The eInvoicing framework is a decentralized 5 corner model. The Service Provider will validate all data fields and report the data to the Federal Tax Authority (FTA) / the Ministry of Finance (MoF).
There are two components in this model: (1) exchange and (2) reporting. A Service Provider shall validate all the fields of an eInvoice based on the UAE data dictionary before exchanging the invoice over the Peppol network. Subsequently all the tax data fields in a invoice shall be reported to the FTA system (Corner 5)

Businesses in the UAE shall be required to engage with an Accredited Service Provider to issue and receive an eInvoice.
The electronic address (End point) of the buyer would be used for sharing the invoice over the Peppol network.

Yes, an invoice can contain taxable transactions, along with exempt or out of scope transactions.

Each member of the VAT group must have an endpoint via a UAE Accredited Service Provider.

Each member of the VAT group should have an endpoint via a UAE Accredited Service Provider. When issuing an invoice, the group’s Tax Registration Number (TRN) should be provided, but the endpoint details should correspond to the specific group member conducting the transaction.

In case of exports, if the foreign buyer is already registered within the Peppol network, then the end point (electronic address) of the buyer is required to be provided. If they are not registered, then a dummy end point will be provided. In such cases exchange of document will not happen via the Peppol network, however, the Corner 2 (SP of seller) will continue to report the invoice to Corner 5. The seller is required to send the invoice to the buyer outside the network such as via email.
It is not mandatory for the overseas buyer to register with a UAE Accredited Service Provider if he is not obligated to do so as per the UAE VAT and Corporate Tax law.

It is proposed to be a near real time integration between businesses and UAE Accredited Service Providers.

In case of self-billing the buyer (customer) should create the eInvoice and will exchange the document with the seller and will also report to the Federal Tax Authority via the Accredited Service Provider.

Should there be an issue with the invoice, the Accredited Service Provider shall return the invoice to the issuer.

The invoice has to be exchanged between the seller and the buyer via an Accredited Service Provider who would transmit the invoice in the form of an XML and the Service Provider will also report the invoice data to the Federal Tax Authority.

The business should analyze their transactions and the resulting invoicing data against the data dictionary and ensure that they are compliant.
Once the list of Accredited Service Providers is published by the Ministry of Finance, the businesses need to enter into a commercial arrangement with one of them and work on the integration between their systems to transmit the invoice.

The eInvoicing framework encompasses all business-to-business (B2B) and business-to-government (B2G) transactions, regardless of the VAT registration status of the entities involved.

1. The interface between C1 to C2 and C3 to C4 is not regulated by the Ministry of Finance (MoF) or the Federal Tax Authority (FTA). It is subject to the arrangements made between the businesses (seller, buyer) and their Accredited Service Providers (ASPs). Typically, their integration would be based on Application Program Interfaces (APIs), web interfaces, or SFTP/ETL methods.
2. The interface between C2 to C3 is regulated by Peppol and utilizes the AS4 protocol.
3. The connection between C2 to C5 is regulated by the MoF/FTA and utilizes the Peppol AS4 protocol.

The businesses are not required to interact directly with the UAE Peppol Authority. Instead, the Accredited Service Provider (ASP) will liaise with the UAE Peppol Authority on their behalf.

Businesses that are onboarded to the eInvoicing platform will be listed in the Peppol directory. The URL to access the Peppol directory will be made available on the websites of the Federal Tax Authority /Ministry of Finance.

No, there is no proposal in place for any inquiry of invoices from C1 to C5 or from C3 to C5.

Only an Accredited Service Provider (ASP) can exchange and report invoices. Those who intend to be an ASP shall strictly adhere to the UAE Accreditation Procedures (yet to be published) and all the underlying requirements including the Service Level Agreements that need to be adhered to. Even if a business would like to be an ASP, as part of the eInvoicing exchange, it is important to acknowledge that the eInvoice data still needs to be shared with the buyer’s ASP.

The first list of Accredited Service Providers will be published in due course.

Actual exchange of eInvoicing can start without the legislation and the 5th corner. You can join the pilot from the moment there are Accredited Service Providers and your business is ready to exchange eInvoices.

There will be a testing phase before going live with Accredited Service Providers and the Federal Tax Authority platform to ensure there are no issues during the exchange.

Yes, payment due date should be mentioned even if the payment is on the spot. The due date will be the same as the invoice date.

We are still working on the rollout strategy, but it will be a phased implementation, with businesses implementing at prescribed stages according to specific criteria and adequate notice shall be provided in advance of the requirements coming into effect.

It will be the Tax identification number (TIN) which is the first 10 digits of the Tax registration number (TRN) issued to the business. For the businesses which are not registered with the FTA (i.e. they don’t have a TRN), they would need to register with the FTA to get a TIN.

Yes, he the buyer has to be onboarded to an Accredited Service Provider.

In case of any errors in tax invoices, a credit note is required to be issued for its rectification.

It is the obligation of the seller (UAE business) to ensure that the eInvoice generated is compliant to the UAE PINT framework and the eInvoice is reported to the Federal Tax Authority through their Accredited Service Provider. The transmission of the invoice to the buyer can be managed outside the Peppol network wherein the seller can generate a PDF and transmit to the buyer (overseas business in a non-Peppol compliant country).

Accredited Service Providers (ASPs) will report eInvoices of taxpayers to the Corner 5 Access Point (Central Data Platform) via Peppol AS4 standards (not using APIs).

A similar approach shall be followed by the ASPs to report periodic Key Performance Indicators (KPIs) that are mandated by the FTA.

The invoice has to be exchanged between the seller and the buyer via an Accredited Service Provider (ASP) who would transmit the invoice in the form of an XML and the ASP will also report the invoice data to the FTA.

The business should analyze their transactions and the resulting invoicing data against the data dictionary and ensure that they are compliant.
Once the list of Acredited Service Providers (ASPs) is published by MoF – the businesses need to enter into a commercial arrangement with an ASP and work on the integration between their systems to transmit the invoice.

The authentication process between C2 and C3 will adhere to Peppol standards and will be managed by the Accredited Service Provider.

The authentication method between C2 – C3, C2 – C5 will adhere to Peppol AS4 standards.

AS4 is used in the Peppol network for transmission of asynchronous messages (e.g. an eInvoice) between Corner 2 and Corner 3, Corner 2 and Corner 5 using the Peppol PKI for signature and encryption on AS4 message level and SMP/SML for dynamic discovery.

Yes, there are standard procedures that Accredited Service Providers will have to adhere to. In addition there will be periodic audits that will be performed.

Yes, in addition to the data hosting requirements as mandated by the respective regulators of the taxpayers/businesses, it is important to consider the UAE National Cloud Security Policy when adopting any cloud solution.

The exchange of eInvoices between the seller and buyer will be carried out in XML format and it will not involve any PDFs. It is pertinent to mention that these XML would be encrypted and will follow the industry standard security protocols.

Taxpayers are required to adhere to data protection and security standards that are mandated by the regulators of the respective sectors. In addition to this Accredited Service Providers will need to follow the data protection guidelines as esablished by the UAE Peppol Authority.