E-invoicing for new companies and VAT groups
Version 2.0 of the UAE e-invoicing guidelines says a new business in scope must have its e-invoicing provider in place before its first invoice. Transactions inside a VAT group get two extra years.
The Ministry of Finance published version 2.0 of its e-invoicing guidelines on 26 October 2026. Two of its changes concern how a business is set up: one for companies that are just starting, the other for companies registered for VAT together as a group.
What changes
- A newly established business within the scope of e-invoicing has to appoint an Accredited Service Provider (ASP) and complete onboarding before it issues its first invoice. The guidelines say this applies “irrespective of their date of establishment”, and every invoice it issues has to be an e-invoice.
- A business in scope that is not registered for any tax has to register with the FTA to get a Tax Identification Number (TIN), its e-invoicing identifier.
- Transactions between members of the same VAT group get a grace period of 24 months from 1 January 2027. During it, those transactions do not have to go through e-invoicing.
- The grace period changes only the timing. Intra-group transactions stay in scope, and each member’s transactions with outside customers follow the normal phase dates.
- Each group member uses its own TIN, the first 10 digits of its own TRN, not the TRN of the group representative.
What to do
- If you are setting up a company, plan the ASP and onboarding as part of the setup, before you send your first invoice.
- Register with the FTA if your company needs a TIN and has no tax registration yet.
- If you are in a VAT group, list which invoices go to other group members and which go to outside customers, because only the first kind gets the grace period.
- Check that each member’s own TRN, not the representative’s, is set up in your invoicing system.
What this means for you
For a new company, e-invoicing becomes one of the setup steps, next to the licence, the bank account and tax registration. For a VAT group, the grace period buys time for invoices between members only. Invoices to outside customers still follow your phase date.
How QuickTax helps
For each company we keep the TRN and master data that e-invoicing relies on in order. QuickTax is building e-invoicing into its service and plans to have it running by the end of 2026: what this means for businesses under AED 50 million. Setting up a company? Start with our business setup service.
This update is for reference and is not tax advice. Source: the Ministry of Finance’s e-invoicing guidelines, version 2.0, sections 6.3.2 and 8.4.