UAE amends e-invoicing rules for tax groups as 30 October deadline nears for larger firms
By Catherine Smith GST 2 min read
The UAE Ministry of Finance has amended the rules behind the country’s Electronic Invoicing System, temporarily excluding transactions between members of the same VAT tax group for 24 months and dropping a requirement to store e-invoice data inside the UAE. The changes, set out in Ministerial Decision No. 197 of 2026, were announced on 19 October 2026 and took effect from 1 October 2026.
The decision amends Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. According to the ministry, the changes are meant to make certain requirements clearer, help companies implement the system and lighten their operational load.
What has changed
- Tax groups: business transactions between members of the same tax group will be treated as excluded transactions for 24 months starting on 1 January 2027. A tax group is defined in the decision as two or more persons registered with the Federal Tax Authority as a single taxable person under the VAT Law.
- Data storage: businesses must keep all electronic invoices, electronic credit notes and associated data for the period set by the Tax Procedures Law, and be able to produce them to the Federal Tax Authority on request. The previous requirement for that data to be stored within the UAE has been removed.
- System failure: the provisions on “System Failure” have been removed, so businesses no longer have to tell the Federal Tax Authority within two business days when a system failure occurs.
- Issuing deadline: an electronic invoice or electronic credit note must now be issued and transmitted through the Electronic Invoicing System within 14 business days from the date of the business transaction, where the original text said 14 days. This is subject to a separate clause under which an issuer registered for VAT issues them within the timeline set by the VAT Law.
The full text of the decision is published on the Ministry of Finance e-invoicing page, which the ministry describes as the only official source of information on the introduction of e-invoicing in the UAE.
Deadlines businesses still face
The rollout timetable is set by a separate decision. Under Ministerial Decision No. 244 of 2025, as amended by Ministerial Decision No. 66 of 2026, the system is being introduced in phases.
| Who | Appoint an Accredited Service Provider by | Implement e-invoicing by |
|---|---|---|
| Businesses with revenue of AED 50,000,000 or more | 30 October 2026 | 1 January 2027 |
| Businesses with revenue below AED 50,000,000 | 31 March 2027 | 1 July 2027 |
| Government entities | 31 March 2027 | 1 October 2027 |
Decision No. 244 of 2025 defines revenue as the gross income earned during the most recent accounting period, based on financial statements prepared under UAE legislation or, where those are not available, other documentation acceptable to the Federal Tax Authority. The 30 October 2026 date for larger businesses replaced the original 31 July 2026 deadline. Business-to-consumer transactions are not subject to the system, and anyone engaged exclusively in such transactions is not covered, until a time set by a further ministerial decision.
What it means for companies in Dubai
For persons registered with the Federal Tax Authority as a single tax group, business transactions between group members will be treated as excluded transactions for 24 months from 1 January 2027. Businesses can also hold their e-invoice records outside the UAE, provided they keep them for the required period and can hand them to the Federal Tax Authority when asked. Larger businesses that have not yet appointed an Accredited Service Provider have until 30 October 2026 to do so.
