement on September 29, 2025, the UAE Ministry of Finance released the list and contact details of pre-approved e-invoicing service providers, naming Pagero as one of the pre-approved providers.

The inclusion of Pagero on the list acknowledges fulfillment of the legislative requirements and capabilities in supporting taxpayers subject to the upcoming UAE e-invoicing and CTC obligations.

Stay connected with Pagero to receive timely updates as further details about the UAE e-invoicing mandate are released.