TAX

Tax Alert – Executive Regulation amendments set the stage for UAE’s 2026 e-invoicing mandate

insight featured image
Contents

The United Arab Emirates (UAE) has taken a significant step towards the digital transformation of its tax ecosystem by formally incorporating several e-invoicing provisions into the UAE VAT Executive Regulations. This development underscores the government’s commitment to implementing e-invoicing in the UAE from July 2026.

Regulatory background

The UAE VAT Law had previously introduced key definitions relating to e-invoicing, including “electronic invoices” and “electronic credit notes”.

Building on this, Cabinet Decision No. 100 of 2025, effective from 29 September 2025, introduces amendments to Article 59 and Article 60 of the VAT Executive Regulations, reinforcing the e-invoicing mandate.

Key amendments introduced in the VAT Executive Regulations

  1. Elimination of simplified invoices: The concept of simplified invoices has been removed under the e-invoicing framework. Consequently, businesses previously issuing simplified invoices for supplies below AED 10,000 will be required to issue e-invoices.

  2. Mandatory e-invoicing for zero-rated supplies: All zero-rated transactions, including exports of goods and services to non-UAE businesses, will be subject to e-invoicing requirements.

  3. Revised requirements for credit notes: Under the e-invoicing framework, credit notes will no longer be required to include the original invoice value, the corrected value, and the difference between the two. Instead, it will be sufficient to disclose the credit note amount along with the applicable VAT.

  4. Administrative exceptions: The amendments indicate that the Federal Tax Authority (FTA) will not grant exceptions from issuing e-invoices or credit notes. It is likely that current administrative exceptions already given to businesses will be withdrawn once e-invoicing takes effect (subject to any further clarification from the FTA).

  5. Electronically issued invoice storage rules: Earlier provisions governing the storage and authenticity of electronically issued invoices and/or credit notes are no longer applicable under the new e-invoicing framework and are expected to be clarified further in due course.

Industry implications and next steps

The UAE’s e-invoicing mandate, effective July 2026, represents a transformative shift in VAT compliance. While the legal framework is now embedded within the VAT Law and Executive Regulations, the business community awaits further clarity on:

  • Dedicated e-invoicing regulations: Expected to outline implementation rules, transitional provisions, and penalties for non-adherence.

  • Phased implementation plan: Details on rollout timelines and taxpayer segmentation.

  • Accredited service provider (ASP) list: The official list of ASPs, who will facilitate integration with the FTA’s e-invoicing platform.

How Grant Thornton UAE can help

The e-invoicing mandate is more than a compliance requirement—it is a catalyst for operational efficiency and digital transformation. CFOs, tax leaders, IT heads and business owners should initiate readiness assessments, upgrade ERP systems, and engage with accredited service providers to ensure seamless integration with the FTA’s e-invoicing platform.

At Grant Thornton UAE, we are equipped to support businesses through every stage of this transition, from regulatory interpretation to system implementation. For tailored guidance and practical solutions, we invite you to contact our e-invoicing core team.