Law amends & details of 2026 B2B and B2G decentralised mandatory 5-corner model
On 29 October, the Arab Gulf state of United Arab Emirates (UAE) Ministry of Finance and Federal Tax Authority has updated the VAT Law to include provision for e-invoicing: definitions; recovery; issuance; and credit notes.
On 24 October, the FTA updated its guidance on the July 2026 B2B and B2G e-invoicing mandate. This includes a Frequently Asked Questions page. B2C to follow at a later date. 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.
The Authority is adopting a “Decentralised CTC and Exchange Model” (DCTCE) with 5-corner model and Accredited Service Providers operating within a Peppol framework.
It will be adopting a 5-corner model, with vendors and customers able to exchange e-invoices directly without the need to pre-clearance the invoice with the Ministry. The first version will be 4-model. This will likely be adopted under a Peppol PINT basis, including the use of Accredited Service Providers (e-invoicing agents). These ASP’s are responsible for validating basic information in the invoice, and forwarding to the customer, via their agent. The agent also sends the invoice to the Federal Tax Authority (5th-corner), but there is no pre-clearance required from the Authority.
Phased launch plan for e-invoicing
The launch of e-invoicing will be as follows:
- Q4 2024: issuance of draft technical requirements and ASP process; development of Data Directory;
- Q2 2025: draft legislation
- Dec 2025: rollout strategy
- July 2026: phase 1 lunch
- Further phase waves to be confirmed
E-billing system
E-invoicing is part of a wider initiative the Ministry of Finance describes an “e-billing system” project to develop an advanced electronic billing system and activate it at the country level. The system will also automate the procedures for filing tax returns with the tax system to facilitate filing tax returns, improve tax compliance, and reduce cases of tax evasion.
Currently, the UAE government has given legal recognition to e-invoices when agreed between transaction counter-parties.
This would follow the December 2021 Saudi Arabia e-invoicing implementation.
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