UAE's e-invoicing initiative: A new era for VAT compliance and efficiency

This article was last updated on 02 December 2025 to reflect the new Cabinet Decision outlining violations and administrative penalties related to the e-invoicing system.

These decisive strides follow the groundbreaking e-invoicing progress made in Saudi Arabia over the course of the past years. With the recent issuance of Federal Decree-Laws No. 16 and No. 17 of 2024, the UAE is laying the groundwork for an e-invoicing system that aims to streamline VAT compliance, increase transparency, and maximise revenue collection efficiency. Here’s an overview of how these initiatives are shaping the UAE’s indirect tax landscape.

Evolution of VAT in the UAE

Since the introduction of VAT in 2018, the UAE has been actively working to build a robust taxation framework that balances economic growth with revenue collection. These new amendments reinforce the country’s emphasis on digital innovation, positioning the UAE as a frontrunner in the region. The upcoming e-invoicing system represents a continuation of this journey, using advanced technology to improve compliance, close tax gaps, and reduce administrative burdens for businesses and the government.

Key changes: Setting the stage for e-invoicing

Federal Decree-Law No. 17 of 2024, which focuses on tax procedures, introduces a formal definition of the “e-invoicing system”- an electronic platform designed for issuing, sending, exchanging, and sharing VAT invoices and credit notes in accordance with UAE tax legislation - and empowers the Ministry of Finance to implement this system through the necessary regulatory updates. Federal Decree-Law No. 16 of 2024 amends the VAT-specific legislation to include electronic formats for tax invoices and credit notes, thereby establishing the legal framework for the use of e-invoices.

The UAE e-invoicing model: Decentralised Continuous Transaction Control and Exchange (DCTCE)

The UAE has chosen a decentralised, five-corner model known as the Decentralised Continuous Transaction Control and Exchange (DCTCE) system, leveraging the OpenPeppol network for interoperability. This model allows suppliers and buyers to exchange invoices via Accredited Service Providers (ASPs) that validate and standardise the invoice data. The ASPs then share the data with the Federal Tax Authority (FTA), ensuring compliance and accuracy. By decentralising the process, the model enables efficient and secure transaction records, while providing the FTA with real-time access to invoice data for better oversight and reduced tax evasion.

Implementation timeline and future steps

The UAE’s e-invoicing rollout follows a phased timeline:

• Q4 2024: Development of ASP accreditation and the UAE Data Dictionary

• Q2 2025: Legislative updates specific to e-invoicing

• July 2026: Pilot/voluntary adoption phase: Taxpayer working group & voluntary adopters

• January 2027: Phase 1: Mandatory e-invoicing implementation for large businesses with an annual revenue ≥ AED 50 million (deadline to appoint ASP: 31 July 2026)

• July 2027: Phase 2: Mandatory e-invoicing for smaller businesses with an annual revenue < AED 50 million (deadline to appoint ASP: 31 March 2027)

• October 2027: Phase 3: Mandatory e-invoicing implementation for government entities (B2G) (deadline to appoint ASP: 31 March 2027)

These steps underscore the UAE's commitment to a gradual, structured implementation to ensure that businesses can adapt to the new system.

New Cabinet Decision introduces penalties for non-compliance

Further emphasising the government's commitment to rolling out e-invoicing, the UAE officially released Cabinet Decision No. 106 of 2025 in November 2025, outlining violations and administrative penalties related to the e-invoicing system. This crucial step signals that the timeline is set in stone, emphasising the critical need for all organisations to prioritise timely readiness and proper system integration, as well as onboarding an ASP.

Key penalties that businesses must be aware of include:

• AED 5’000 per month for failing to adopt the Electronic Invoicing System and appoint an ASP.

• AED 100 per document (capped at AED 5’000 per month) for failing to issue and transmit e-invoices or e-credit notes through the mandated system.

• AED 1’000 per day for both issuers and recipients failing to notify the Federal Tax Authority (FTA) of a system failure.

• AED 1’000 per day for failing to update the ASP with changes to registered data.

A future-ready tax system

The UAE’s developments in e-invoicing highlight a broader trend in the GCC, where countries are increasingly adopting digital solutions to enhance tax transparency and streamline compliance.

By embracing a comprehensive e-invoicing model, the UAE is pioneering a shift towards a modern, paperless economy while strengthening its VAT administration. As the system evolves, businesses in the UAE can look forward to streamlined processes and a more transparent tax environment that aligns with international best practices. This proactive approach is an important step in the UAE’s journey towards digital transformation and economic resilience.

As the UAE moves on to the next phase of its VAT transformation, Unifiedpost plays an instrumental role in the country's digital tax revolution. With the assistance of its advanced technology and secure systems, Unifiedpost is able to facilitate a streamlined exchange of VAT invoices between businesses, Accredited Service Providers (ASPs), and the Federal Tax Authority (FTA). This ensures compliance, reduces administrative burdens, and supports the UAE's efforts to create a transparent and efficient tax system that aligns with global best practices.

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