Phase 1: A person subject to the system whose annual revenue is equal to or exceeds AED 50 million must appoint an accredited service provider by 30 October 2026 and implement the system by 1 January 2027.
What changed?
Ministerial Decision No. 66 of 2026 amended paragraph (a) of Article 5(1) of Ministerial Decision No. 244 of 2025. It moved the Phase 1 ASP appointment deadline from 31 July 2026 to 30 October 2026; the 1 January 2027 implementation date remains.
What should a Phase 1 business do?
- Confirm whether it is a person subject to the electronic invoicing system.
- Document the revenue threshold determination and any activity-specific considerations.
- Review the Ministry's latest accredited ASP register.
- Choose and appoint an ASP before the applicable deadline.
- Plan ERP integration, invoice data validation, testing and operational responsibilities before 1 January 2027.
Important scope considerations
A revenue threshold alone is not a full legal scope determination. Under the original implementation decision, business-to-consumer transactions remain outside the system until a further ministerial decision. Complex structures and transaction types may require professional review.
Do not rely solely on a calculator: corporate structures, taxable persons, exclusions, invoicing arrangements and the current regulations may change how the rules apply to you.
Official references: Ministerial Decision 66 of 2026 ↗ · Ministry e-invoicing portal ↗. Reviewed 3 October 2026.