The Ministry of Finance (MoF) has fixed 30 October 2026 as the deadline for in-scope businesses to appoint an Accredited Service Provider (ASP) and register for the UAE
Electronic Invoicing System. Key points are as follows:
1. Deadline and Applicability (Ministerial Decision No. 244 of 2025, as amended by
Ministerial Decision No. 66 of 2026)
• Registration deadline: 30 October 2026 (extended from 31 July 2026) for businesses
with annual revenue of AED 50 million or more.
• Go-live date: 1 January 2027 – this date has not changed, so there are only about
nine weeks between the deadline and go-live.
• Revenue test: Based on gross income for the most recent accounting period, checked
separately for each legal entity. The Decision refers to gross income of “AED 50 million or more”.
• Smaller businesses: Not covered by this deadline
2. Registration Requirements
• Appoint an ASP: The first step is to appoint an ASP from the official MoF list of
accredited service providers and sign the contract before 30 October 2026.
• Complete onboarding: Giving the ASP the business details so that you are set up on
the e-invoicing network.
• Both parties need an ASP: The issuer and the recipient of the invoice must each
appoint an ASP so that both parties will be informed in advance.
• Structured format: Invoices must be issued as structured data (XML, PINT AE
format). PDF, Word, scanned or emailed invoices do not qualify as e-invoices.
• Keep details updated: Any change in registered data must be notified to the ASP
within 5 business days.
• Out of scope (for now): B2C transactions, government sovereign activities, certain
airline services and exempt/zero-rated financial services.
3. Penalties for Non-Compliance (Cabinet Decision No. 106 of 2025)
• Failure to appoint an ASP / implement the system: AED 5,000 per month.
• Delay in informing the ASP of changes in registered data: AED 1,000 per day.
Recommended action:
At Sun Management, our team can support you from start to finish—from assessing your e- invoicing applicability and understanding the requirements, to coordinating with ASPs, reviewing ERP readiness, and supporting the implementation process to ensure a smooth transition to e-invoicing.