Dubai Company Formation

Tax 2 min read

E-invoicing: tax groups get two years, and the storage-in-the-UAE rule goes

Three blank cream paper sheets on a teal ground, two overlapping and the third set apart with a small gold dot at its top edge

The e-invoicing regulations that a UAE company has been reading since last year have been amended, and every change is a subtraction. Ministerial Decision No. 197 of 2026, announced by the Ministry of Finance on 19 October, amends Ministerial Decision No. 243 of 2025 and took effect on 1 October 2026.

Tax groups get 24 months

Transactions between members of the same Tax Group are excluded from the e-invoicing system for 24 months from 1 January 2027. For a Dubai holding structure with several entities registered as one group for VAT, the invoices that cross between them do not have to go through an accredited service provider until 2029. Invoices to anyone outside the group still do.

Storage anywhere

Article 11 no longer requires e-invoices and e-credit notes to be stored within the UAE. The ministry says this gives businesses flexibility in how they meet their record-keeping obligations. The obligation to keep the records is unchanged; the geography is not.

The system-failure duty is repealed

Article 12, which covered what happens when the e-invoicing system fails, is repealed, and with it the duty to notify the authority within two business days of a system failure and the provisions on how to issue invoices in the meantime. The ministry gives no replacement procedure.

What stays

The rest of the 2025 decision stands: the Peppol-based five-corner model, accredited service providers, the data dictionary and the phased go-live. The decision only moves the edges of the net; a company that issues invoices to customers outside its own group is as far inside it as it was in September.

The tax-group exclusion is the change that alters a project plan. Intercompany invoicing is where most groups expected the first integration headache, because it runs on internal systems that were never built to talk to an accredited provider; taking it out of scope for two years lets the customer-facing flow go first and the internal one follow when the tooling is mature. The storage change matters to anyone on a foreign group's ERP, which usually keeps its archive where the group does. The repeal of Article 12 is the one to read twice: there is now no written rule for what to do when the system is down, which is not the same as being allowed to do nothing.

Source: Ministry of Finance checked against the source

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