UAE e-invoicing Phase 1 goes live on 1 January 2027. Check your invoices free
Resources · updated 2 November 2026

Questions finance teams ask us.

The mandate, your ERP, and where Orbaura fits. Includes the October 2026 amendments.

The mandate

What is the UAE e-invoicing mandate?

Businesses in the UAE must issue and receive invoices as structured XML in the PINT AE format instead of PDFs, paper or scans. Invoices travel from the seller's Accredited Service Provider (ASP) to the buyer's ASP, and tax data is reported to the Federal Tax Authority along the way. This is called the 5-corner model.

Emailing a PDF invoice will no longer count as e-invoicing.

Source: MoF, UAE eInvoicing Programme (30 June 2026) · Zoho Books, UAE e-invoicing FAQ

Who has to comply?

Anyone doing business in the UAE, for business-to-business and business-to-government sales, whether or not they are VAT registered. Commercial (non-VAT) invoices are in scope too.

Excluded for now:

  • Sales to consumers (B2C)
  • Government entities acting in a sovereign capacity
  • Airline passenger tickets and related passenger services
  • International air cargo with an airway bill, for 24 months
  • VAT-exempt or zero-rated financial services
  • Transactions between members of the same VAT tax group, until 31 December 2028

Source: Baker McKenzie, new e-invoicing rules · Zoho Books, UAE e-invoicing FAQ · KPMG, phased implementation (July 2026) · Fiscal Requirements, Ministerial Decision 197 of 2026 amendments

When does it start?
PhaseWhoAppoint ASP byLive from
Phase 1Revenue AED 50m or more30 October 20261 January 2027
Phase 2Revenue under AED 50m31 March 20271 July 2027
Phase 3Government entities31 March 20271 October 2027

The Phase 1 ASP deadline was moved from 31 July to 30 October 2026, so it has now passed. The Ministry has said the 1 January 2027 go-live will not be extended again. A voluntary pilot has been running since 1 July 2026.

Source: KPMG, phased implementation (July 2026) · MoF, UAE eInvoicing Programme (30 June 2026)

What is an ASP, and do we need one?

An Accredited Service Provider is a company approved by the Ministry of Finance to send, receive and report e-invoices for you. Every in-scope business appoints one through EmaraTax. Buyers need one too, because supplier invoices arrive through it. You use one ASP for both sending and receiving.

The Ministry publishes the list of accredited providers. It had more than 60 names by October 2026 and is still growing.

Source: Zoho Books, UAE e-invoicing compliance guide · Zoho Books, UAE e-invoicing FAQ · einvoicing-uae.ae, accredited provider list (Oct 2026)

What are the penalties?
  • Not implementing on time, including not appointing an ASP: AED 5,000 for each month or part month of delay
  • An e-invoice not issued and sent through the system on time: AED 100 each, capped at AED 5,000 a month
  • An e-credit note not issued and sent on time: AED 100 each, capped at AED 5,000 a month
  • Not telling your ASP about changes to your registered details on time: AED 1,000 a day

The penalty for late notice of a system failure no longer applies, because the October 2026 amendment removed the duty to report system failures.

Source: MoF, Cabinet Decision on violations and penalties · Fiscal Requirements, Ministerial Decision 197 of 2026 amendments

What is PINT AE?

PINT is the Peppol international invoice specification. PINT AE is the UAE version. It sets the XML structure and roughly 50 mandatory fields, including:

  • Seller and buyer tax identifiers and electronic addresses
  • Buyer address, including the emirate
  • An 8-part transaction-type flag: free zone, deemed supply, margin scheme, summary invoice, continuous supply, disclosed agent, e-commerce and exports
  • For every line: quantity, unit-of-measure code, price, tax category and tax rate

The Ministry updated its mandatory field guidance to version 1.1 on 28 October 2026. The standard format can't carry QR codes or barcodes.

Source: MoF, mandatory field requirements V1.1 (28 Oct 2026) · Zoho Books, UAE e-invoicing FAQ

We aren't VAT registered. Does this still apply?

Yes, unless your business falls under an exclusion. A business with no tax registration has to register with the FTA for a Tax Identification Number (TIN) to take part. Each member of a VAT group needs its own TIN and its own ASP onboarding.

Source: Hadef & Partners, compliance considerations · KPMG, phased implementation (July 2026)

How quickly must an e-invoice go out?

Within 14 business days of the transaction, subject to the timelines in the VAT law. Late invoices are penalised per invoice.

Source: Fiscal Requirements, Ministerial Decision 197 of 2026 amendments · MoF, Cabinet Decision on violations and penalties

Can we correct an invoice after it's sent?

No. An issued e-invoice can't be edited. Errors are fixed with an electronic credit note, which has the same timing rules and penalties. This is why order data has to be right before the invoice is raised.

Source: Zoho Books, UAE e-invoicing FAQ · MoF, Cabinet Decision on violations and penalties

What if our system or our ASP goes down?

You no longer have to report it. The October 2026 amendment removed the duty to notify the Authority of a system failure within two business days. Invoices still have to go out within 14 business days, so keep a recovery plan with your ASP.

Source: Fiscal Requirements, Ministerial Decision 197 of 2026 amendments

How long do we keep e-invoices, and where?

Five years after the end of the tax period for taxable persons, five years after the calendar year for others, and seven years for real estate records.

They no longer have to be stored in the UAE. Since the October 2026 amendment, records can be kept anywhere, as long as they are kept for the required period and available to the FTA on request.

Source: Fiscal Requirements, Ministerial Decision 197 of 2026 amendments · Hadef & Partners, compliance considerations

Are free zone companies covered?

Free zones are not on the list of exclusions, and PINT AE has a free-zone flag on every invoice, so plan on free zone businesses being in scope. Clients with designated-zone supplies should confirm the treatment with their tax adviser.

Source: Baker McKenzie, new e-invoicing rules · MoF, mandatory field requirements V1.1 (28 Oct 2026)

Orders, data and your ERP

What does this change for order entry?

Most sales invoices start as a customer PO keyed into a sales order. Under PINT AE, that order has to be complete before the invoice is raised. The ASP rejects invoices with missing or invalid fields, and a sent invoice can only be fixed with a credit note.

The order needs:

  • Buyer legal name and TRN, or TIN if not VAT registered
  • Buyer Peppol ID: 0235 followed by the 10-digit TIN, which is the first 10 digits of the TRN
  • Buyer address with the emirate
  • A unit-of-measure code, tax category and tax rate on every line
  • The right transaction flags, such as free zone, export or continuous supply

Source: MoF, mandatory field requirements V1.1 (28 Oct 2026) · ClearTax, Tally integration with an ASP

Will our accounting system handle e-invoicing?
  • Odoo, Business Central, NetSuite, SAP Business One: each connects to an ASP, usually through a connector your ERP partner sets up. Odoo, for example, has connector modules listed for Odoo 19.
  • Tally: Tally is an MoF-listed ASP, and TallyPrime has e-invoicing built in once party, item, unit and currency masters are configured.
  • Zoho Books: Zoho publishes UAE e-invoicing guidance. Confirm the ASP route with Zoho or with the ASP you've chosen.

In every case the ASP converts what is already in the system. It can't fix a wrong TRN or a missing unit code.

Source: Tally Solutions, TallyPrime for UAE e-invoicing · Cybrosys, Odoo and UAE e-invoicing · Zoho Books, UAE e-invoicing compliance guide

What about invoices we receive from suppliers?

They arrive as e-invoices through your ASP, and you must report receiving them on time. That's the payables side, and it is outside the Order Desk's scope.

Source: Hadef & Partners, compliance considerations

How Orbaura fits

What is the free health check?

You export your customer list, item list and a sample of recent invoices, sign our mutual NDA online, and upload them. Within 48 hours we show you how many records would be rejected under PINT AE today, grouped by reason, with examples. It's free, and you can remove contact names and phone numbers before you upload.

What do we get from the data fix?

Corrected import files for your accounting system, a list of TRNs and details to request from your customers, and working sessions with your finance team or ERP partner. It takes about 5 working days, from AED 7,500. If you go on to the Order Desk, it's credited against setup.

Is Orbaura an ASP?

No. Orbaura turns incoming customer POs from email, WhatsApp, portals, PDFs and spreadsheets into sales orders in your accounting system, and checks the PINT AE fields before each order posts. Your ASP then issues, sends and reports the invoice. We work with whichever ASP you appoint.

Our ASP already handles PINT AE. Why do we need Orbaura?

The ASP formats and sends what is already in your system. It doesn't read a customer's PDF purchase order, notice a missing TRN, or map a customer's "ctn" to the right unit code. Orbaura removes the manual keying and catches those gaps at the order stage. Fixing them there is cheap. Fixing them later means a rejected invoice or a credit note.

How is this different from a general order-entry AI?

General order-entry tools check an order against your price lists, credit limits and stock. Orbaura does that too, and also checks every PINT AE field the invoice will need: buyer TRN or TIN, Peppol ID, emirate, unit codes, tax category and the transaction flags. It works across Odoo, Business Central, NetSuite, SAP Business One, Zoho Books and Tally.

Should we be live with Orbaura before our e-invoicing date?

It helps. Businesses are advised to appoint their ASP at least three months before go-live and to test end to end. Clean order data makes that testing faster. For Phase 2, that means an ASP by 31 March 2027 and going live on 1 July 2027.

Source: Fiscal Requirements, Peppol test goes live in UAE · Zoho Books, UAE e-invoicing compliance guide

Does UAE hosting matter for compliance?

No. Since the October 2026 amendment, e-invoice records no longer have to be stored in the UAE. UAE hosting is available for clients who want their order data processed and stored in the country for their own policy or their customers' requirements.

Source: Fiscal Requirements, Ministerial Decision 197 of 2026 amendments

Pricing

How is the Order Desk priced?

By how many customer POs you receive a month: Starter up to 1,000, Growth up to 3,000 and Enterprise up to 10,000. Above a plan's volume, extra POs are billed in blocks of 1,000 a month. There's a one-time setup and a monthly fee. Book a call for your exact quote.

Are ASP fees included in the price?

No. You contract and pay your ASP directly. Our prices cover the health check, the data fix, PO capture, order creation, the PINT AE checks and the connection to your accounting system.

What does the monthly fee cover?

Hosting, AI processing up to your plan's monthly PO volume, monitoring, updates when your ERP changes, and support on WhatsApp at your plan's level.

Do you charge per PO layout?

No. Every plan reads unlimited PO layouts: PDFs, spreadsheets, scans, email bodies and WhatsApp photos.

This page is general guidance, not tax or legal advice. Confirm your situation with your tax adviser.

How many of your invoices would be rejected today?

Send us your customer and item lists. In 48 hours you'll know the number, the reasons, and the fix.