B2B e-Invoicing in the United Arab Emirates (UAE): Peppol DCTCE scheduled for 2026

The electronic invoicing project in the United Arab Emirates is called the "E-Billing System". The government is developing legislation that will regulate electronic transactions, electronic accounting, and storage both in the B2B and B2G domains. In the future, it will also apply to B2C transactions.

The implementation timeline is still provisional. The potential dates that the UAE government may consider are:

• 2024 (third quarter): Development of requirements and certification procedures for service providers.
• 2025 (second quarter): Publication of e-Invoice Legislation.
• December 2025: The Pilot Phase begins.
• July 2026: Phase 1 Go-live of B2B and B2G e-invoicing.

How electronic invoicing works in the United Arab Emirates: DCTCE

During an event held in Dubai in 2024, the Ministry of Finance announced that the United Arab Emirates government is poised to adopt a decentralized approach to Continuous Transaction Controls (CTC), drawing upon Peppol as its foundation. This approach is commonly referred to as the "5 corners" model of Peppol.

The framework comprises a five-corner model, including the issuer, the receiver, and the central tax platform. The intention is to integrate the Peppol PINT standard, requiring both the issuer and receiver to possess certified Peppol Access Points. These access points will verify the data and transmit it to the recipient. Moreover, the issuer's Peppol Access Point will manage the transmission of the invoice to the tax authority. In this setup, the governmental platform serves as an invoice repository without conducting validation on the invoices.

This information is pending confirmation by the Ministry of Finance. Together with the administrations in each country, EDICOM continuously tracks the advancement and evolution of the laws governing electronic invoicing.

e-Invoicing Context in the UAE

The Federal Tax Authority (FTA) published Federal Law No.1 of 2006 on Business and Electronic Transactions, introducing regulations related to electronic accounting, storage, and validation processes such as authorization and document signing. 

This regulation mandates that whenever electronic invoicing is required, invoices must only be created and distributed electronically, and an electronic signature must be used. These documents must also be stored electronically for ten years.

The exchange of electronic commercial papers is currently permitted, provided that the recipient agrees to receive them in the format that was chosen along with the issuer. They must be produced following the set guidelines and stored in the same format as when they were first given. To ensure the legitimacy and consistency of the documents, an electronic signature must be used.

The Federal Law of 2006 has the following objectives:

• To lay the foundations and obligations of mandatory electronic processes.
• Unify the procedure for the creation of electronic invoices and promote the development of technological infrastructures necessary to implement electronic processes.
• Facilitate the exchange of documents with public entities and business partners in a standardized and authenticated manner.