UAE E-Invoicing Timeline: Deadlines, Fines and ERP Changes
The UAE e-invoicing timeline from the Ministerial Decisions: ASP deadlines, 2027 go-live dates, the six fines and the ERP data the PINT AE rules reject.
Luka Abramovic24 min read
Businesses in the UAE with revenue of AED 50 million or more in their most recent accounting period must appoint an Accredited Service Provider by October 30, 2026, and still go live on January 1, 2027. That leaves 63 days between the last permitted appointment and live e-invoicing, and for calendar-year companies go-live lands in the year-end close. Ministerial Decision No. 66 of 2026 moved only the appointment date, which was July 31. The Ministry of Finance's own Electronic Invoicing Guidelines V1.1, dated June 1, 2026, still print July 31 in their timeline table, so any UAE e-invoicing timeline copied from it carries the wrong date.
This guide sets out every date that applies to businesses in the UAE, the six fines, what must be an e-invoice, how to vet a provider, and the ERP data the UAE validation rules reject, with checks to run this week. Checked in September 2026 against the Ministerial Decisions, Cabinet Decision No. 106 of 2025, the Ministry's guidance and the PINT AE rules. This is a practical summary, not legal or tax advice. The Ministry of Finance e-invoicing page holds the current texts.
Every date in the UAE e-invoicing timeline
The legal base is Ministerial Decision No. 243 of 2025 (scope and obligations) and Ministerial Decision No. 244 of 2025 (phases), as amended by Decision No. 66 of 2026.
| Date | What happens | Who | Source |
|---|---|---|---|
| July 1, 2026 | Pilot Programme starts. The Ministry invites a "Taxpayer Working Group", and a business joins only by written agreement. | Invited businesses | Decision 244, Art. 3 |
| July 1, 2026 | Voluntary adoption opens. All technical requirements apply, but the e-invoicing fines do not until your mandatory date. | Any business | Decision 244, Art. 4; Cabinet Decision 106, Art. 2(2) |
| October 30, 2026 | Last day to appoint an Accredited Service Provider (ASP). Originally July 31, 2026. | Revenue AED 50,000,000 or more | Decision 66 of 2026 |
| January 1, 2027 | Mandatory go-live | Revenue AED 50,000,000 or more | Decision 244, Art. 5(1)(a), as amended |
| January 1, 2027 to December 31, 2028 | 24-month grace period for transactions between members of the same VAT group. Their other transactions follow the normal phase. | VAT group members | Guidelines V1.1, 6.3.2.1 |
| March 31, 2027 | Last day to appoint an ASP | Revenue below AED 50,000,000; Government Entities | Decision 244, Art. 5(1)(b), (c) |
| July 1, 2027 | Mandatory go-live | Revenue below AED 50,000,000 | Decision 244, Art. 5(1)(b) |
| October 1, 2027 | Mandatory go-live | Government Entities | Decision 244, Art. 5(1)(c) |
| 24 months after the start date | Exclusion ends for airlines' international cargo on an airway bill | Airlines | Decision 243, Art. 4(1)(d) |
| No date set | Business-to-consumer transactions, and businesses dealing only with consumers, stay out until the Minister decides otherwise | B2C | Decision 244, Art. 5(2) |
| No date set | HSN codes become mandatory. They are optional for now, and the timeline "shall be announced in due course" | All issuers | Guidelines V1.1, 12.2, constraint 28 |
Two rules sit outside the table. After the three phases, anyone who becomes subject to the system must appoint an ASP and implement it, with no separate window (Decision 244, Art. 5(1)(d)). Our reading is that a company formed in 2028 should be ready from its first invoice. And joining the pilot doesn't change your phase, which Decision 244 sets by revenue alone.
This week: put your two dates at the top of the project plan, then add the go-live dates of your ten largest customers. Once you are live, every customer who isn't gets two documents per invoice, as the routing section explains.
Which phase you are in
Decision 244 defines Revenue as "the gross income earned by a Person during the most recent Accounting Period, based on the financial statements", or other documentation the Federal Tax Authority (FTA) accepts. Three consequences follow.
- Consumer sales count. Gross income has no carve-out for B2C. An illustrative example: a retailer with AED 45 million of consumer sales and AED 8 million of trade sales has AED 53 million of revenue, so its AED 8 million of trade invoicing goes live in January 2027.
- The test is per Person, meaning each natural or legal person. The Decisions say nothing about adding up a group's companies. If your group prepares only consolidated accounts, ask your tax adviser how each entity will be read before you pick a phase.
- VAT registration doesn't matter. The Guidelines put every Person making a Business Transaction in the UAE in scope "notwithstanding their VAT registration status". A business with no tax registration must get a Tax Identification Number (TIN) through EmaraTax, because the TIN is its address on the network.
| Situation | What applies | First action |
|---|---|---|
| You sell only to consumers | Out until a Minister's decision | Check that no customer is a business. One trade account brings you in. |
| Investment holding company | Out if all revenue is passive. Any recharge, such as a management fee, is a Business Transaction (6.3.1). | List every invoice the company issued last year |
| VAT group member | Each member onboards with its own TIN and may use a different ASP. Invoices between members get the grace period. | List the members and each one's TIN |
| Non-resident required to issue UAE tax invoices | Those invoices must be e-invoices (6.3.3) | Confirm your phase with your tax representative |
| Government Entity | Sovereign activities that don't compete with the private sector are excluded. Everything else follows the October 2027 phase. | Separate sovereign from commercial activity |
What must be an e-invoice, and what is excluded
An Electronic Invoice is one "issued, transmitted, and received in a structured electronic format that enables automatic and electronic processing" (Decision 243). In practice that means PINT AE XML exchanged through ASPs. UAE e-invoices carry no QR code or barcode (Guidelines 5.3), so a PDF is never the e-invoice.
| Type | Issued by the supplier | Self-billed by the buyer |
|---|---|---|
| Tax invoice | Electronic tax invoice (51 mandatory fields) | Self-billed electronic tax invoice |
| Tax credit note | Electronic tax credit note | Self-billed electronic tax credit note |
| Commercial invoice: any invoice that isn't a tax invoice, such as exempt supplies or a seller not registered for VAT | Commercial e-invoice (49 mandatory fields) | Not available |
| Credit note against a commercial invoice | Electronic credit note | Not available |
The field counts come from the Ministry's mandatory fields list of February 23, 2026. There is no category for provisional invoices, so each one must itself be an e-invoice, adjusted later by a credit note or a further invoice. Self-billing needs the buyer to be live, so a Phase 1 supplier whose customer self-bills but goes live in July 2027 must agree how those invoices are issued from January.
When a credit note is compulsory
Article 6(2) of Decision 243 requires an electronic credit note when a transaction is canceled, when the consideration is reduced, when it is returned in full or in part, or when "an administrative or numerical error" occurred. Correcting an invoice by editing and resending it no longer works. The correction is a credit note referencing the original, then a new invoice.
The 14-day clock starts at the earlier of supply or payment
Each e-invoice or credit note must be issued and transmitted within 14 days of the Date of Business Transaction: "the earlier of the date on which the Business Transaction occurred or the date of receipt of payment" (Decision 243, Art. 6(5)). For VAT registrants, Art. 6(4) applies the VAT Law's tax invoice deadline instead, and under that law a payment received before the supply also fixes the date of supply. Either way, a deposit starts the clock. An illustrative example: a customer pays a deposit on March 3, 2027 for goods shipped on March 25. The deposit's e-invoice is due by March 17 (Appendix 5 of the Guidelines confirms an advance gets its own tax invoice). If the balance is paid after delivery, its invoice is due by April 8.
Issuer and Recipient must also report each document to the FTA "within the timeline prescribed by the Minister" (Art. 6(6)). As of September 2026 no Decision sets a separate reporting deadline. The Guidelines have the supplier's ASP report in parallel with delivery, and require ASPs to confirm reporting "on an event-driven basis and without undue delay".
Exclusions
| Excluded | Condition or limit | Source |
|---|---|---|
| Government Entities acting in a sovereign capacity | Only where not competing with the private sector. Sales to government, including through procurement portals, are in scope. | Decision 243, Art. 4(1)(a); Guidelines 6.2 |
| International passenger flights, and airline ancillary services sold to passengers | Where an electronic ticket or Electronic Miscellaneous Document is issued | Decision 243, Art. 4(1)(b), (c) |
| International air cargo | Where an airway bill is issued, for 24 months only | Decision 243, Art. 4(1)(d) |
| Exempt financial services | Excluded, also when supplied to non-residents as zero-rated exports. Services standard-rated for residents are not excluded, even when zero-rated as exports. | Decision 243, Art. 4(1)(e); Guidelines 7.3 |
| Imports of Concerned Goods and Services under the reverse charge | Out of scope. Domestic reverse-charge supplies (electronic devices, precious metals and stones, oil, gas, hydrocarbons, metal scrap) are in scope, invoiced without VAT with the goods type referenced. | Guidelines 10.5 |
| Supplies to or from consumers | Until a Minister's decision, including where a billing agent is used | Decision 244, Art. 5(2); Guidelines 6.2 |
One line in chapter 7 of the Guidelines matters to anyone with a tax-invoice concession: administrative exceptions the FTA granted for tax invoices and credit notes "do not apply to Electronic Invoices and/or Electronic Credit Notes". Plan as if yours ends on your go-live date.
How an invoice moves: five corners and PINT AE
Invoices travel over the Peppol network in a five-corner model: supplier (corner 1), supplier's ASP (2), buyer's ASP (3), buyer (4) and the FTA (5). Of the eleven steps in Guidelines section 5.1, four shape your systems:
- Your ASP validates your data, converts it to PINT AE XML, sends it to the buyer's ASP and, in parallel, reports tax data to the FTA. Nothing waits for FTA approval.
- The buyer's ASP validates the invoice, confirms to your ASP and reports its own tax data.
- If the buyer's ASP finds the invoice invalid, it tells your ASP and the FTA, and reports no tax data. The FTA sees your failed invoices.
- The FTA confirms each successful report, and the ASPs pass confirmations to supplier and buyer.
That parallel design differs from Saudi Arabia's Fatoora integration phase, where each standard tax invoice goes through ZATCA's clearance API and simplified invoices are reported within 24 hours. Our guide to the ZATCA Phase 2 waves covers who has to integrate there, and when, if you invoice in both countries.
| Item | Value |
|---|---|
| Specification (CustomizationID) | urn:peppol:pint:billing-1@ae-1 (self-billing: urn:peppol:pint:selfbilling-1@ae-1) |
| Business process (ProfileID) | urn:peppol:bis:billing (or urn:peppol:bis:selfbilling) |
| Current version | PINT AE 1.0.4, status Final, released June 2, 2026 and maintained by the UAE Peppol Authority, published on docs.peppol.eu |
| Your participant ID | 0235: plus your 10-digit TIN, which is the first 10 digits of your 15-digit TRN |
| Invoice UUID | Generated by your ASP, alongside your own sequential invoice number |
Where to send an invoice when the buyer isn't on the network
Until July 2027, many of a Phase 1 supplier's domestic customers won't have a participant ID, and collecting each buyer's ID is the supplier's job (Guidelines 5.2). The Guidelines set predefined endpoints for these cases. This is the routing logic your ERP or ASP connector needs:
if deemed supply (VAT Decree-Law, Art. 11):
endpoint = 0235:9900000097 # reported only, if no invoice goes to the recipient
elif export and buyer has no Peppol ID:
endpoint = 0235:9900000099
elif buyer has not implemented e-invoicing yet:
endpoint = 0235:9900000098 # AND send a regular (PDF) tax invoice
else:
endpoint = 0235:<buyer TIN> # your ASP looks it upThe third branch creates the work. For buyers who aren't live, section 10.2.2 requires a regular tax invoice as well, so your billing run produces two documents. Your customer master needs an "e-invoicing live" flag and a participant ID field, updated as customers go live in July and October 2027. And each business appoints one ASP for both sending and receiving (Guidelines 6.1), so accounts payable moves to the same provider.
The six fines in Cabinet Decision No. 106 of 2025
Cabinet Decision No. 106 of 2025 lists six violations. None applies to voluntary adopters. The general VAT penalties in Cabinet Decision No. 40 of 2017 may also apply where tax-invoice obligations are missed (Guidelines chapter 11).
| # | Violation | Fine | Examples of how it happens |
|---|---|---|---|
| 1 | Issuer fails to implement the system, including failing to appoint an ASP on time | AED 5,000 per month or part of a month of delay | A contract signed after the appointment date, or a go-live that slips |
| 2 | Issuer fails to issue and transmit an e-invoice through the system on time | AED 100 per e-invoice, up to AED 5,000 per calendar month | Manual invoices, recharges or deposits raised outside the ERP |
| 3 | Issuer fails to issue and transmit an e-credit note on time | AED 100 per e-credit note, up to AED 5,000 per calendar month | Credits agreed by email and booked as journals |
| 4 | Issuer fails to notify the FTA of a System Failure on time | AED 1,000 per day or part of a day | An ASP outage that stops you issuing, not reported within 2 Business Days (Decision 243, Art. 12) |
| 5 | Recipient fails to notify the FTA of a System Failure on time | AED 1,000 per day or part of a day | The same outage on the payables side |
| 6 | Issuer or Recipient fails to notify its ASP of changes to data registered with the FTA on time | AED 1,000 per day or part of a day | A trade license renewal, address or tax group change in EmaraTax not passed to the ASP within 5 Business Days of the FTA's confirmation (Decision 243, Art. 5(3)) |
Read literally, rows 2 and 3 are capped separately per calendar month, and the cap bites at the 50th document. So rows 1 to 3 together can cost at most AED 15,000 a month. An illustrative example: a Phase 1 distributor goes live on February 20, 2027 instead of January 1, raising 600 invoices and 40 credit notes a month in the meantime. The table gives AED 10,000 under row 1 (January and part of February), AED 10,000 under row 2 (capped both months) and about AED 6,700 under row 3 (40 credit notes, then about 27). That is roughly AED 26,700. How the FTA combines rows is its decision, so treat this as the arithmetic of the table, not a forecast.
Rows 4 to 6 have no cap, and they are the ones a process can miss for weeks. The Guidelines expect your ASP to report its own outages to the FTA at e-invoicingsupport@tax.gov.ae, but rows 4 and 5 fine the Issuer and the Recipient. Our default contract terms: the ASP notifies the FTA of any outage, copies you the same day, and exchanges and reports every held invoice when service resumes. Then name the person in finance who files your own notice.
Choosing an Accredited Service Provider
The Ministry's service provider page carries two lists: accredited providers (Article 16 of Ministerial Decision No. 64 of 2025) and pre-approved providers (Article 15). When it extended the Phase 1 deadline in May 2026, the Ministry said 32 service providers had been approved, with more in the final stages of accreditation (announcement). A separate amendment, Ministerial Decision No. 56 of 2026, rewrote the eligibility article: a provider may deliver the service through a product owned by a third party, and outsource its development, operation or management, while keeping full responsibility for meeting the conditions. The lists change often. Read them on the day you shortlist, record the date, and if a provider works through a partner, ask which company holds the accreditation and which one runs the product.
Pre-approved is not accredited, and accreditation expires
A pre-approved provider may serve clients only if it is accredited within the Ministry's timeline. If not, it "shall not be permitted to continue providing Electronic Invoicing Services" (Decision 64, Art. 4(3)). Accreditation lasts two years (Art. 16(3)), and renewal must be filed at least 70 Business Days before expiry. Miss that, or fail to fix a rejected renewal, and "links to all Persons represented by the Service Provider shall be revoked" (Art. 18(7)). A terminated provider has 5 Business Days to tell its clients (Art. 19(3)). Your contract should say what you get in each case, including a full export another ASP can load.
How onboarding works
You start onboarding, not the provider, and only once the contract and commercial terms are settled (Guidelines 13.2). The Account admin of your EmaraTax profile opens the E-INVOICING tile, selects the ASP and clicks "Proceed to ASP", then finishes on the provider's portal. The provider then gives you your participant ID. The Guidelines ask you to check first that your trade license, address and contact details in EmaraTax are up to date. Each VAT group member onboards separately.
| Condition | Article | Ask for |
|---|---|---|
| Active Peppol-certified provider that passed OpenPeppol conformance tests. The product it delivers the service through has run for at least two years, and that experience may sit with a third party. | 5(1)(a), (b); 5(bis) | Certification, and who owns and runs the product |
| UAE company, or foreign company licensed in the UAE, with at least AED 50,000 paid-up capital | 6(1), (2) | The contracting entity's trade license |
| ISO 22301 for business continuity; ISO/IEC 27001 for the product; multifactor authentication; encryption in transit and at rest; hosting and residency compliance | 6(4), 9 | Certificates, and where your data is hosted |
| Insurance from insurers operating in the UAE: professional indemnity of at least AED 2,500,000, crime and cyber fraud of at least AED 5,000,000 each | 11 | Current certificates of insurance |
| Commitment to 100 free e-invoice exchange and reporting services a year from signing the end-user agreement | 10(4), Schedule 1 | How that shows in the price, and the price per document after it |
Send this to each shortlisted provider and compare the written answers:
Subject: UAE e-invoicing: questions before we appoint an ASP
1. Are you on the accredited (Article 16) or pre-approved (Article 15) list
today? If pre-approved, what is your accreditation deadline, and what
happens to our onboarding if you miss it?
2. When does your accreditation expire, and when will you file to renew?
3. Please send your ISO/IEC 27001, ISO 22301 and insurance certificates.
4. How do we send invoice data (API, file, ERP connector), and in what format
and how fast do you return validation errors and FTA confirmations?
5. Which PINT AE version do you validate against, and how much notice do you
give before moving to a new one?
6. How do you handle buyers not yet live (0235:9900000098), exports
(0235:9900000099) and deemed supplies (0235:9900000097)? Do you also
produce the PDF for buyers who are not live?
7. In an outage, when do you notify the FTA, and will you copy us that day?
8. Where do you store our documents, for how long, and how do we export
everything in readable form if we leave?
9. We have [n] entities / VAT group members. One contract? What do you need
to onboard each?What your ERP must change: the rules that reject invoices
Your ASP validates every invoice against the PINT AE rules before it leaves corner 2. In version 1.0.4 the UAE-specific rules file holds about 130 checks, all flagged fatal, on top of about 170 general PINT checks. These test master data that ERPs often store loosely, so we'd check them first:
| Rule | What it demands | ERP data that fails, and the fix |
|---|---|---|
| ibr-132-ae | A TRN is 15 digits, starts with 1 and ends with 03 | Spaces, dashes, a "TRN" prefix or a TIN in the TRN field. Validate at entry (query 1). |
| ibr-148-ae | A seller not registered for VAT identifies itself by its TIN: 10 digits, 1XXXXXXXXX | A 15-digit TRN or a license number in that field. Keep the TIN in its own field. |
| ibr-143-ae, ibr-144-ae, ibr-128-ae | Every seller and buyer address, foreign ones included, needs line 1, a city and a country subdivision. In a UAE address the subdivision is an emirate code: AUH, DXB, SHJ, UAQ, FUJ, AJM or RAK. | "Dubai" typed in a state field, no emirate, or an export customer with no state or region. Add a code field and map it (queries 2 and 4). |
| ibr-172-ae, ibr-101-ae | With a trade license as legal registration, the issuing authority's name is required | No authority stored, and there is no code list for it (Guidelines constraint 20). Capture it at customer onboarding. |
| ibr-127-ae, ibr-192-ae | A payment due date when an amount is due; an account identifier for credit transfers | "On receipt" terms with no due date; bank details only on the PDF template. Make both data fields. |
| ibr-158-ae, ibr-055-ae | A credit note reason from the UAE list, and a reference to the original invoice, except for a volume discount, which must not carry one | Free-text reasons and credits "on account". Map reasons (table below). |
| ibr-141-ae | A VAT point date, if sent, must be earlier than the issue date | ERPs that fill the tax point with the invoice date on every invoice. Equal dates fail. Send it only when the supply date differs. |
| ibr-190-ae | Every standard-rated line, allowance and charge carries a rate of 5 | Rates stored as fractions (0.05), or a standard-rated code reused for 0% lines. Map each tax code to one of the six UAE tax categories. |
| ibr-159-ae, ibr-002-ae, ibr-175-ae | Foreign-currency invoices carry the exchange rate (up to 6 decimals) and AED totals for VAT and the invoice | USD invoices with no AED figures. The Guidelines also want each line's VAT and amount payable in AED (constraint 16), and the AED total at the Central Bank rate (constraint 17). |
Rule IDs are from PINT AE 1.0.4. When a new version is released, get the release notes from your ASP and rerun your test invoices.
The tax group trap in your customer master
A VAT group is registered as a single taxable person, so its members invoice and are invoiced under the group's TRN, and that is the TRN your customer master holds. The endpoint is different. The Guidelines say a member's TIN is "the first 10 digits of your own TRN and not the first 10 digits of the Tax Group representative's TRN", and the February 2026 fields list names that TRN: the member's Corporate Tax TRN. Derive endpoints from the VAT TRN on file and every member's invoices go to the same endpoint. No PINT AE rule compares the endpoint with the TRN, so validation won't catch it. Keep two fields: the TRN printed on the invoice and the endpoint it is sent to. Payables has the mirror problem: matching supplier invoices on TRN lumps group members together, so match on endpoint or legal registration number.
Checks to run on your customer master this week
Run these on an export of the customer table. They are written for PostgreSQL, with placeholder table and column names.
-- 1. UAE customers whose TRN would fail ibr-132-ae
SELECT id, name, trn FROM customers
WHERE country_code = 'AE' AND trn IS NOT NULL
AND trn !~ '^1[0-9]{12}03$';
-- 2. UAE customers whose region is not one of the seven emirate codes,
-- with a suggested mapping
SELECT id, name, region,
CASE upper(regexp_replace(region, '[^A-Za-z]', '', 'g'))
WHEN 'ABUDHABI' THEN 'AUH' WHEN 'DUBAI' THEN 'DXB' WHEN 'SHARJAH' THEN 'SHJ'
WHEN 'AJMAN' THEN 'AJM' WHEN 'UMMALQUWAIN' THEN 'UAQ'
WHEN 'RASALKHAIMAH' THEN 'RAK' WHEN 'FUJAIRAH' THEN 'FUJ'
END AS suggested_code
FROM customers
WHERE country_code = 'AE'
AND coalesce(region, '') NOT IN ('AUH','DXB','SHJ','UAQ','FUJ','AJM','RAK');
-- 3. One TRN on several customers: probably a VAT group,
-- and each member needs its own endpoint TIN
SELECT trn, count(*) AS customers, string_agg(name, '; ') AS names
FROM customers WHERE country_code = 'AE' AND trn IS NOT NULL
GROUP BY trn HAVING count(*) > 1;
-- 4. Any customer, UAE or foreign, missing address line 1, city or
-- region, or with a license number but no issuing authority
SELECT id, name, country_code FROM customers
WHERE coalesce(trim(address_line1), '') = ''
OR coalesce(trim(city), '') = ''
OR coalesce(trim(region), '') = ''
OR (trade_license_no IS NOT NULL AND license_authority IS NULL);No database? In Excel or Google Sheets, keep the TRNs in column A as text and put this in B2. FALSE marks a TRN to fix, stray spaces included:
=AND(LEN(A2)=15, LEFT(A2,1)="1", RIGHT(A2,2)="03",
SUMPRODUCT(--ISNUMBER(--MID(A2,ROW($1:$15),1)))=15)For duplicate and unmatched customers across systems, the profiling queries in our ERP integration guide go further.
Map your credit note reasons
The codes and meanings come from the PINT AE code list. The third column is our suggested mapping, so agree it with your tax adviser.
| Code | Meaning | ERP reasons to map here |
|---|---|---|
| DL8.61.1.A | Supply canceled | Order canceled |
| DL8.61.1.B | Tax treatment changed because the nature of the supply changed | Reclassified supply |
| DL8.61.1.C | Agreed consideration altered for any reason, such as bad debt relief | Price correction, settlement discount, short delivery, write-off |
| DL8.61.1.D | Goods or services returned and consideration returned | Returns |
| DL8.61.1.E | Tax charged, or tax treatment applied, in error | Wrong VAT code or TRN, duplicate invoice |
| VD | Volume discount | Rebates. ibr-055-ae rejects a VD credit note that references an invoice, so send it without one. |
Set the eight transaction flags per invoice
Every UAE e-invoice carries an eight-character code of 0s and 1s in cbc:ProfileExecutionID. Most positions switch on extra mandatory data, so the ERP should set the flags from the order, not a person:
position 1 free zone involved -> beneficiary ID required (ibr-007-ae)
position 2 deemed supply -> endpoint 0235:9900000097
position 3 margin scheme -> VAT amount shown as 0
position 4 summary invoice -> invoicing period required (ibr-138-ae)
position 5 continuous supply
position 6 disclosed agent billing -> principal ID required (ibr-137-ae)
position 7 e-commerce supply -> delivery address required (ibr-142-ae)
position 8 export -> delivery rules (ibr-152-ae)
00000000 = ordinary domestic invoice 00000001 = exportProcess changes outside the ERP
- A rejection and confirmation queue. Each invoice ends confirmed, rejected or waiting. Our default is to treat a rejected invoice as not issued until a corrected one is confirmed, because the 14-day rule and fine 2 measure issuing and transmitting. What the queue should hold, and who works it, is in our guide to connecting business systems.
- A daily 14-day report. List supplies and payments with no confirmed e-invoice after 10 days, dated by the earlier of the two. The 10-day trigger is our rule of thumb: it leaves time to fix a rejection.
- A master data change procedure that passes any change registered with the FTA to the ASP within 5 Business Days, through EmaraTax reverification or offboarding (Guidelines 13.5).
- A system failure runbook naming who declares a System Failure and who notifies the FTA within 2 Business Days.
- Payables intake for XML supplier invoices arriving from your ASP, with approval workflows that no longer start from a PDF in a mailbox.
- One advance-payment method. Guidelines V1.1 has two: constraint 9 puts the advance in the final invoice's Paid Amount, while Appendix 5, headed a clarification, bills only the balance and leaves that field blank. Agree one with your adviser and ASP.
- Storage. Keep documents and associated data 5 years after the tax period (Taxable Persons), 5 years after the calendar year (others) or 7 years for real estate, plus 4 more during an audit or dispute. Article 11 says "within the State", which the Guidelines read as retrievable by the FTA "irrespective of the geographic location of the servers". An ASP may store for you by contract, but the obligation stays yours.
Rounding applies only to the invoice total, to 2 decimal places. There is no line limit, you can't add your own optional fields, and one credit note may reference several invoices (Guidelines 12.2).
A plan and worksheet for your deadline
For a Phase 1 business reading this in October 2026, this sequence fits the 63 days. The order follows the Guidelines' four steps. The timings are our judgment.
| By | Done |
|---|---|
| October 30, 2026 | ASP contract signed. EmaraTax details checked. Onboarding started for every entity and VAT group member. |
| Mid-November | Customer master queries run and fixed. Credit reasons mapped. Endpoint and "live" fields added. Transaction flags derived per invoice type. |
| Early December | End-to-end tests with the ASP: each invoice type you use, a rejection, a credit note, a foreign-currency invoice, a buyer not yet live, and an incoming supplier invoice. |
| Mid-December | Rejection queue, 14-day report, change procedure and failure runbook live, each with a named owner. |
| January 1, 2027 | Live. Check daily that invoices issued equal invoices confirmed. |
Phase 2 businesses and Government Entities can run the same sequence from January 2027. Until you have a participant ID, your Phase 1 suppliers keep sending you PDF tax invoices (Guidelines 10.2.2), and their XML reaches your payables team only after you onboard.
| Item | Our answer | Owner | Date |
|---|---|---|---|
| Revenue per legal entity, and the phase it puts each in | |||
| ASP chosen, list checked (with date), accreditation expiry noted | |||
| Participant ID for every entity and VAT group member | |||
| Customers failing queries 1 to 4, and the date they will be clean | |||
| Invoices raised outside the ERP, and how each reaches the ASP | |||
| Credit reasons mapped; transaction flags derived | |||
| Routing for buyers not yet live, exports and deemed supplies | |||
| Owners of the rejection queue, 14-day report and FTA failure notices | |||
| Storage location, retention and export route | |||
| Payables intake for XML supplier invoices |
If your ERP can't produce clean PINT AE data, or invoices are raised in more places than it knows about, bring the completed worksheet and an export of your customer master. We'd start with the TRN, emirate and credit note reason fields, because they decide how many invoices bounce in January. Getting them right comes before any other part of our systems integration work.