UAE E-Invoicing Deadline for Businesses Under AED 50 Million: Checklist to 1 July 2027
Last updated:
Short answer
If your annual revenue is under AED 50 million and you invoice businesses or government, you must appoint an accredited service provider (ASP) by 31 March 2027 and send those invoices as e-invoices from 1 July 2027 (Ministerial Decision No. 244 of 2025, Art. 5(1)(b); unchanged by Ministerial Decision No. 66 of 2026). Before you can appoint, you need a signed contract; before you go live, your customers' TRNs and Peppol IDs, complete invoice fields and a tested set-up.
136 days to the ASP deadline, 228 days to go-live.
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 dates
Your phase depends on your own Revenue, not your customers'. You can start voluntarily at any time since 1 July 2026 (Art. 4). New businesses set up after their phase has started must onboard before their first invoice (Guidelines §8.4).
| Who | Appoint an ASP | Go live | Source |
|---|---|---|---|
| Annual revenue ≥ AED 50 million | Passed — 30 October 2026(extended from 31 July 2026) | 1 January 2027 | Ministerial Decision No. 244 of 2025, Art. 5(1)(a); Ministerial Decision No. 66 of 2026 |
| Annual revenue below AED 50 million | By 31 March 2027 | 1 July 2027 | Ministerial Decision No. 244 of 2025, Art. 5(1)(b) |
| Government entities | By 31 March 2027 | 1 October 2027 | Ministerial Decision No. 244 of 2025, Art. 5(1)(c) |
| Businesses set up after their phase has started | Before the first invoice | From the first invoice | Ministerial Decision No. 244 of 2025, Art. 5(1)(d); MoF Guidelines v2.0, §8.4 |
| B2C only (sales to individual consumers) | Not yet announced(out of scope until a Minister's decision) | Not yet announced | Ministerial Decision No. 244 of 2025, Art. 5(2) |
| Voluntary adoption (any business) | — | From 1 July 2026 | Ministerial Decision No. 244 of 2025, Art. 4 |
Dates are from Ministerial Decision No. 244 of 2025 and Ministerial Decision No. 66 of 2026, which moved the AED 50M+ appointment deadline and left every other date unchanged, as published by the UAE Ministry of Finance. Revenue means gross income in your most recent accounting period (Art. 1). A business that invoices government (B2G) follows its own revenue row; the government row is for government entities themselves. "Not yet announced" means the MoF has not published a date. Last checked 1 November 2026.
Checklist to 1 July 2027
In order, following the MoF Guidelines v2.0 (Chapter 13). Section numbers refer to the guidelines.
Now, before 31 March 2027: get your data ready
- Confirm you are in this phase. You invoice businesses or government, and your Revenue (gross income in your most recent accounting period, from your financial statements) is under AED 50 million. Selling only to consumers? You are out for now. Check with the readiness checker.
- Check your own details in EmaraTax. Trade licence, address and contacts must be up to date before you onboard (Guidelines Appendix 3). No TRN? Generate a TIN in EmaraTax; if you have a TRN, your TIN is its first 10 digits (§13.2).
- Collect each business customer's TRN and Peppol ID. For every business and government customer: legal name, TRN (or TIN), and a structured address (street, city, emirate, country). Their Peppol ID is 0235 followed by their 10-digit TIN. Getting it is your job as the supplier (Guidelines §5.2). Check TRNs with the TRN checker. The full list, and the rules that reject e-invoices: what customer details an e-invoice needs.
- Check your invoice fields. An e-invoice carries every detail in a fixed field: buyer TRN and address, item lines, VAT rates and amounts, currency. If you invoice from Word or Excel, move to software that keeps this data. The full list: PINT AE mandatory fields.
- Decide who does what. The EmaraTax account admin starts onboarding (§13.2). Name who sends invoices, who fixes rejected ones, who handles incoming supplier invoices, and who tells the ASP when your FTA details change (5 business days, or AED 250 a day).
- Count your invoices. How many invoices and credit notes you send to businesses and government in a year, and how many you receive. ASP prices depend on it.
By 31 March 2027: appoint your ASP
- Shortlist and sign. Compare providers on the accredited ASP list. You must finish the contract and its commercial terms before you can onboard (§13.2), so do not leave it to the last week.
- Onboard through EmaraTax. Open the E-Invoicing tile, choose your ASP and continue in its portal. You get your Peppol participant ID through the ASP. One ASP covers both sending and receiving (§6.1).
April to June 2027: test
- Agree the set-up with your ASP. How your invoice data reaches them, how you get confirmations back, and how supplier invoices reach you (§13.3).
- Test end to end. Send a test invoice, receive the confirmation, receive a supplier invoice, and check the FTA reporting confirmation. Agree how errors are fixed (§13.4). You may also start sending for real early: voluntary e-invoices carry no e-invoicing fines.
From 1 July 2027: live
- Every business and government invoice is an e-invoice. Credit notes too. VAT-registered: the VAT law timeline, a tax invoice within 14 days of the supply and a credit note within 14 days of the event (Art. 6(4)). Not VAT-registered: within 14 business days from the date of the transaction (Art. 6(5) as amended by Ministerial Decision No. 197 of 2026). A PDF alone no longer counts (PDF invoices after July 2027).
- Customers not on e-invoicing yet. Still send the e-invoice, addressed to the placeholder 0235:9900000098, and give them an ordinary tax invoice, such as a PDF, as well (§10.2.2).
Customer data: TRN and Peppol ID
This is the step that takes longest, because it depends on your customers. Each e-invoice is addressed to the buyer's Peppol ID, so your ASP can deliver it to the buyer's ASP. For a UAE business that is 0235 plus the first 10 digits of its TRN, or its TIN if it has no TRN (PINT AE vs Peppol). Ask every business customer to confirm their TRN, legal name and address now, and when they expect to go live. A customer that is not on e-invoicing yet does not stop you: you send to the placeholder address and add a PDF tax invoice.
Don't forget receiving
From 1 July 2027 your suppliers' e-invoices reach you through the same ASP, and recipients can be fined too. Large suppliers go live on 1 January 2027; until you are onboarded they send you a PDF tax invoice as well. More in I only receive invoices: do I need an ASP?
Fines, and when they start
Under Cabinet Decision No. 173 of 2026, not implementing e-invoicing costs AED 5,000, then AED 5,000 for each month it continues, up to AED 50,000 in any 12 months.
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). Invoices you send voluntarily before your mandatory date carry no e-invoicing fines (Art. 2(2); Guidelines §8.2 and §11). You still cannot send or receive e-invoices without an ASP, so appoint one by 31 March 2027 as the decision requires.
How Fatura Go helps with the e-invoicing deadline under AED 50 million
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. The client TRNs and addresses you collect before go-live stay on each client record.
2. Prepare for e-invoicing
Your invoices carry the details an e-invoice needs, and the e-invoicing checklist shows which business and client details are still missing. Appointing an accredited service provider in EmaraTax is your own step, by your deadline.
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.
Join the e-invoicing waitlist
We'll email you when you can send and receive e-invoices from Fatura Go through our accredited partner. No newsletter.
Frequently asked questions
What is the e-invoicing deadline for businesses under AED 50 million?
Appoint an accredited service provider by 31 March 2027 and send invoices to businesses and government as e-invoices from 1 July 2027 (Ministerial Decision No. 244 of 2025, Art. 5). Ministerial Decision No. 66 of 2026 changed only the deadline for businesses with AED 50 million or more.
I'm below AED 50m — any reason to act before March 2027?
Nothing is required before 31 March 2027, but you must sign the contract before you can onboard, collecting every business customer's TRN and Peppol ID takes time, and you need time to test. You can also start voluntarily now; voluntary e-invoices carry no e-invoicing fines.
Can I appoint an ASP now but start later?
Yes. Appointing and onboarding are due by 31 March 2027; sending e-invoices is required from 1 July 2027. In between you can test or send voluntarily. Note that the 100 free exchanges a year every provider must give start counting from the date you sign, so check when billing starts too.
When do penalties start?
Only from your own mandatory dates; voluntary e-invoices carry none (Cabinet Decision No. 173 of 2026, Art. 2(2)). 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). You still need an ASP appointed by 31 March 2027, as Ministerial Decision No. 244 of 2025 requires, to send and receive e-invoices from go-live.
What counts as AED 50 million revenue?
Revenue is your gross income in your most recent accounting period, from your financial statements, or from other records the FTA accepts if you have none (Ministerial Decision No. 244 of 2025, Art. 1).
Still deciding whether it applies to you? Read do I need e-invoicing for my small business. The one-page PDF checklist is in the UAE e-invoicing hub.