Other BriefingsNew UAE E-Invoicing Framework: Public Consultation till Feb. 27
The UAE Ministry of Finance has launched a consultation process on its proposed e-invoicing framework, inviting stakeholders to provide feedback by February 27, 2025, to ensure the system is practical, comprehensive, and aligned with business needs. This initiative aims to enhance tax compliance, operational efficiency, and digital transformation in the UAE.
By Giulia Interesse
The United Arab Emirates (UAE) is taking a significant step toward digitalizing its tax and business environment with the planned introduction of an e-invoicing regime. On February 6, 2025, the UAE Ministry of Finance (MoF) released a public consultation document, inviting businesses and stakeholders to provide feedback on the proposed framework by February 27, 2025.
This marks the first formal consultation process on e-invoicing in the UAE, following the October 2024 announcement confirming the adoption of a decentralized continuous-transaction control-and-exchange (DCTCE) five-corner model. The consultation document outlines the key features of the system, including its structure, the expected ‘Data Dictionary’, and specific use cases.
The implementation of e-invoicing is expected to enhance tax compliance, improve efficiency, and align the UAE with international best practices. However, it also introduces new regulatory and technical requirements for businesses operating in the country. Given the potential impact, the MoF is actively seeking industry feedback to ensure the system is designed in a way that is compatible with the UAE’s business landscape.
This article explores the key aspects of the proposed e-invoicing regime, its potential implications for businesses, and what companies should consider when submitting feedback during the consultation period.
UAE’s e-invoicing consultation document overview
What are the objectives of the consultation document?
The UAE MoF’s e-invoicing consultation aims to engage businesses, industry experts, and e-invoicing service providers in shaping a standardized and efficient e-invoicing framework. By gathering feedback from key stakeholders, the consultation seeks to ensure that the proposed system is practical, comprehensive, and aligned with business needs.
The primary objectives of the consultation include:
- Defining the e-invoicing Data Dictionary (PINT AE): This document outlines the key data elements (fields) and their attributes for commonly used invoice types in the UAE. Standardization is critical to ensuring seamless integration and processing of e-invoices across different businesses and systems.
- Clarifying excluded transactions: Identifying business transactions that will be exempt from e-invoicing exchange and reporting requirements, providing clarity on the scope of the framework.
- Establishing a common understanding: Creating a shared interpretation of e-invoice data elements among businesses to promote consistency and interoperability.
- Addressing practical business requirements: Identifying any gaps or additional data fields necessary to support operational, regulatory, or analytical needs.
- Gathering diverse industry perspectives: Encouraging feedback from accounting firms, industry experts, and e-Invoicing Service Providers to develop a holistic and widely accepted framework.
Moreover, the UAE government has confirmed that e-invoicing will be introduced in phases, with a comprehensive rollout strategy to be communicated in due course.
What is the proposed e-invoicing framework?
The UAE’s e-invoicing framework, based on the five-corner DCTCE model, involves collaboration between e-invoicing users, accredited service providers (ASPs), and the MoF.
Below is an overview of the process:
| Stakeholder | Key Actions |
| E-invoicing users |
|
| Accredited service providers (ASPs) | ASPs facilitate the secure exchange and validation of invoice data:
|
| Ministry of Finance and Federal Tax Authority |
|
This framework ensures a standardized, secure, and compliant e-invoicing process, leveraging advanced technology to streamline transactions while meeting regulatory requirements. It highlights the UAE’s commitment to enhancing its business environment and facilitating digital transformation.
Addressing key issues for stakeholders: Scope and clarity
The UAE Ministry of Finance is actively seeking feedback from stakeholders to refine its e-Invoicing Data Dictionary. This collaborative approach aims to ensure that the framework meets the diverse needs of businesses, regulators, and service providers while addressing all potential scenarios. Two critical areas of focus have been identified: comprehensiveness and clarity.
Comprehensiveness is vital to ensure that the Data Dictionary covers all the fields necessary for a seamless end-to-end e-invoicing process. These fields include invoice-specific details such as the invoice number, issue date, buyer and seller information, item descriptions, tax breakdowns, and payment terms. The dictionary has been designed to account for general use cases, including discounts, surcharges, and multi-currency transactions. However, stakeholder feedback is needed to identify gaps or additional fields that may be required to cater to specific industries or unique business scenarios.
One notable feature is the inclusion of Harmonized System (HS) Codes and service codes, which are currently optional but will become mandatory in the later stages of the e-invoicing program. Stakeholders are encouraged to consider the implications of this change, particularly the practicality of reporting these codes with varying levels of detail (4, 6, or 8 digits).
To ensure the dictionary is comprehensive, stakeholders are asked to consider whether all necessary fields are included, if there are any conflicts with the current structure, and whether industry-specific data elements are adequately represented. Additionally, potential challenges such as privacy concerns or the complexity of reporting certain transactions should be highlighted.
The second key area is clarity, which is essential to avoid ambiguity and ensure that the Data Dictionary is accessible to all stakeholders, regardless of their technical expertise. For instance, terms like “Invoice Date” must be clearly defined to mean the date the invoice is issued, as opposed to the date it was created or sent. Ambiguity in such definitions could lead to inconsistencies and operational inefficiencies.
Stakeholders are invited to identify any fields or terms in the Data Dictionary that may be confusing or open to multiple interpretations. Clear and concise descriptions will help eliminate misunderstandings and streamline implementation across different industries.
What are the next steps for stakeholders?
To facilitate this consultation, the Ministry of Finance has established a structured timeline and submission process. Stakeholders are encouraged to provide their feedback by the specified deadline, which will be communicated alongside the document release date. The feedback should address key areas such as missing fields, potential conflicts, and the adequacy of industry-specific data elements. Stakeholders are also asked to include their contact details, business information, and industry-specific insights to enable further discussions if needed.
The MoF has also posed several targeted questions to guide feedback. These include whether there are fields missing for specific business needs, whether any terms are unclear or ambiguous, and whether certain transactions pose challenges from a privacy or practicality perspective. Stakeholders are encouraged to reflect on these questions and provide detailed responses through the submission platform.
Next steps for the UAE’s e-invoicing program
As part of the consultation process for the UAE’s e-invoicing program, MoF has outlined a clear roadmap to collect stakeholder feedback and refine the proposed framework. Businesses, software vendors, and other stakeholders are encouraged to actively participate in this process to help shape an effective and comprehensive e-Invoicing system.
The consultation timeline includes the release of the Data Dictionary document and a deadline for feedback submission, both of which will be specified by the Ministry. Stakeholders are urged to review the document thoroughly and submit their feedback before the deadline to ensure their perspectives are considered.
To participate, stakeholders are required to provide specific information as part of their submission, including:
- Full name and contact details (phone number and email address).
- Company name, industry, and annual turnover (to assess the impact of raised issues).
This information will allow the MoF to follow up for further discussions, if necessary, ensuring a comprehensive understanding of concerns and recommendations.
Moreover, the MoF has posed several guiding questions to facilitate detailed and constructive feedback. These include:
- Are there any missing fields in the Data Dictionary that are critical to your business operations?
- Are there conflicts or issues with the existing fields?
- Are industry-specific data elements adequately represented?
- Do you foresee any challenges in reporting transactions via the e-Invoicing exchange, such as those related to privacy or practicality?
- What is your preference for reporting HSN (HS Code) and service codes? Would 4, 6, or 8 digits be the most practical for your transactions?
Feedback can be submitted through the official consultation platform provided by the Ministry of Finance at this link.
This structured approach ensures that the feedback is both actionable and reflective of the diverse needs of stakeholders. By engaging the business community and other participants, the UAE aims to create a robust and inclusive e-invoicing system that not only ensures compliance but also enhances operational efficiency.
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