The problem these solve
Peppol is a routing network. Every document needs a destination, and that destination is the buyer's participant identifier — in the UAE, 0235:<buyer TRN>.
But plenty of legitimate UAE invoices have no buyer you can route to. A deemed supply has no external buyer at all. An overseas customer is not on Peppol. A domestic customer may simply not have onboarded yet, because their mandate wave has not arrived. The invoice still has to reach the Federal Tax Authority.
The Ministry of Finance solved this with three fixed receiver addresses. A document sent to one of them is reported to the FTA rather than delivered to a counterparty.
0235:9900000097 — Deemed supply
Used for supplies made without consideration: gifts above the threshold, private use of business assets, and similar transactions where VAT is due but no customer is being billed.
The Guidelines are unusually direct about this one: the buyer electronic address should always be 0235:9900000097, and the value does not change based on the identity of the supplier. There is nothing to look up and nothing to configure per transaction.
0235:9900000098 — Buyer not yet on the network
Used when the buyer has no participant identifier because they have not implemented electronic invoicing yet — either they are in a later mandate wave, or they have not onboarded voluntarily.
Two things are commonly misunderstood here.
First, this address is defined by onboarding status, not by VAT scope. It is tempting to read "out of scope" into the label, but a supply that is genuinely out of scope or exempt is expressed through the tax category code on the invoice, not through the receiver address. The two are independent: an exempt supply to an onboarded buyer goes to that buyer's real participant ID with category E.
Second, using this address does not discharge your obligation to the customer. They still need an invoice they can actually read, so a conventional invoice must be issued alongside the electronic one.
0235:9900000099 — Exports
Used for export transactions where the overseas buyer has no Peppol identifier, which is most of them today.
An export carries more than just a different receiver. It needs a complete delivery address block with a destination country that is not the UAE, and a transaction type code that marks it as an export. Zero-rating is applied through the tax category, normally Z. Getting the receiver right while leaving the delivery block incomplete is one of the more common export rejections.
What to expect back
These are not real participants, so two things differ from an ordinary send.
The participant registration check is skipped — there is no directory entry to look up, and a system that checks anyway will report the address as unregistered and may refuse to send.
The status that comes back is reported, not delivered. Both are successful outcomes. Teams new to this often treat a reported status as a partial failure and start investigating; it is worth explaining the difference to your finance team before go-live rather than after the first month-end.
Getting it right in your ERP
The practical implication is that the receiver address cannot be a single global setting. It has to be driven from the customer record or the document, because the same company will produce all three kinds of transaction.
The pattern that works is to classify each customer — domestic and onboarded, not yet onboarded, export, or a dedicated record for deemed supply — and derive the receiver from that classification. Exports can usually be detected automatically from the ship-to country, but the other two need an explicit flag.
Reference
UAE Electronic Invoicing Guidelines, Ministry of Finance. Deemed supply is covered in section 10.4 scenario 2, buyers not yet onboarded in section 10.2.2, and exports in section 10.4 scenario 8. The Guidelines are versioned, so check the current release before treating any of this as final.