New UAE E-invoicing Regulations: What Service Providers Need to Qualify for MoF Accreditation

Understand how the UAE e-invoicing regulations under Ministerial Decision No. 64 of 2025 outline the Ministry of Finance’s accreditation rules for service providers, including eligibility, testing, and compliance.

By Sudhanshu Singh

The United Arab Emirates (UAE) Ministry of Finance (MoF) has issued Ministerial Decision No. 64 of 2025 on March 19, 2025 to formalize the eligibility criteria, application procedures, and compliance obligations for service providers (SPs) seeking to participate in the country’s electronic invoicing system. This move aligns with the broader rollout of digital tax infrastructure in the UAE, emphasizing security, interoperability, and continuity of services.

Only service providers who have completed the accreditation process as outlined in the decision will be permitted to deliver electronic invoicing services within the state. The Ministry will maintain a Central Register of Accredited Service Providers (ASPs) to support transparency and regulatory enforcement.

Eligibility criteria for service providers

Legal and Operational Requirements

First, the service provider must be Peppol-certified and must have successfully completed OpenPeppol conformance tests. It must also demonstrate a minimum of two years of operational experience managing an electronic invoicing system. Legal incorporation is mandatory, either in the UAE or in a recognized foreign jurisdiction with authorization to operate within the UAE. The provider must maintain a paid-up capital of no less than AED 50,000 (US$13,612) and submit audited financial statements for the latest financial year. If unavailable at the time of application, these must be provided within six months.

To demonstrate business continuity preparedness, applicants must obtain ISO 22301 certification. If this certification is not yet held, it must be secured within three months after the financial year ends. The technical compliance of the provider’s Peppol Service Provider (PSP) product is also scrutinized. It must adhere to the Peppol Interoperability Framework, including compliance with PINT AE specifications and the national Data Dictionary. Any additional requirements specified under the Peppol Authority Specific Requirements (PASR) must also be met.

Tax and Insurance Requirements

In terms of tax compliance, providers are obligated to register under Federal Decree-Law No. 47 of 2022 for Corporate Tax, and under Federal Decree-Law No. 8 of 2017 for VAT, where applicable. Information security is another area of scrutiny. Providers must maintain ISO/IEC 27001 certification for their PSP product. The product must implement multifactor authentication, ensure encryption of data at rest and in transit, and be subjected to regular security monitoring. Further, providers must adhere to UAE-specific data storage and residency obligations, including those under the national cloud security policy.

Self-Declaration and Ethical Standing

A signed self-declaration is also required. This document affirms that the provider is not undergoing liquidation or bankruptcy, is not engaged in legal disputes impacting financial integrity, and is not blacklisted by any government authority. The declaration must also confirm the provider’s commitment to offer at least 100 free eInvoice exchanges annually and uphold confidentiality standards.

Finally, the provider must present proof of adequate insurance coverage, sourced only from insurers licensed to operate in the UAE. The minimum coverage amounts are AED 2.5 million (US$680,636) for professional indemnity, AED 5 million (US$1.36 million) for crime, and AED 5 million (US$1.36 million) for cyber fraud. These insurance documents are to be uploaded only after the Ministry completes its initial application review and instructs the applicant to proceed.

Application and pre-approval procedures

Applications must be submitted through the official MoF eInvoicing Service Provider Accreditation Portal. Email submissions are not permitted. Only one active application is allowed per provider, and applications can remain in draft for up to 90 days.

The MoF will respond within 90 business days. If additional information is needed, the applicant has 30 business days to comply. If approved, the applicant proceeds to pre-approval testing.

Pre-approval testing includes:

• OpenPeppol interoperability tests;
• Participant ID creation with the Federal Tax Authority (FTA);
• Trial use of EmaraTax production API; and
• Data exchange simulation using valid Peppol Public Key Infrastructure (PKI) certificate.

Following successful verification, the provider receives pre-approval.

Final testing and full accreditation

After receiving pre-approval, the service provider must demonstrate its ability to transmit tax data and perform live exchanges under supervision. This involves completing the tax data reporting tests, undergoing final OpenPeppol validation, and participating in a trial run overseen by the Ministry to confirm operational readiness. Upon successful completion, the Ministry grants full accreditation. This status remains valid for two years.

Ongoing compliance and renewal

Accredited providers are subject to regular evaluations by the Ministry. Compliance with all eligibility criteria must be maintained throughout the accreditation period. Renewal applications must be submitted no later than 70 business days before the expiration date. These applications must include updated insurance certificates, a valid ISO/IEC 27001 certification, and documentation proving that eligibility criteria continue to be met.

Failure to submit a renewal application on time, or failure to meet the conditions of continued eligibility, may lead to cancellation of accreditation. The Ministry may authorize third-party reviews during the renewal process and reserves the right to reject renewal applications if deficiencies are not corrected within the prescribed timeframe.

Termination and objection procedures

Accreditation can be terminated if the provider voluntarily exits the market, fails to meet ongoing compliance obligations, or becomes the subject of substantiated complaints from end users. In the event of termination, the provider must notify its clients within five business days. The Ministry also reserves the right to delist the provider from the Central Register and related directories.

If a provider wishes to contest the termination, it must file an objection within 40 business days of notification. The objection must include justifications and supporting documents. The Ministry will review the case and issue a decision within 30 business days. If the objection is denied, the decision becomes final, and the provider is barred from reapplying for accreditation for two years.

In summary

The UAE’s e-invoicing accreditation framework introduces a robust and structured compliance regime for technology service providers. It aligns with international interoperability standards while enforcing stringent local requirements for security, business continuity, and tax reporting. Service providers must be diligent in fulfilling each requirement and maintaining compliance throughout the accreditation cycle. Businesses relying on these providers must verify their ASP’s standing to ensure uninterrupted and lawful invoicing operations.

Frequently Asked Questions (FAQs)

Can I apply via email?

No. All applications must go through the MoF’s official portal.

What if my application is inactive?

Only one active application is allowed. If the submit button is disabled, an application is already in progress.

What is the response time?

The MoF responds within 90 days, and additional information must be submitted within 30 days.

What are the testing requirements?

OpenPeppol interoperability and FTA onboarding tests are mandatory.

Can I save a draft application?

Yes, for up to 90 days.

Where should insurance be sourced from?

All policies must be issued by insurers operating in the UAE.

What if I lack ISO 22301?

Submit a justification. The MoF may assign a deadline for compliance.

Will ASPs be monitored?

Yes, through regular audits and compliance checks.

How do I track my application?

Use the “My Application Status” section in the portal.

(US$1 = AED 3.67)

Further reading:

• New UAE E-Invoicing Framework: Public Consultation till Feb. 27
• UAE to Implement E-Invoicing Mandate by July 2026: What Businesses Need to Know

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