Regulatory updates - United Arab Emirates

The official accreditation confirms that ONESOURCE Pagero has fulfilled the technical, organizational, and legislative requirements set out by the Ministry of Finance. As a fully accredited service provider, businesses can use ONESOURCE Pagero to exchange and report e-invoices in compliance with the UAE e-invoicing model.

The UAE e-invoicing obligations will apply broadly, encompassing not only businesses established in the UAE, but also UAE VAT-registrants. Businesses in scope should begin preparations now, as implementation deadlines are approaching.

Large businesses with annual revenues of 50 million AED or more are required to appoint a UAE-accredited service provider (ASP) no later than October 30, 2026. Mandatory e-invoicing and reporting will be introduced for large businesses on January 1, 2027. Following this, other businesses with annual revenues less than 50 million AED, as well as government entities, will be brought into scope in accordance with the Ministry of Finance's implementation timeline. Note: the ASP appointment deadline for large businesses was extended to October 30, 2026.

Businesses within scope should now evaluate service providers and may then select their preferred ASP in the EmaraTax portal to begin onboarding and prepare for compliance with UAE e-invoicing requirements.

The key update in this version is the addition of Appendix 5 – Advance Payments and Retention Clarification, which provides further guidance on the electronic invoicing treatment of advance payments and retention amounts.

All Accredited Service Providers are requested to review the updated guidelines and assess any implementation, operational, and compliance impacts arising from the new clarification and other updates included in Version 1.1.

The updated UAE Electronic Invoicing Guidelines are available on the Ministry of Finance e-invoicing website.

The amendment affects large businesses with annual revenues exceeding 50 million AED (ca. 11.56 million EUR). Previously, large businesses were required to appoint an Accredited Service Provider (ASP) by July 31, 2026, but may now do so no later than October 30, 2026.

The timeline for required e-invoicing system implementation, however, remains unchanged. Full implementation for large businesses is required no later than January 1, 2027.