UAE sets the scope of mandatory e-invoicing in Ministerial Decision No. 243 of 2025

What changed in detail

Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System was announced by the UAE Ministry of Finance on 29 September 2025. It sets the scope of the e-invoicing system, which runs on the OpenPeppol model through Accredited Service Providers, and the obligations of the persons subject to it.

The system applies to any person conducting business in the UAE, for every business transaction, unless the transaction is excluded. The excluded transactions are:

• sovereign-capacity transactions of government entities that do not compete with the private sector;
• international passenger air transport where an electronic ticket is issued, and related ancillary services under an Electronic Miscellaneous Document;
• international air cargo under an airway bill, for 24 months from the date the system becomes effective;
• financial services that are VAT-exempt or zero-rated under Article 42 of the VAT Executive Regulation.

Issuers and recipients must each appoint an Accredited Service Provider. The issuer must issue and transmit the electronic invoice or electronic credit note within 14 days of the business transaction. For VAT registrants, Article 6(4) puts the VAT-law timeline for issuing tax invoices first.

The decision comes into force on the date of its publication in the Official Gazette. That date is not stated in the Ministry of Finance sources cited here, so this record gives no effective date. Phase dates are in the companion Ministerial Decision No. 244 of 2025.

What it means

This is the rulebook for who is in scope, and it is in force, but no longer in its original form. Ministerial Decision No. 197 of 2026 amended it from 1 October 2026, adding a 24-month exclusion for transactions within a VAT Tax Group and replacing the data-storage rule, and changed the issuing window from 14 days to 14 Business Days. That window and the obligation on both sides to appoint a provider still drive implementation work. The recipient’s obligation is easy to miss: a business that only buys still needs an Accredited Service Provider.