What's changing
From 2027, businesses in the UAE must issue and receive invoices as structured data in a format called PINT AE, sent through an Accredited Service Provider (ASP). A PDF attached to an email will no longer count as an invoice for these sales.
Once an e-invoice is issued it can't be edited. Mistakes are fixed with an electronic credit note, which follows the same rules and penalties.
Who's in scope
Business-to-business and business-to-government sales by anyone doing business in the UAE, whether or not they're VAT registered. Free zone businesses should plan on being in scope.
Deadlines
| Phase | Who | Appoint an ASP by | Live from |
|---|---|---|---|
| 1 | Revenue AED 50m or more | ||
| 2 | Revenue under AED 50m | ||
| 3 | Government entities |
The Phase 1 ASP deadline moved from 31 July to 30 October 2026 and has now passed. The Ministry has said the 1 January 2027 start won't be extended again.
Find your phase
How invoices travel
The UAE uses a five-corner model. You raise the invoice in your ERP (corner 1). Your ASP validates it and sends it as PINT AE (corner 2) to the buyer's ASP (corner 3), which delivers it to the buyer (corner 4). Tax data is reported to the Federal Tax Authority (corner 5).
Every ASP converts what's already in your ERP. None of them can correct a wrong TRN or a missing unit code.
What PINT AE needs
Roughly 50 mandatory fields. The ones that most often fail come from your customer and item records:
- Buyer TRN, or TIN if they aren't VAT registered
- Buyer Peppol ID: 0235 followed by the 10-digit TIN, the first 10 digits of the TRN
- Buyer address, including the emirate
- On every line: quantity, unit-of-measure code, price, tax category and rate
- Transaction flags: free zone, deemed supply, margin scheme, summary invoice, continuous supply, disclosed agent, e-commerce and exports
The Ministry updated its mandatory field guidance to version 1.1 on 28 October 2026.
Penalties
| Not implementing on time, including no ASP | AED 5,000 a month |
| E-invoice not issued and sent on time | AED 100 each, up to 5,000 a month |
| E-credit note not issued and sent on time | AED 100 each, up to 5,000 a month |
| Not updating your ASP on changed registration details | AED 1,000 a day |
Invoices must go out within 14 business days of the transaction.
Why it starts with the order
For most distributors, a sales invoice is a customer PO that someone typed into a sales order. If the PO came in with a customer's own unit (“ctn”), no TRN, or a zero-rated item at 5%, that error flows straight to the invoice and gets rejected.
What to do now
- Confirm your phase and deadline.
- Appoint an ASP through EmaraTax, if you haven't already.
- Check your customer records for TRNs, addresses and emirates.
- Check your item records for unit codes and tax categories.
- Request missing TRNs from customers now. It takes weeks.
- Test end to end with your ASP at least three months before go-live.
- Make sure every new order comes in clean.
Sources: MoF, UAE eInvoicing Programme (30 June 2026) · KPMG, phased implementation (July 2026) · MoF, Cabinet Decision on violations and penalties · MoF, mandatory field requirements V1.1 (28 Oct 2026) · Baker McKenzie, new e-invoicing rules · Fiscal Requirements, Ministerial Decision 197 of 2026 amendments · Zoho Books, UAE e-invoicing compliance guide · Fiscal Requirements, Peppol test goes live in UAE
General guidance, not tax or legal advice. Confirm your situation with your tax adviser.