UAE authorities release minor electronic invoicing amendments

The United Arab Emirates is progressively introducing mandatory electronic invoicing under a phased implementation programme. Large businesses with annual revenue of AED 50 million or more must implement the system from January 1^st 2027, followed by smaller businesses from July 1^st 2027 and government entities from October 1^st 2027.

On October 19^th 2026, the UAE Ministry of Finance announced Ministerial Decision No. 197 of 2026 [↗︎], amending certain provisions of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. Effective from October 1^st 2026, the amendments introduce several targeted measures to ease compliance and facilitate implementation.

Official legal text: Ministerial Decision No. 197 of 2026 [↗︎] — Amending Certain Provisions of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (Arabic version).

Temporary exclusion for transactions within the same Tax Group

Business transactions between members of the same Tax Group will be treated as excluded transactions for 24 months, starting on January 1^st 2027.

This temporary measure gives affected businesses additional time to adapt their invoicing processes.

Greater flexibility for electronic invoice data storage

Ministerial Decision No. 197 of 2026 removes the requirement to store electronic invoices, electronic credit notes and associated data within the UAE, allowing businesses greater flexibility in choosing where their records are stored.

However, businesses remain responsible for retaining these records for the period prescribed under the Tax Procedures Law and ensuring that they can be provided to the FTA upon request.

Removal of the system failure notification requirement

Ministerial Decision No. 197 of 2026 removes the specific obligation for issuers and recipients to notify the Federal Tax Authority (FTA) of a system failure within two business days.

Under the former Article 12 of Ministerial Decision No. 243 of 2025, both the issuer and the recipient of electronic invoices were required to report such failures to the FTA within two business days of their occurrence, in accordance with the applicable notification procedures.

Issuance window: 14 business days

The deadline for issuing and transmitting electronic invoices and electronic credit notes is extended to 14 business days, instead of 14 calendar days, from the date of the Business Transaction.

The Decision also introduces drafting adjustments concerning excluded transactions and persons excluded from the scope of the Electronic Invoicing System. These include an amendment to the definition of “Accredited Service Provider” and the introduction of definitions for “Tax Group” and “Taxable Person”.

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