What is different about buying in the United Arab Emirates

Ministerial Decisions No. 243 and No. 244 of 2025 roll electronic invoicing out "on a phased basis for any Person carrying out Business in the UAE, in respect of any Business Transaction, unless specifically excluded". The Ministry's own table gives a Person with annual revenue of AED 50,000,000 or more a last date to appoint a service provider of 31st July 2026 and a last date to implement of 1st January 2027; a Person below that threshold, 31st March 2027 and 1st July 2027; a Government Entity, 31st March 2027 and 1st October 2027. Supplies to natural persons who are not in Business are outside the scope.

What to do with it. Revenue decides the row, not headcount or entity count, so a group whose UAE companies straddle AED 50 million runs two go-live dates six months apart over one chart of accounts. Ask a vendor which cohort its delivery capacity is booked against, because the first one is already inside a quarter.

An invoice reaches the tax authority through an accredited provider rather than directly, and the Ministry accredits those providers under Ministerial Decision No. 64 of 2025. Its amendment announcement records the "extension of the deadline for the appointment of an Accredited Service Provider (ASP) from 31 July 2026 to 30 October 2026", with entities in that cohort "required to fully implement the eInvoicing system by no later than 1 January 2027" where "annual revenues exceed AED 50 million". The same notice put the count at "32 Service Providers have already been approved, with a significant number of additional providers currently in the final stages of the accreditation process".

What to do with it. The guidelines table still prints 31 July 2026, so read the ministerial amendment after it and treat 30 October 2026 as the operative date. And keep two registers apart: a system listed by the Federal Tax Authority as tax accounting software is not thereby an accredited service provider, and only the second can put the invoice on the network.

In the Ministry's words, "Electronic Invoices are issued, transmitted and received in XML format and will not feature a Quick Response Code (“QR code”) or barcode", with the contents set by "Peppol’s PINT-AE billing specifications". The exchange has five corners (supplier, supplier's provider, recipient's provider, recipient, and the Federal Tax Authority as Corner 5), and it is the providers, not the supplier, that report tax data to the authority. The framework "is designed to support both the Arabic and English languages".

What to do with it. The question to put to a ledger is whether it emits PINT-AE XML itself or hands a provider enough structured data to build it; a PDF rendering pipeline is the wrong shape here. Note also what the UAE does not want: no QR code on the invoice, which is the opposite of the Saudi requirement next door.

"In line with Article 3(1) of the Tax Procedures Executive Regulation, data relating to the issuance, transmission and receipt of Electronic Invoices must be retained": five years following the tax period it relates to for a Taxable Person, five years from the end of the calendar year of creation for other Persons, and seven years for real estate records, with a further four years where there is a dispute with the authority.

What to do with it. Retention falls on whoever holds the XML, and under a five-corner model that may be the provider rather than the ledger. Ask where cleared invoices are archived, in what format they come back, and what happens to the archive when the provider contract ends.