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Every business in scope of UAE e-invoicing must exchange and report its e-invoices through an Accredited Service Provider (ASP). Businesses with revenue below AED 50 million must appoint one by 31 March 2027 and go live by 1 July 2027 (see the full timetable and penalties). In October 2026 the Ministry of Finance changed how providers are accredited and published practical guidance on choosing one.
In short: Ministerial Decision No. 168 of 2026, in force since 1 October 2026, sets the rules a provider must meet to be accredited. Among them, an ASP must hold ISO/IEC 27001 certification for its product, carry professional indemnity, crime and cyber fraud insurance, and commit to 100 free e-invoice exchange and reporting services a year for each customer. On 28 October 2026 the Ministry also published a checklist of questions to ask a provider, and the mandatory fields every e-invoice must carry.
The accreditation rules
Ministerial Decision No. 168 of 2026 replaces Ministerial Decision No. 64 of 2025 and its amendments. The Ministry says it removes the earlier pre-approval stage: providers must now pass the accreditation assessment and tests before they are accredited. Only an accredited provider may offer e-invoicing services in the UAE.
| Requirement | What the decision says |
|---|---|
| Peppol | An active Peppol-certified provider that has passed the OpenPeppol conformance tests, with a product that meets the UAE specification (PINT AE) |
| Experience | The product has been in operation for at least two years. A provider may use a third party's product or outsource parts of the service, but stays fully responsible |
| Company | Licensed to do business in the UAE, paid-up capital of at least AED 50,000, audited financial statements, and ISO 22301 business continuity certification |
| Security | Multi-factor authentication, encryption of data in transit and at rest, regular security monitoring, ISO/IEC 27001 certification for the product, and compliance with each customer's own hosting and data residency rules |
| Insurance | Professional indemnity of at least AED 2.5 million, crime cover of AED 5 million and cyber fraud cover of AED 5 million |
| Free allowance | 100 free e-invoice exchange and reporting services a year for each customer, from the date the customer's agreement is signed |
| Validity | Two years. A renewal application is due at least 70 business days before expiry |
| Old pre-approvals | Providers pre-approved under the 2025 decision had up to 30 days from 1 October 2026 to complete accreditation, or lose the pre-approval |
The practical point: before you sign, confirm that the provider appears on the Ministry of Finance's published list of Accredited Service Providers.
The Ministry's checklist for choosing a provider
The Ministry's Considerations for Selecting an Accredited Service Provider (version 1.1, 28 October 2026) groups its questions under experience, product, integration, security, support, pricing and scalability. Put these to each provider on your shortlist:
- How long has it provided e-invoicing services, and been a Peppol Service Provider? When was it accredited in the UAE?
- Is the e-invoicing system its own product or a third party's, and will it support you directly or through a subcontractor?
- Can it integrate with your ERP, accounting or billing system? Ask about APIs, data formats and integration support
- How will it support keeping e-invoices, credit notes and their data for the period the Tax Procedures Law requires, and producing them for the Federal Tax Authority on request?
- Which certifications does it hold, and how does it protect your data: encryption, access controls and incident response?
- What are its support response times, and does it commit to uptime in a service level agreement?
- What is the pricing model (subscription or per transaction), how does the 100 free services a year apply, and are there any other fees?
- Can the system grow with your volumes, and what is on its product roadmap?
Get your invoice data ready
The Ministry's list of UAE Electronic Invoice Mandatory Fields (version 1.1, 28 October 2026) highlights some points that catch businesses out:
- E-invoicing applies to any person conducting business in the UAE, whether or not it is registered for VAT, unless specifically excluded under Article 4 of Ministerial Decision No. 243 of 2025 as amended.
- Your e-invoicing identifier is based on your Tax Identification Number (TIN), the first 10 digits of your Corporate Tax TRN. A business in scope that does not have to register for Corporate Tax must register with the FTA to get a TIN.
- Members of a VAT tax group use their own TIN, not the representative member's.
- A tax invoice has 51 mandatory fields and a commercial invoice 49. They include the buyer's electronic address and identifier, codes for transaction types such as free zone, deemed supply, margin scheme, continuous supply, e-commerce and exports, and, on a tax invoice, the VAT and the amount of each line in AED.
What to do now
- Confirm your revenue group and the dates that apply to you
- Shortlist two or three providers from the Ministry's list of ASPs and put the Ministry's questions to each
- Ask for evidence: accreditation date, ISO/IEC 27001 certificate and the service level agreement
- Check that your ERP or billing system can produce every mandatory field, and collect customers' TINs and electronic addresses
- If you are in scope but not required to register for Corporate Tax, register with the FTA for a TIN
- Below AED 50 million: sign with your ASP by 31 March 2027 and leave time to test before 1 July 2027
How Veridian can help
Our tax and IT consulting teams help UAE businesses compare providers against the Ministry's criteria, map ERP data to the mandatory fields and plan testing before go-live. Where a filing or registration with the FTA is needed, it is handled by locally licensed professionals. Book a consultation to plan your move to e-invoicing.
Official sources
- UAE Ministry of Finance — Ministerial Decision No. 168 of 2026 on the Eligibility Criteria and Accreditation Procedure for Service Providers under the Electronic Invoicing System
- UAE Ministry of Finance — Ministry of Finance issues decision on accreditation of eInvoicing Service Providers, 9 October 2026
- UAE Ministry of Finance — Considerations for Selecting an Accredited Service Provider, version 1.1, 28 October 2026
- UAE Ministry of Finance — UAE Electronic Invoice Mandatory Fields, version 1.1, 28 October 2026
- UAE Ministry of Finance — eInvoicing: list of Accredited Service Providers, guidelines and legislation
Frequently asked questions
Do UAE e-invoicing providers have to offer free e-invoices?
Yes. Under Ministerial Decision No. 168 of 2026, an Accredited Service Provider must commit to providing 100 free e-invoice exchange and reporting services a year to each customer, starting from the date the customer's agreement is signed.
How can I check that an e-invoicing provider is accredited in the UAE?
The Ministry of Finance publishes the list of Accredited Service Providers on its eInvoicing page. Only accredited providers may offer e-invoicing services in the UAE.
Do I need e-invoicing in the UAE if I am not registered for VAT?
Possibly. The Ministry says e-invoicing applies to any person conducting business in the UAE regardless of VAT registration, unless specifically excluded. A business in scope that is not required to register for Corporate Tax must register with the FTA to get a Tax Identification Number.
This guide is general information based on the law as we understand it on the date shown, not advice for your situation. Tax rules change often — please speak to us before acting on it. See our disclaimer.