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Home / E-invoicing / Who must comply
The rule is short. Every business that makes a business transaction in the UAE is in scope, whether or not it is registered for VAT. The details are below.
The rule
A business transaction is any transaction a person carries out in the course of its business. If your company sells to, or buys from, other businesses or government entities in the UAE, you are in scope.
There is no size test and no revenue limit for being in scope. Revenue decides only when you start: AED 50 million or more in phase 1, everyone else in phase 2.
The requirements are the same for every business: appoint one accredited service provider, send and receive e-invoices through it, and keep your records in the set format.
Case by case
Chapters 6 and 7 of the Ministry of Finance E-Invoicing Guidelines, version 2.0, October 2026. The Minister can add exclusions by decision.
B2C companies
A shop, a restaurant, a clinic or an online store does not e-invoice its sales to individuals. A receipt or a simplified tax invoice stays as it is.
But every such business buys from other businesses, and those suppliers will send e-invoices. To receive them you need an accredited service provider. And any sale you make to a business or a government entity must itself be an e-invoice.
So a B2C company appoints a provider like everyone else, by the date for its phase.
Questions
Yes. Every business with business transactions in the UAE is in scope, whatever its size. Small businesses fall in phase 2, live from 1 July 2027.
Yes. A free zone company is treated like any other business in the UAE.
Yes. VAT registration does not matter. Making business transactions in the UAE does.
B2B and B2G sales must be e-invoices. B2C sales, to individuals, are not e-invoiced. A B2C company is still in scope for what it buys and for any sale to a business.
There is no revenue limit for being in scope. Revenue only decides the phase: AED 50 million or more is phase 1, below that is phase 2.
Financial services that are exempt from VAT are excluded. Financial services that are standard rated are in scope.
International passenger transport by an airline with an electronic ticket is excluded, and so are ancillary services to the passenger. Air cargo with an airway bill has a temporary exclusion of 24 months.
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