June 2026 brought two significant official documents for UAE businesses navigating e-invoicing compliance. On 1 June, the Ministry of Finance published Version 1.1 of the UAE Electronic Invoicing Guidelines — 51 pages of detailed guidance on scope, invoice categories, storage rules, and the five-corner Peppol framework. Shortly after, Ministerial Decision No. 66 of 2026 amended MD No. 244 of 2025 to formally set the Phase 1 ASP appointment deadline at 30 October 2026. Together, these two documents are the most current authoritative statement of UAE e-invoicing rules for large businesses, SMEs, and government entities. Here's what they say, what they change, and what your finance team needs to do next.
For the full regulatory background and Peppol framework overview, read our UAE e-invoicing complete guide.
Key Takeaways- Phase 1 businesses (≥ AED 50M revenue) must appoint an ASP by 30 October 2026 and go live by 1 January 2027 — deadline set by Ministerial Decision No. 66 of 2026, amending MD No. 244 of 2025- A 24-month grace period applies to intra-VAT-group transactions from 1 January 2027 — confirmed in the V1.1 Guidelines published 1 June 2026- Government Entities have their own phase: ASP by 31 March 2027, go-live 1 October 2027- E-invoicing is mandatory for all persons conducting business in the UAE regardless of VAT registration status
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What Are the UAE E-Invoicing Guidelines V1.1 and MD 66 of 2026?
In June 2026, the UAE Ministry of Finance released two documents that together define the current rules for e-invoicing compliance (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). Reading one without the other leaves Phase 1 businesses with the wrong deadline.
UAE Electronic Invoicing Guidelines V1.1 (published 1 June 2026) is the Ministry's 51-page operational guidance document, aimed at commercial businesses, government entities, and tax and technology advisors. It consolidates rules from four key pieces of subordinate legislation:
- MD No. 243 of 2025 — the Electronic Invoicing System (scope and obligations)
- MD No. 244 of 2025 — the Implementation of the Electronic Invoicing System (phased rollout)
- MD No. 64 of 2025 — eligibility criteria and accreditation of ASPs
- CD No. 106 of 2025 — violations and administrative penalties
Ministerial Decision No. 66 of 2026 amends Article 5, Clause 1(a) of MD No. 244 of 2025. It replaces the original Phase 1 ASP appointment deadline with a new date — 30 October 2026 — while keeping the Phase 1 go-live date unchanged at 1 January 2027.
Reading the V1.1 Guidelines alone isn't sufficient for Phase 1 businesses. The Guidelines document was published before MD No. 66 of 2026 came into effect, so its internal implementation table reflects the pre-amendment deadline. The authoritative Phase 1 ASP appointment deadline is 30 October 2026, as set by MD No. 66. Finance teams relying only on the V1.1 PDF without cross-referencing MD No. 66 will have the wrong date.
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What Are the Mandatory UAE E-Invoicing Implementation Deadlines?
In June 2026, the confirmed mandatory implementation schedule — reading MD No. 66 of 2026 together with MD No. 244 of 2025 and the V1.1 Guidelines — is (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026; Ministerial Decision No. 66 of 2026):
- Phase 1 — Businesses with revenue ≥ AED 50,000,000 — ASP appointment by 30 October 2026 — go live 1 January 2027
- Phase 2 — Businesses with revenue < AED 50,000,000 — ASP appointment by 31 March 2027 — go live 1 July 2027
- Government Phase — Government Entities — ASP appointment by 31 March 2027 — go live 1 October 2027
The voluntary pilot opens on 1 July 2026 for all persons regardless of revenue. Businesses joining the pilot voluntarily must meet all technical requirements set by the Ministry and the FTA. Administrative penalties under CD No. 106 of 2025 don't apply until each business's own mandatory go-live date — not from the pilot entry date.
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Which Businesses Must Comply — and Which Are Excluded?
In June 2026, the V1.1 Guidelines confirmed that Electronic Invoicing applies to all persons conducting business in the UAE for all B2B and B2G transactions, unless specifically excluded (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). "All persons" means everyone — VAT-registered, non-VAT-registered, and non-UAE-established entities that are required to issue Tax Invoices under UAE VAT law. The VAT registration threshold creates no e-invoicing exemption.
The transaction type scope from V1.1 is:
- Business → Business (B2B): ✅ In scope
- Business → Government (B2G): ✅ In scope
- Business → Consumer (B2C): ❌ Excluded
- Government → Business (G2B): ✅ In scope
- Government → Government (G2G): ✅ In scope
- Government → Consumer (G2C): ❌ Excluded
- Consumer → any party: ❌ Excluded (consumers don't issue tax invoices)
Three categories of transactions are excluded from Electronic Invoicing:
- Sovereign government activities — Business Transactions conducted by a Government Entity in a sovereign capacity and not in competition with the private sector
- VAT-exempt financial services to non-resident customers that qualify as zero-rated exports under Article 31 of the VAT Executive Regulation (standard-rated financial services to UAE resident customers remain in scope)
- International airline passenger transport — where an Electronic Ticket is issued to the passenger, or ancillary services where an Electronic Miscellaneous Document is issued — subject to a temporary 24-month exclusion from the date specified in MD No. 244 of 2025
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What Is the New VAT Group Grace Period?
In June 2026, Version 1.1 introduced a grace period for intra-VAT-group transactions that wasn't widely flagged before publication. For Business Transactions carried out between members of the same VAT group, a 24-month grace period applies, commencing 1 January 2027 (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). During this window — running until 31 December 2028 — electronic invoicing obligations under MD No. 243 of 2025 don't apply to intra-group transactions.
What does this mean in practice? If your corporate group has multiple VAT-registered entities that transact with each other — intercompany charges, management fees, shared service recharges — you don't need to route those through the Peppol network until 1 January 2029 at the earliest. The grace period doesn't exempt intra-group transactions permanently; it defers the technical obligation to give groups time to align internal systems.
Important: the grace period is timing-only. It doesn't affect a group's obligations on external Business Transactions, which become mandatory from the applicable Phase 1 or Phase 2 go-live date. Groups relying on the intra-group grace period while ignoring their external transaction obligations will still face penalties.
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What Are the Six Electronic Invoice Categories?
In June 2026, V1.1 confirmed six categories of Electronic Invoices that can be issued under the UAE system (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). The category used depends on whether the transaction requires a Tax Invoice under UAE VAT law and whether billing is standard (supplier-issued) or self-billed (buyer-issued):
One clarification from V1.1: there's no separate "provisional invoice" category. Every provisional invoice must be issued as a standard Electronic Invoice. Adjustments to the provisional amount are handled by issuing either an Electronic Credit Note or an additional Electronic Invoice — not a standalone provisional document.
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How Does the Five-Corner Peppol Framework Work?
In June 2026, the V1.1 Guidelines confirmed the Peppol five-corner model as the transmission framework for all UAE electronic invoices (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). Understanding the responsibility split between corners matters for both ASP selection and internal controls.
- Corner 1 — Supplier: Submits Electronic Invoice data to their ASP in an agreed format
- Corner 2 — Supplier's ASP: Validates, converts to PINT-AE XML, transmits to the buyer's ASP, and reports Tax Data to Corner 5
- Corner 3 — Buyer's ASP: Receives the XML invoice, validates, delivers to the buyer, and also reports Tax Data to Corner 5
- Corner 4 — Buyer: Receives the Electronic Invoice in the format agreed with their ASP
- Corner 5 — FTA: Receives Tax Data from Corners 2 and 3; issues electronic confirmations
Your Participant Identifier on the Peppol network is 0235 followed by your 10-digit Tax Identification Number (TIN). In a Tax Group, each member has their own TIN and Peppol Participant Identifier and may onboard with a different ASP.
For a deeper breakdown of the five-corner model and data flow, see our Peppol network guide.
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What Are the Data Storage Requirements?
In June 2026, V1.1 confirmed that electronic invoice data must be retained for the following minimum periods under Article 3(1) of the Tax Procedures Executive Regulation (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026):
- 5 years from the end of the Tax Period — for Taxable Persons
- 5 years from the end of the calendar year — for all other persons
- 7 years from the end of the calendar year — for real estate records
An FTA audit notification, tax dispute, or ongoing audit extends these periods by an additional 4 years. A voluntary disclosure submitted in the fifth year adds 1 year from the submission date.
Note for VAT-registered businesses: The 7-year figure above applies specifically to electronic invoice data under the Tax Procedures Executive Regulation (Cabinet Decision No. 74 of 2023). A separate 15-year retention obligation applies to VAT records for real estate transactions under the VAT Executive Regulation. Both obligations run concurrently — the longer one governs.
Storage can be inside or outside the UAE — cloud or on-premise — as long as the FTA can retrieve and reproduce records in a complete and readable form on request.
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What Are the Penalties for Non-Compliance?
In June 2026, the V1.1 Guidelines confirmed two separate penalty regimes that apply from each business's mandatory go-live date (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026):
Administrative penalties under Cabinet Decision No. 40 of 2017 apply where a business fails to issue or maintain compliant Tax Invoices in line with the VAT Decree-Law and Tax Procedures Law.
Electronic Invoicing-specific penalties under Cabinet Decision No. 106 of 2025 apply for failing to meet Electronic Invoice compliance obligations specifically. These penalties don't apply to invoices issued voluntarily before the mandatory go-live date.
The penalty distinction matters for businesses joining the voluntary pilot from 1 July 2026. If a transmission fails during the pilot period before your mandatory go-live, CD No. 106 penalties won't apply. But once your mandatory phase is active, system malfunctions must be notified to the FTA within the required timeframe — failure to notify carries its own penalty. Get your malfunction escalation process agreed with your ASP before go-live, not after.
For penalty amounts and how to structure your readiness process, read our UAE e-invoicing readiness checklist.
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What Must Finance Teams Do Before 30 October 2026?
As of June 2026, Phase 1 businesses face a firm ASP appointment deadline of 30 October 2026 — confirmed by MD No. 66 of 2026 — with go-live on 1 January 2027 (UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines V1.1", 1 June 2026). The onboarding process must be initiated by the business (not the ASP) via the FTA's EmaraTax platform.
Step 1 — Understand requirements: Review MD No. 243 and MD No. 244 of 2025 (as amended by MD No. 66 of 2026), identify which of the six PINT-AE invoice categories your transactions fall into, and assess what ERP or accounting system changes are needed.
Step 2 — Select and appoint an ASP: Identify an ASP from the Ministry's current list of accredited providers (mof.gov.ae), finalise commercial terms, and complete onboarding via EmaraTax. Each VAT Group member must onboard individually with their own TIN.
Step 3 — Test: Agree the data transmission approach with your ASP, confirm your systems can extract all required PINT-AE data fields, and run end-to-end exchange and reporting tests. The voluntary pilot opens 1 July 2026 — use it for a penalty-free live test before your mandatory go-live date.
Step 4 — Go live: Confirm roles and responsibilities with your ASP for invoice transmission oversight and error resolution before 1 January 2027.
For detailed guidance on evaluating and selecting an ASP, read our UAE e-invoicing ASP guide.
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Frequently Asked Questions
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Sources
- UAE Ministry of Finance, "UAE Electronic Invoicing Guidelines, Version 1.1," retrieved 2026-06-11, https://mof.gov.ae
- UAE Ministerial Decision No. 66 of 2026, Amending Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System
- UAE Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System
- UAE Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System
- UAE Ministerial Decision No. 64 of 2025 on the Eligibility Criteria and Accreditation Procedure for Service Providers
- UAE Cabinet Decision No. 106 of 2025 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System