The Two Decisions That Set the Foundation
On 29 September 2025, the UAE Ministry of Finance issued two ministerial decisions that converted the long-anticipated e-invoicing initiative into binding rules. Decision 243 of 2025 covers the framework and operational arrangements; Decision 244 of 2025 covers scope, phasing, and obligations of in-scope persons.
Together, they are the legal basis for everything that followed - the April 2026 pilot, the October 2026 ASP appointment deadline, and the January and July 2027 phase deadlines.
What Ministerial Decision 243 of 2025 Sets Out
Decision 243 establishes the operational framework for the e-invoicing system:
- Architecture. Adoption of the Peppol 4-corner exchange model with FTA reporting as an additional corner.
- Format. PINT AE - the Peppol Invoice Standard for the UAE - based on Peppol BIS Billing 3.0 in UBL XML.
- Accredited Service Providers (ASPs). The accreditation regime for service providers, their obligations, technical requirements, and the role of EmaraTax as the appointment channel.
- Reporting. Near real-time submission of structured invoice data to the FTA.
- Document retention. Electronic archive obligations for tax invoices and related documents.
What Ministerial Decision 244 of 2025 Sets Out
Decision 244 sets out the scope and phased rollout for taxpayers:
- Phase 1. Mandatory for businesses with annual revenue of AED 50 million or more from 1 January 2027.
- Phase 2. Mandatory for businesses with annual revenue below AED 50 million from 1 July 2027, including those that are not VAT-registered but otherwise in scope.
- Coverage. B2B and B2G tax invoices. B2C is currently out of scope.
- ASP appointment. In-scope businesses must appoint an Accredited Service Provider via EmaraTax. The original deadline of 31 July 2026 was extended to 30 October 2026.
- Validity. A tax invoice that is not issued through an ASP in PINT AE format will not be a valid tax invoice for affected transactions.
What This Changed in Practice
Before Decision 243 and 244, e-invoicing in the UAE was discussed as a policy direction. After them, it is a binding compliance obligation with hard dates:
- Format becomes mandatory. A PDF or paper invoice between Phase 1 businesses from 1 January 2027 onward is not a valid tax invoice.
- ASP appointment becomes a deadline. The 30 October 2026 EmaraTax appointment date is now non-negotiable for Phase 1 businesses.
- Master data becomes critical. The PINT AE business rules require fields like customer TRN, Peppol participant ID, and FTA tax category codes that many ERPs do not populate consistently today.
- The 4-corner model is now official. The country's adoption of Peppol is no longer rumour - it is the legal architecture.
The Extended ASP Appointment Deadline
One important update after the decisions: the Ministry of Finance extended the ASP appointment deadline for Phase 1 from 31 July 2026 to 30 October 2026. This gives in-scope businesses an additional three months but does not change the 1 January 2027 go-live for Phase 1. Use the extra time to choose well, not to delay starting.
What You Should Do Now
- Confirm your phase. Apply the AED 50M revenue test to your latest audited statements.
- Shortlist Accredited Service Providers. Compare ERP integration depth, PINT AE conformance testing, support model, and pricing.
- Audit your master data. Customer TRNs, addresses, Peppol IDs, tax category codes, item codes.
- Plan your pilot. Run sandbox exchanges in 2026 so you are not learning the format under deadline pressure.
How InvoiceNet Helps You Comply
InvoiceNet is built specifically against the obligations in Decisions 243 and 244. We act as your Accredited Service Provider, connect to your ERP, generate PINT AE, exchange via Peppol, and report to the FTA simultaneously. Talk to our team for a free readiness assessment aligned to the Decision 244 phase test.