Updated: 20 October 2026 | A&A Associate LLC
In the same month that large UAE businesses have to appoint an e-invoicing provider, the Ministry of Finance has changed the rules twice. Both decisions took effect on 1 October 2026, but they were only announced in the past two weeks: Decision 168 on 9 October and Decision 197 on 19 October.
Decision 197 makes life easier. Transactions inside a VAT group get a two-year break, invoice data no longer has to sit on UAE servers, and the duty to report system failures within two business days is gone. Decision 168 goes the other way on providers. Only fully accredited providers can now offer e-invoicing services, and the “pre-approved” status some vendors were relying on is being phased out.
What didn’t change is the date. If your revenue is AED 50 million or more, you still need an Accredited Service Provider (ASP) appointed by 30 October 2026 and a working system by 1 January 2027.
This article covers only the October changes. If you need the basics first (what an e-invoice is, how the Peppol model works, how to prepare your data), start with our UAE e-invoicing guide.
The October changes at a glance
| Change | Decision | What it means in practice |
|---|---|---|
| Pre-approval stage removed for providers | MD 168 of 2026 | Only providers on the Ministry’s accredited list can provide e-invoicing services. Previously pre-approved providers have 30 days from 1 October to complete accreditation |
| Intra-group transactions excluded | MD 197 of 2026 | Transactions between members of the same VAT tax group are outside the system for 24 months from 1 January 2027 |
| Data can be stored outside the UAE | MD 197 of 2026 | You must keep e-invoice data for the Tax Procedures Law period and produce it to the FTA on request. Where it is stored no longer matters |
| System failure notice removed | MD 197 of 2026 | The rule to notify the FTA within two business days of a system failure has been repealed |
| 14-business-day issuing rule restated | MD 197 of 2026 | E-invoices and credit notes must be issued and transmitted within 14 business days of the transaction date |
| Deadlines | Unchanged | AED 50 million and above: appoint by 30 October 2026, go live 1 January 2027. Below AED 50 million: appoint by 31 March 2027, go live 1 July 2027 |
Decision 168: your provider must be accredited, not "approved"
Until 30 September, a provider could hold preliminary approval from the Ministry of Finance while the technical side of the UAE system was still being built and tested. Many businesses shortlisted vendors on that basis.
Ministerial Decision No. 168 of 2026 ends that. It replaces Decision No. 64 of 2025 and its amendments, removes the pre-approval stage, and moves to direct accreditation: a provider has to pass the Ministry’s assessment and testing before it can offer e-invoicing services at all. The Ministry said the change reflects the programme moving from development and testing into live operation.
Providers that already had preliminary approval get a transition period of up to 30 days from 1 October to meet the new requirements. They don’t need to reapply unless the Ministry says otherwise. If they don’t meet the requirements in time, the preliminary approval is terminated.
The timing is awkward. Your appointment deadline is 30 October. A pre-approved provider’s transition window runs 30 days from 1 October, so it closes at about the same time. If the provider you’re about to sign with is still in transition, you could appoint it on time and then find it isn’t accredited.
The register itself is easy to check. The Ministry’s list of eInvoicing Accredited Service Providers, last updated on 20 October 2026, shows 69 accredited providers, each with an accreditation number. A separate section lists three more providers that are pre-approved and still going through the final production assessment.
So, before you sign:
- Check the provider’s name and accreditation number on the Ministry’s register yourself. Don’t rely on a logo on their website or a line in a proposal.
- If your preferred provider appears in the “final accreditation assessment” section rather than the accredited list, ask in writing what happens to your appointment if accreditation isn’t granted, and have a second provider in mind.
Decision 168 also keeps a flexibility introduced earlier this year. Providers can still use third-party Peppol products and outsource parts of their service, but they stay fully responsible for compliance and delivery. In other words, your contract is with the accredited provider, whoever builds the software behind it.
Decision 197: intra-group invoices get a two-year break
This is the change most groups will feel first.
From 1 January 2027, transactions between members of the same tax group are treated as excluded transactions for 24 months, which takes the relief to 31 December 2028. Management fees, shared service recharges and internal sales between group members don’t need to go through the e-invoicing system during that period.
Before you plan around it, check the definition. Decision 197 defines a Tax Group as two or more persons registered with the FTA as a single taxable person under the VAT Law. So:
- Companies that share an owner but are registered separately for VAT are not a tax group for this purpose. Their transactions with each other stay in scope.
- A Corporate Tax group is a different registration. Being grouped for Corporate Tax doesn’t, on its own, bring you inside this exclusion.
- Sales from any group member to a customer outside the VAT group are fully in scope.
A worked example. A Dubai holding company has three operating subsidiaries, and all four are registered as one VAT group. The holding company charges each subsidiary a monthly management fee, and one subsidiary sells stock to another. Until the end of 2028, none of those internal invoices need to run through the ASP. Everything those four companies invoice to outside customers still does, from 1 January 2027 if the group is in the AED 50 million wave.
The decision also lets businesses use e-invoicing voluntarily for excluded transactions. If you do, the e-invoicing rules apply to those transactions, but the violation and penalty provisions don’t.
We’d take the two years, but we wouldn’t park intercompany invoicing. Intra-group flows are usually the least tidy part of a group’s books, and they sit right next to your transfer pricing position. Leave them alone until late 2028 and you’ll be doing the same clean-up then, closer to a deadline and with less room to fix what it turns up. Use the window to map the flows and line them up with your intercompany agreements. Once your external invoicing is stable, you can decide whether to put them through the system voluntarily.
The exclusion also follows the VAT group registration. If an entity joins or leaves the group, its treatment changes with it, so membership changes need to reach whoever configures your ERP and ASP.
Invoice data can now be stored outside the UAE
The original rules required e-invoices, credit notes and related data to be stored in the UAE. Decision 197 rewrites Article 11 so the requirement is now about retention and access:
- You must keep all e-invoices, e-credit notes and associated data for the period set by the Tax Procedures Law.
- You must be able to produce those records to the FTA on request.
The Ministry described this as shifting the focus from where data is stored to whether it is retained and accessible. For groups running regional or global cloud systems, this removes the need for a UAE-only copy of the invoice archive.
It doesn’t remove the record-keeping duty, and it raises a question many businesses haven’t asked their provider yet: if you change ASPs in two years, how do you get your structured invoice data back, in what format, and how fast? A folder of PDFs won’t do, because the PDF was never the e-invoice. Put the exit terms in the contract before you sign, not after.
No more two-day system failure notice
Under the original Article 12, a business had to notify the FTA within two business days of a system failure. Decision 197 repeals Article 12 and deletes the definition of “System Failure” altogether.
That matters because Cabinet Decision No. 106 of 2025, which sets e-invoicing penalties, includes a fine of AED 1,000 for each day of delay in notifying the FTA of a system failure. Our reading is that this penalty now has no obligation to attach to, but we would wait for the FTA to say so before treating it as closed.
What the repeal doesn’t change is the clock on your invoices. Decision 197 restates that an e-invoice or e-credit note must be issued and transmitted through the system within 14 business days of the date of the business transaction. An outage, an invoice stuck in approval or a missing purchase order doesn’t stop that clock. You no longer have to report a failure, but you still need a plan for catching up afterwards.
What hasn't changed: the deadlines and the penalties
| Who | Appoint an ASP by | Go live by |
|---|---|---|
| Businesses with revenue of AED 50 million or more | 30 October 2026 | 1 January 2027 |
| Businesses with revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities in scope | 31 March 2027 | 1 October 2027 |
The FTA confirmed the first two rows at a meeting it held in Dubai on 29 September with more than 700 businesses and providers. It also set out the order of steps: select an accredited provider, contract and integrate with it, then complete the procedures on EmaraTax. The 30 October date is the one that was extended from 31 July back in May; it hasn’t moved again.
The penalties under Cabinet Decision No. 106 of 2025 are also unchanged:
- Failing to implement the e-invoicing system or appoint an ASP: AED 5,000 for each month or part of a month of delay.
- Failing to issue and transmit an e-invoice or e-credit note through the system: AED 100 per document, capped at AED 5,000 per calendar month.
The first penalty is the one that applies to a missed 30 October appointment, and it repeats every month until you fix it.
If you're in the AED 50 million group: what to do before 30 October
- Confirm the revenue figure your wave is based on. The threshold is assessed on revenue in your most recent accounting period, not profit.
- Check the Ministry’s accredited register today and shortlist only providers on the accredited list.
- Ask each shortlisted provider for its accreditation number, where your invoice data will be held, how you get it back if you leave, how it will flag excluded intra-group transactions, and what support it gives during cutover in December.
- Sign with your provider and complete the appointment before 30 October. The FTA’s sequence is select, contract and integrate, then complete the procedures on EmaraTax, so confirm with your provider exactly which steps have to be done by the 30th. Full implementation is due by 1 January.
- Confirm which of your entities are in a VAT group, list the transactions between them, and decide how your ERP will mark them as excluded.
- Build a realistic integration and testing plan for November and December, including credit notes, rejected invoices and the 14-business-day issuing rule.
If you're below AED 50 million
Your dates are 31 March 2027 to appoint and 1 July 2027 to go live, and you’ll be choosing from a provider market that has already been through a live rollout. The October changes still help you. The tax group exclusion runs from 1 January 2027 to 31 December 2028 for everyone, so if you go live in July 2027 it covers your first 18 months. The storage change also helps if your accounting system is already hosted outside the UAE.
The accreditation rule applies to you too. Any provider you sign with next year must be on the accredited list.
How A&A Associate can help
A&A Associate LLC is an accounting and tax advisory firm, not an Accredited Service Provider. We don’t transmit invoices. We help businesses get the decisions around the system right:
- Checking your revenue wave and VAT group registrations
- Mapping intra-group transactions and aligning them with your intercompany agreements and transfer pricing position
- Reviewing ASP proposals against the Ministry’s register and the questions above
- Cleaning customer and supplier master data before testing
- Keeping your VAT and Corporate Tax positions consistent with the invoice data the FTA will now receive
If your 30 October appointment isn’t done yet, or you aren’t sure your chosen provider is fully accredited, talk to our team this week.
The bottom line
For groups, October brought some breathing room, and everyone now has more freedom over where invoice data lives. The provider choice got harder, though, and large businesses have to make it this month. If you’re in the first wave, the next ten days come down to one thing: choosing a provider that is on the accredited list today and getting the appointment done. Working out what Decision 197 lets you leave out until the end of 2028 can start the week after.
Disclaimer: This article reflects Ministerial Decisions No. 168 and No. 197 of 2026, Cabinet Decision No. 106 of 2025 and FTA announcements as published on 20 October 2026. E-invoicing rules are still being refined, so check the latest Ministry of Finance and FTA guidance and take advice on your specific circumstances.
