With the 30 October 2026 deadline to appoint an Accredited Service Provider (ASP) fast approaching for businesses with revenue of AED 50 million or more, and go-live on 1 January 2027, the same questions keep coming up in our client conversations. Is my VAT group covered? What about my B2C business? What do I do if my customer is not yet on the system?
Below are the answers to the questions we are asked most often.
1. Which transactions are covered – B2B, B2G and B2C?
In scope: E-invoicing applies to B2B and B2G transactions (and G2B and G2G). Supplies to consumers – natural persons who are not in business – are not covered, even where a billing agent issues the invoice or collects payment.
2. Does it apply at the VAT group level or to each individual TRN?
Individual: Each member of a VAT group must onboard separately. Your Participant Identifier is based on your own Tax Identification Number (TIN) – the first 10 digits of your own TRN, not the TRN of the group representative. Group members may even appoint different ASPs.
3. Are exempt or zero-rated financial services covered?
No: Financial services that are exempt or zero-rated are excluded. The exclusion also extends to such exempt services when supplied to non-residents and zero-rated as exports.
- Watch out: fee-based financial services that are standard-rated when supplied to UAE customers remain in scope, even if they are zero-rated as exports.
4. Are transactions between members of the same VAT group covered?
Not yet: Intra-group transactions are within scope, but a 24-month grace period applies from 1 January 2027. During this period, e-invoices are not required for transactions between members of the same VAT group. Full compliance applies from 1 January 2029.
- The grace period affects timing only – transactions with third parties must follow the normal roll-out dates.
5. Our business only sells to consumers (B2C). Are we in scope?
Yes: E-invoicing applies to any person conducting business in the UAE in respect of its Business Transactions. Even if all your sales are B2C, you still receive goods and services from other businesses – rent, utilities, stock, professional services – and must be onboarded with an ASP to receive those suppliers’ e-invoices.
6. Is it only for VAT-registered businesses?
No: E-invoicing applies regardless of VAT registration status. A business that is not registered for any tax must register with the FTA to obtain a TIN. Its invoices will be issued as electronic Commercial Invoices rather than Tax Invoices.
7. Does it apply to non-resident businesses?
Yes: Where a person without a place of residence in the UAE is obliged to issue Tax Invoices under the VAT Decree-Law, those Tax Invoices must be issued as Electronic Invoices.
8. Do imports of concerned goods and services under reverse charge require e-invoices?
No: Imports of Concerned Goods and Concerned Services are not subject to e-invoicing.
- However, the domestic reverse charge is covered – electronic devices, precious metals and stones, crude or refined oil, natural gas, pure hydrocarbons and metal scrap. The supplier issues an e-invoice without VAT, using the “Reverse Charge” tax category and stating the reason and the type of goods.
9. What if my customer has not yet implemented e-invoicing?
Two invoices: You still issue the Electronic Invoice, using the predefined endpoint 0235:9900000098 in place of the buyer’s Participant Identifier. Because the buyer cannot receive it electronically, you must also issue a regular Tax Invoice (e.g. PDF) so that the buyer can support its input tax recovery.
10. How are exports handled?
Special endpoint: The Tax Invoice for an export must be issued as an Electronic Invoice, which may also be provided to Customs. If the overseas buyer does not have a Peppol ID, the supplier must include the predefined endpoint 0235:9900000099.
- Optional fields are available for the Customs Reference Number and Incoterms.
Key Dates
| Category | Appoint an ASP by | Go-live |
|---|---|---|
| Revenue AED 50 million or more | 30 October 2026 | 1 January 2027 |
| Revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government Entities | 31 March 2027 | 1 October 2027 |
| Transactions within a VAT group | — | 1 January 2029 |
Recommended Action
At Sun Management, we help businesses move from questions to a working solution – mapping which of your transactions are in scope, checking your VAT group and non-resident positions, reviewing ERP data readiness, and coordinating with your ASP through onboarding, testing and go-live. Talk to our team before the deadline arrives.
