Customers Abroad, Exempt Supplies, Marketplace Sellers: Does E-Invoicing Apply?

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Short answer

Usually yes. UAE e-invoicing covers every business transaction you make with a business or government customer, not only sales that carry VAT: exports to businesses abroad, exempt supplies and out-of-scope supplies all need an e-invoice. What stays outside: sales to individual consumers (including through Amazon or noon), exempt and zero-rated financial services, and services or goods you import under the reverse charge. Under AED 50 million revenue, appoint an accredited service provider (ASP) by 31 March 2027 and go live on 1 July 2027.

General guidance from the Ministry of Finance decisions and guidelines, not tax or legal advice. For your situation, check with the FTA or a qualified tax advisor.

The rule: every business transaction

Ministerial Decision No. 243 of 2025 applies to anyone doing business in the UAE "in respect of every Business Transaction", unless the person or the transaction is excluded (Art. 3). The test is who your customer is and what the transaction is, not whether it carries 5% VAT and not whether you are VAT-registered (Guidelines §6.1). The exclusions are a short, closed list (Art. 4, as replaced by Ministerial Decision No. 197 of 2026), and sales to consumers are kept out separately (Ministerial Decision No. 244 of 2025, Art. 5(2)).

Situation by situation

Your situationE-invoice?How
Export of goods or services to a business abroadYesExport scenario; buyer not on Peppol: 0235:9900000099 (Guidelines §10.4).
Business customer abroad, but the sale is not an exportYesBuyer not on UAE e-invoicing: 0235:9900000098. Don't flag it as an export just because the buyer is abroad (§18.2.3).
Individual consumer, in the UAE or abroadNoSales to people not in business are outside e-invoicing for now.
Exempt supply to a business (for example bare land, local passenger transport)YesExempt tax category, with an exemption reason code on each exempt line.
Exempt or zero-rated financial servicesNoExcluded transaction (Art. 4(1)(e)).
Supply outside the scope of UAE VAT, to a businessYesOut-of-scope invoice type, only when every line is out of scope (§18.3.1).
You are not VAT-registered and sell to businessesYesCommercial e-invoice with your 10-digit TIN (§10.2.1, §18.1.1).
Services or goods you import and reverse-chargeNoNo e-invoicing requirement on the import (§10.5).
Sales between members of your VAT groupNot yetExcluded for 24 months from 1 January 2027 (Art. 4(1)(f)).

Other exclusions are narrow: sovereign activities of government bodies, international passenger flights with an e-ticket, and air cargo with an airway bill for 24 months (Art. 4(1)).

Customers outside the UAE

An export is one of the eight e-invoice scenarios in the MoF guidelines, with examples such as a wholesaler selling to a retailer in Kuwait and an IT firm building software for a client in France (§10.4, scenario 8). Your tax invoice for the export is the e-invoice, sent through your ASP and reported to the FTA. A foreign customer usually has no UAE Peppol ID, so:

  • Export, buyer not on Peppol: address it to the placeholder 0235:9900000099.
  • Buyer abroad, but not an export (the export conditions are not met): use 0235:9900000098. The export flag is for transactions that meet the export conditions, not for every foreign buyer (§18.2.3, §18.3.3).
  • Their details: their foreign tax number where they have one, and a VAT number only if one applies to the transaction (§18.2.3).

E-invoicing does not change the VAT: whether the sale is zero-rated is still decided by the VAT rules, see do I charge VAT to a client outside the UAE. Your foreign customer will still want a readable invoice, such as a PDF. Goods shipped from one foreign country to another without entering the UAE are classified as an out-of-scope transaction (§18.3.2).

Exempt and out-of-scope supplies

Exempt and out-of-scope sales are business transactions, so they need e-invoices too. The MoF guidelines call an invoice for sales that need no tax invoice a commercial invoice, and say paper and PDF commercial invoices must be replaced by e-invoices (§10.2.1). What changes is how the e-invoice is filled in:

  • Each line carries its tax category: standard, zero-rated, exempt, out of scope, reverse charge or margin scheme (§10.5). Exempt lines need an exemption reason code (IBR-167-AE).
  • A TRN is not mandatory on commercial invoices or for out-of-scope and exempt transactions (§12.2).
  • The out-of-scope invoice type is only for invoices where every line is outside VAT, never for exempt or zero-rated supplies (§18.3.1). Taxable and non-taxable lines can share one invoice (§10.2.2).
  • The one exempt category that is excluded is financial services that are exempt or zero-rated (Art. 4(1)(e); §7.3). Financial services that would be standard-rated at home stay in scope even when exported.

Selling through Amazon, noon or your own store

A marketplace changes the channel, not the rule. What decides it is who buys:

  • Only individual consumers: a business that makes only sales to consumers is outside e-invoicing until the Minister decides otherwise, so you need no ASP for now (Ministerial Decision No. 244 of 2025, Art. 5(2)). The guidelines say the same applies where a billing agent invoices or collects for the sale (§6.2).
  • Some buyers are businesses: those sales are in scope and you need an ASP. A company ordering without giving a TRN can still be a business buyer. The e-invoice stays your responsibility even if the platform issues invoices for you (§10.4, scenario 7).
  • The platform's fees to you: when the platform is a UAE business, its commission invoices to you are its own e-invoices. If you are consumer-only and outside the system, you get an ordinary tax invoice alongside them, as any buyer not on e-invoicing does (§10.2.2). More in I only receive invoices: do I need an ASP?

Selling on your own website: the same test, see step 5 of how to start selling online in the UAE.

What you buy from abroad

Importing services or goods that you account for under the reverse charge, such as software subscriptions or advertising from a foreign company, has no e-invoicing requirement (§10.5). Your foreign supplier is not in the UAE system, and you report the VAT on your return as before (reverse charge for small businesses). The domestic reverse charge is different: sales of mobile phones, precious metals or scrap between UAE registrants are e-invoiced, with the buyer's TRN (IBR-103-AE).

Dates and fines

Revenue under AED 50 million: appoint an ASP by 31 March 2027, go live on 1 July 2027. AED 50 million or more: live from 1 January 2027. Government entities: from 1 October 2027. Exports and exempt supplies follow the same dates as the rest of your sales. The decisions do not set a separate penalty for appointing an ASP late. For businesses under AED 50 million, per-invoice penalties apply from 1 July 2027: AED 100 for each e-invoice or e-credit note not sent through the system, up to AED 5,000 a month (Cabinet Decision No. 173 of 2026). Compare providers on the accredited ASP list; collect your customers' details with what customer details an e-invoice needs; still unsure you are in scope? See do I need e-invoicing for my small business.

How Fatura Go helps with e-invoicing for exports, exempt supplies and marketplaces

  1. 1. Keep the records

    UAE VAT law requires invoices and VAT records to be kept for at least five years. Fatura Go keeps issued invoices, credit notes, expenses and bills in one place, with each receipt attached to its expense. Each invoice line keeps its VAT treatment, so the record shows why a sale was zero-rated, exempt or out of scope.

  2. 2. Prepare for e-invoicing

    Mark each line as standard-rated, zero-rated or exempt, and the e-invoicing checklist shows which business and client details are still missing.

  3. 3. Get help

    Need an accountant to check your records before e-invoicing starts? Leave a request with Fatura Go support and say what you need. If you already work with an accountant, invite them to your account with their own login.

Fatura Go is invoicing software for UAE VAT. It is not an accredited service provider. We'll get you ready and connect you through an accredited partner. What you can use today:

  • Client TRN and Peppol check. Check a client's TRN and whether they are listed on Peppol with the free TRN checker.
  • The ASP register. The full list of accredited providers, compared with the Ministry of Finance register every week.
  • Credit notes. Corrections, discounts and refunds are issued as credit notes against the original invoice, the way e-invoicing expects them.
  • Zero-rated, exempt and out-of-scope lines. Each invoice line carries its VAT treatment, and the VAT report keeps out-of-scope sales off the FTA return.
  • Shopify orders. The Fatura Go Shopify app turns each paid order into a tax invoice and each refund into a credit note, and issues a full tax invoice when the buyer gives a TRN.

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Frequently asked questions

Do invoices to customers outside the UAE go through e-invoicing?

Yes, when the customer is a business. An export of goods or services is an e-invoice scenario of its own: you send it through your accredited service provider and, if the customer is not on Peppol, address it to the placeholder 0235:9900000099. Invoices to individual consumers abroad are outside e-invoicing, like all sales to consumers.

My supplies are VAT-exempt. Do I still issue e-invoices?

Yes, for business customers. E-invoicing covers every business transaction, not only sales that carry VAT; exempt and out-of-scope sales go on an e-invoice with the matching tax category, and exempt lines carry an exemption reason code. The exception is financial services that are exempt or zero-rated: those are excluded.

I sell through marketplaces like Amazon. Do I need an ASP?

Not if every sale is to an individual consumer: a business that makes only sales to consumers is outside e-invoicing until the Minister decides otherwise. If any of your buyers are businesses, those sales are in scope and you need an accredited service provider, by 31 March 2027 if your revenue is under AED 50 million. The e-invoice stays your responsibility even if the platform issues invoices for you.

Do I need e-invoicing if I am not VAT-registered?

Yes, if you sell to businesses or government. E-invoicing applies regardless of VAT registration; you issue a commercial e-invoice with your 10-digit TIN instead of a TRN.

Do services I buy from abroad need an e-invoice?

No. Imports of services and goods that you account for under the reverse charge have no e-invoicing requirement. Your foreign supplier is not in the UAE system, and you keep reporting the VAT on your return as before.

Deadlines, fines and the full checklist: UAE e-invoicing hub.