FAQs
Here you can get answers to the most common questions on the topic of eInvoicing
The eInvoicing framework is a decentralized 5 corner model. The Service Provider will validate all data fields and report the data to FTA/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 an invoice shall be reported to the FTA system (Corner 5)
Businesses in the UAE must engage with an Accredited Service Provider to issue and receive eInvoices. The buyer’s electronic address (endpoint) will be used to share 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 eInvoicing 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 FTA 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 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 Accredited Service Providers is published by MoF, 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 Peppol 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 FTA/MOF.
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 can exchange and report invoices. Those who intend to be an Accredited Service Provider shall strictly adhere to the UAE Accreditation Procedures (yet to be published) and all the underlying requirements including the SLAs that need to be adhered to. Even if a business would like to be an Accredited Service Provider, as part of the eInvoicing exchange, it is important to acknowledge that the eInvoice data still needs to be shared with the buyer’s Accredited Service Provider.
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 FTA 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 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 FTA 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 none Peppol compliant country).
Currently, the scope of UAE eInvoicing includes only B2B and Business-to-Government (B2G) transactions. However, if a taxpayer wishes to issue B2C invoices through the eInvoicing network, this can be decided between the taxpayer and their Accredited Service Provider, but such invoices should not be reported to Corner 5.
B2C transactions are not currently within the scope of UAE eInvoicing.
There is no requirement for QR codes to be printed on the eInvoices.
There are no additional requirements beyond those supported by Peppol
The legislation will be released first, followed by information on the accreditation process. Service providers can then submit their applications for accreditation. Once they meet all requirements, including testing with Peppol and the FTA’s Emaratax system, they will be listed as accredited service providers on the MoF and FTA websites.
For the end-user onboarding pilot testing, the MoF is seeking Taxpayers who are already using service providers to issue eInvoices. An existing combination of the taxpayer and service provider is required for testing.
The legislation is currently being finalized, with the majority expected to be issued in March. These changes will enable eInvoicing and are not material changes. The rollout of eInvoicing will not follow a big bang approach, ensuring flexibility for companies issuing eInvoices and those using traditional methods. Provisions have been introduced in the VAT law and Tax Procedures law to facilitate these changes, followed by a cabinet decision and ministerial decision detailing the requirements.
The MoF cannot impose its standards on foreign vendors, so these invoices will not be required to be sent through the UAE eInvoicing network, and there will be no additional obligation on Taxpayers to report these transactions.
Once everyone is onboarded, there will be no mechanism other than eInvoicing. As eInvoicing is rolled out, buyers and suppliers will be aware of how invoices are issued between them. When it becomes mandatory, invoices must be exchanged through the eInvoicing network. For those for whom it is voluntary, they should ideally use the eInvoicing network if they have the required capabilities. During the transition period, scenarios may arise where not all invoices are exchanged via the eInvoicing network, necessitating the preservation of all documents.
This should be discussed between the taxpayer and their service provider as part of the architecture. If the taxpayer is within the scope of eInvoicing, all B2B transactions in scope should pass through the eInvoicing network.
Credit notes are the standard mechanism to be followed. There is no concept of cancellation of an invoice.
Both the supplier’s invoice and the buyer’s invoice will be sent through the eInvoicing network. Please refer to the use cases detailed in the public consultation document for necessary clarifications. Document identifiers will help identify that they refer to the same transaction.
The accreditation procedure will be issued shortly, and service providers will be informed of the requirements to commence their applications for accreditation. Updates will be communicated through the website and direct communications
Communication will be provided regarding a dummy identifier that should be used in the case of the seller. Your Service Providers will discuss this in more detail.
Since these invoices cannot be issued through the eInvoicing network, the MoF seeks to avoid imposing additional reporting obligations for these transactions.
There are identifiers that can be discussed with the Service Providers
Yes, and the details of the rollout strategy will be announced in due course
The seller’s legal registration identifier type and buyer’s legal registration identifier type fields in the Data Dictionary will allow for capturing trade licenses, Emirates IDs, or passports for sellers/buyers without a TRN. If the contract is signed with a business, it is considered a B2B situation, and eInvoicing would apply
You can receive invoices from a foreign supplier via the Peppol network. However, the UAE’s Data Dictionary cannot be imposed on them, and you are not mandated to report this transaction through the eInvoicing system.
To issue or receive eInvoices, the seller and buyer must have an endpoint and be associated with an accredited service provider, who will work with you on the specifics of issuing and receiving eInvoices.
All mandatory business fields must be provided by the seller to the ASP. The form and structure of sharing such fields must be agreed upon with your ASP.
As defined for Corporate Tax in the UAE, a business is identified by its Tax Identification Number (TIN).
Arabic is not mandatory; e-Invoicing should be in English
Please refer to the UAE Tax Law for guidance on when to issue a commercial invoice
1. When a non-tax registrant generates an invoice that cannot be considered a tax invoice. 2. When a tax registrant generates an invoice related to exempt or out-of-scope transactions or for zero-rated supplies where the taxpayer is not obliged to generate a tax invoice. |
Self-billing refers to the scenario where the buyer is authorized by the seller to issue the invoice, not the reverse charge mechanism
Further legislation will clarify how commercial invoices will be treated. The eInvoicing design will ensure that only business transactions are covered by these requirements
Yes, every member of the VAT group will have their individual Tax Registration Numbers (TRNs) suspended, and a group TRN will be used. Each member will have their own Tax Identification Number (TIN), which will serve as the unique identifier for invoices.
Current legislation specifies the timeframe within which an invoice must be issued. The eInvoicing process begins once the invoice is issued.
The archiving requirements will be as per the VAT laws.
As defined for Corporate Tax in the UAE, a business is identified by its Tax Identification Number (TIN).
| 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 MoF/FTA. |
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 Accredited Service Provider 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 is published my MoF – 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 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 PA.
The data retention requirements are consistent with current law, which mandates a retention period of 7 years.
There are no data residency requirements beyond what is described in the law. However, certain sectors, such as banking and healthcare, may have their own requirements, which should be discussed between Accredited Service Providers and taxpayers.
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 PA.
The data retention requirements are consistent with current law, which mandates a retention period of 7 years.
There are no data residency requirements beyond what is described in the law. However, certain sectors, such as banking and healthcare, may have their own requirements, which should be discussed between Accredited Service Providers and taxpayers.
The expectation is that the TDD should be reported in near real-time, utilizing current technology. Batch submissions of the TDD are also permitted. Additionally, a Service Level Agreement (SLA) document will be made available to provide further details.
Yes, the TDD should be submitted separately for both Corner 2 and Corner 3.
PINT AE will cover credit notes, and there will be no direct contact between taxpayers and Corner 5. All invoices must be routed through Corner 2 or Corner 3. The 5-corner model is the only system involved, and there will be no additional centralized system.
Once the Accredited Service Provider receives the invoice from the taxpayer, they must issue it to Corner 3 and report the TDD to Corner 5. Any issues between the taxpayer and the Accredited Service Provider should be resolved between them. If any of the Corners are down, the Access Points have the capacity to store the information and issue/report it once the required access point is accessible
The protocol used for exchanging invoices between Corner 2 and Corner 3 is AS4, which complies with Peppol standards. More details will be provided once the Architecture document and the PASR are released
More details regarding this will be provided once the Architecture document and the PASR are released.
The end-to-end process will be detailed in the architecture document, which will also include the Service Level Agreements (SLAs) that must be adhered to
When a supplier sends an invoice abroad, they must report that invoice to the Federal Tax Authority (FTA). However, when receiving an invoice from abroad, there is no obligation to report it, as we cannot guarantee that all mandatory fields will be present for validation. If Corner 1 wishes to send the invoice through the UAE eInvoicing network, they may do so, but the Ministry of Finance will not mandate it.
The Access Points have storage capacity, so the TDD must be stored and sent when Corner 5 becomes available. More details will be provided once the architecture document is released.
As part of the accreditation procedure, the first requirement is to be a Peppol Service Provider and conform to Peppol’s standards. Therefore, one cannot be an Accredited Service Provider without having their solution validate the UAE standard Data Document (DD).
The architecture document is expected to be published within a few weeks.
Corner 5 has been expanded to include a Peppol access point and a central data platform. Like Corner 2 and Corner 3, Corner 5 will perform schematron validation. If any issues are encountered, a message will be sent to Corner 2 and/or Corner 3. The model remains an exchange and reporting model, with Corner 5 simplifying the reporting of tax data to the FTA.
Corner 5 will employ similar technology to Corner 2 and Corner 3. Validation will be performed in near real-time upon receiving tax data from Corner 2 or Corner 3, returning a passed/failed message that can be communicated back to the buyer and/or supplier.
The buyer can reject the invoice based on commercial reasons. Rejections by Corner 2, Corner 3, or Corner 5 are based solely on technical schematron validations, and there would be no change in accounting and business practices.