On 28 October 2026 the Ministry of Finance (MoF) released Version 1.1 of the UAE e-invoice mandatory fields document (formally, the UAE Electronic Invoice Mandatory Fields), replacing Version 1.0 of 23 February 2026. The headline for finance and IT teams is reassuring and sobering at the same time: not a single mandatory field has been added, removed or renamed. The electronic Tax Invoice still carries 51 mandatory fields and the commercial Electronic Invoice 49. What has changed is the legal scaffolding around the list — it now speaks of Ministerial Decisions No. 243 and 244 of 2025 “and its amendments”, and it points to Ministerial Decision No. 168 of 2026 as the new accreditation regime for Accredited Service Providers (ASPs).
That matters for two reasons. First, the data model is now effectively frozen nine weeks before the first mandatory go-live on 1 January 2027 — there is no longer any reason to wait for “the final list” before completing ERP mapping. Second, the amendments V1.1 now incorporates by reference change who must issue e-invoices, to whom, how fast, and through which provider. V1.1 was dated just two days before the 30 October 2026 deadline for businesses with Revenue of AED 50 million or more to appoint an ASP.
Effective date: V1.1 is MoF technical guidance, not a legislative instrument, and applies immediately. It governs every Electronic Invoice issued in the Pilot Programme and voluntary phase (live since 1 July 2026) and in mandatory implementation from 1 January 2027 for persons with Revenue of AED 50 million or more. Those persons had to appoint an ASP by 30 October 2026. That deadline has now passed, so any business in that band without a signed ASP appointment is already behind.
Key takeaways
- The UAE e-invoice mandatory fields are unchanged in V1.1: 51 fields for an electronic Tax Invoice and 49 for a commercial Electronic Invoice.
- V1.1 now refers to Ministerial Decisions 243 and 244 of 2025 “and its amendments”, importing the VAT Tax Group exclusion (MD 197) and the 30 October 2026 ASP deadline (MD 66).
- ASP accreditation is now governed by Ministerial Decision No. 168 of 2026; a provider holding only MD 64 pre-approval is not, in our view, a compliant appointment.
- A VAT group member carries two identifiers on one invoice: its own TIN as the electronic address (field 11) and the group VAT TRN as the seller tax identifier (field 15).
- Fields 5, 15, 24 to 25 and 48 to 49 carry the highest mapping risk ahead of go-live on 1 January 2027.
The legal framework behind the UAE e-invoice mandatory fields
The e-invoicing regime rests on the VAT Decree-Law as amended by Federal Decree-Law No. 16 of 2024 (which embedded Electronic Invoices into the law — see our earlier blog on Public Clarification VATP046) and on four Ministerial Decisions, three of which have been amended in 2026:
| Instrument | Subject | 2026 amendment | Key effect |
|---|---|---|---|
| MD No. 243 of 2025 | The Electronic Invoicing System — scope, exclusions, obligations | MD No. 197 of 2026 (effective 1 Oct 2026) | VAT Tax Group intra-group transactions excluded for 24 months from 1 Jan 2027; e-invoice to be issued and transmitted within 14 Business Days of the transaction; in-UAE data storage requirement removed (retention per Tax Procedures Law); System Failure provisions (Art 12) repealed |
| MD No. 244 of 2025 | Phased implementation | MD No. 66 of 2026 | ASP appointment deadline for Revenue ≥ AED 50m moved from 31 Jul 2026 to 30 Oct 2026; go-live unchanged at 1 Jan 2027 |
| MD No. 64 of 2025 | ASP eligibility and accreditation | Repealed by MD No. 168 of 2026 (effective 1 Oct 2026) | Pre-approval stage abolished; providers may operate only once fully accredited; pre-approved providers given 30 days from 1 Oct 2026 to complete accreditation or lose approval |
| UAE Electronic Invoicing Guidelines | Operational rules, eight invoice scenarios | V1.1 of 1 June 2026 | Read alongside the Mandatory Fields document |
The phased e-invoicing timeline under MD 244 (as amended) now reads:
| Category | Appoint ASP by | Implement by |
|---|---|---|
| Persons with Revenue ≥ AED 50 million | 30 October 2026 | 1 January 2027 |
| Persons with Revenue < AED 50 million | 31 March 2027 | 1 July 2027 |
| Government Entities | 31 March 2027 | 1 October 2027 |
What changed between V1.0 and V1.1 of the mandatory fields
| Section | V1.0 (23 Feb 2026) | V1.1 (28 Oct 2026) | Practical effect |
|---|---|---|---|
| 1. Purpose | Read with the Guidelines, MD 243, MD 244 and PINT-AE | Read with the Guidelines and PINT-AE only | The document repositions itself as a technical schedule; the legal obligations are left to the (amended) Decisions |
| 2. Highlights — scope | Excluded “as per Article 4 of MD No. 243 of 2025” | “…and its amendments” | Imports the MD 197 VAT Tax Group exclusion and the reworked list of excluded transactions |
| 2. Highlights — timeline | “as per … MD No. 244 of 2025” | “…and its amendments” | Imports MD 66’s 30 October 2026 ASP deadline |
| 3. Glossary — ASP | Accredited under MD No. 64 of 2025 | MD 64 “has been repealed by” MD No. 168 of 2026 | Accreditation status must now be tested under MD 168 — a pre-approval under MD 64 is no longer enough |
| 4.1 Tax Invoice fields | 51 fields | 51 fields — identical | No remapping required |
| 4.2 Commercial invoice fields | 49 fields | 49 fields — identical | No remapping required |
The two lists remain asymmetric in three places, and these are where most mapping errors will occur:
Field 15 (Seller)
“Seller tax identifier” on a Tax Invoice (the 15-digit TRN) versus “Seller tax registration identifier” on a commercial invoice, where a seller without a TRN states its 10-digit TIN.
Fields 24–25 (Buyer)
Buyer tax identifier and tax scheme code on a Tax Invoice versus Buyer legal registration identifier and its type (TL, EID, PAS or CD) on a commercial invoice.
Fields 48–49 (Tax Invoice only)
VAT line amount in AED and Invoice line amount in AED. A commercial invoice in foreign currency need not carry AED line values; a Tax Invoice always must.
The identity architecture: TIN, TRN and Peppol endpoint
V1.1 retains the Highlights that do most of the practical work. The Participant Identifier is the TIN — the first 10 digits of the Corporate Tax TRN. Combined with the fixed scheme value 0235 (Seller electronic identifier, field 12), it forms the Peppol endpoint the ASP registers (for example, 0235:1004567890). A person in scope that is not required to register for Corporate Tax must register with the FTA (via EmaraTax) solely to obtain a TIN.
The most consequential sentence in the document survives unchanged: a Tax Group member’s TIN is the first 10 digits of its own Corporate Tax TRN, not the first 10 digits of the Tax Group representative’s TRN. For a VAT group member this produces two different identifiers on the same invoice — its own TIN as the electronic address (field 11) and the group’s shared VAT TRN as the seller tax identifier (field 15). Master data that assumes one entity, one number will fail.
Worked example: mapping a VAT group member’s e-invoice (Danat Facilities Management LLC)
Danat Facilities Management LLC (Revenue AED 82 million) is a member of a VAT Tax Group represented by Bahr Holding LLC. Danat is separately registered for Corporate Tax. Its contract with Noor Hospitality LLC (an unrelated, VAT-registered Dubai hotel operator) is priced in US dollars. In January 2027 Danat issues an electronic Tax Invoice for two lines. Assume a Central Bank rate of AED 3.6725 per USD.
Identity fields (fictional numbers):
| Field | Value | Source |
|---|---|---|
| 11 Seller electronic address | 1004567890 | First 10 digits of Danat’s own CT TRN (1004567890 00003) |
| 12 Seller electronic identifier | 0235 | Fixed UAE value |
| 13–14 Legal registration | DED trade licence number / TL | Trade licence |
| 15 Seller tax identifier | 100987654300003 | Group VAT TRN (Bahr Holding LLC as representative) |
| 4 Invoice currency code | USD | Contract currency |
Line computation:
| Line | Item | Qty | Gross price (44) | Net price (43) | Line net (42) | VAT 5% | Line net in AED | VAT line in AED (48) | Line amount in AED (49) |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Planned maintenance visits | 40 | USD 450 | USD 450 | USD 18,000 | USD 900 | AED 66,105.00 | AED 3,305.25 | AED 69,410.25 |
| 2 | HVAC spare parts | 50 | USD 160 | USD 140 | USD 7,000 | USD 350 | AED 25,707.50 | AED 1,285.38 | AED 26,992.88 |
| Totals | USD 25,000 | USD 1,250 | AED 91,812.50 | AED 4,590.63 | AED 96,403.13 |
Fields 30–33 carry USD 25,000 (net), USD 1,250 (tax) and USD 26,250 (gross); fields 35–38 carry one S-category breakdown at 5%. Because the document currency is not AED, the Guidelines also require the tax amount in the tax accounting currency: USD 1,250 × 3.6725 = AED 4,590.625, rounded to AED 4,590.63 — which here happens to reconcile with the sum of the line-level AED VAT (3,305.25 + 1,285.38). On a larger invoice with more lines, line-by-line rounding and invoice-level rounding will diverge by fils; Danat’s ASP validation rules must decide which prevails.
The twist: an intra-group invoice on the same day
Danat issues a second invoice the same day for USD 6,000 of management services to its sister company Bahr Real Estate LLC — a member of the same VAT Tax Group. Under MD 197 that transaction is an Excluded Transaction until 31 December 2028, so no Electronic Invoice is required. But had Danat’s master data populated field 11 with the representative’s TIN (taken from the group VAT TRN), the Noor invoice would have been routed to the wrong endpoint and the group’s eventual 2029 onboarding of intra-group flows would start from corrupted data. The commercial punchline: two invoices, same day, same seller — one fully in scope with dual identifiers, one outside the system for 24 months. A single “e-invoicing on/off” switch per entity will not work.
Observations and gray areas in V1.1
The field list is frozen — the scenario layer is not
V1.1 lists the minimum dataset only. The eight scenarios in the Guidelines (Free Zone, deemed supply, margin scheme, summary invoice, continuous supply, disclosed agent billing, e-commerce, exports) each switch on further conditional fields and predefined values — for example, a deemed supply must route to the FTA’s own endpoint. The 8-digit transaction type flag in field 5 is mandatory on every invoice, so the ERP must evaluate all eight scenarios even for a plain domestic sale (00000000).
The Tax Group exclusion is a VAT concept, the TIN rule is a Corporate Tax concept
MD 197 defines a Tax Group by reference to the VAT Law. Members of a Corporate Tax Group under Article 40 of the CT Law that are not in a common VAT group get no exclusion, while V1.1’s Highlight on TINs refers to the CT TRN. Groups whose VAT and CT perimeters differ must map each relationship twice. And because the exclusion is time-limited, the intra-group flows must still be mapped now — only the switch-on is deferred to 1 January 2029.
Accreditation can lapse under a business’s feet
A business that “appointed an ASP” months ago may have signed with a provider holding only MD 64 pre-approval. MD 168 gives such providers 30 days from 1 October 2026 to complete full accreditation or lose their approval — a window that closed at the end of October, side by side with the 30 October appointment deadline. An appointment of a provider that is not accredited under MD 168 is, in our view, not a compliant appointment. Verify the provider against the MoF register, not the sales deck.
Commercial invoice buyer identifiers are built for UAE buyers
Field 25 allows only TL, EID, PAS or CD. A non-VAT-registered UAE business invoicing a foreign corporate buyer has no obvious code — a foreign company has neither a UAE trade licence nor a passport. Until MoF clarifies, the export scenario rules and the ASP’s validation logic will decide what passes; this should be tested in the pilot environment, not discovered in January.
“Payment due date” and “Seller tax scheme code” are mandatory even where they look meaningless
A cash sale still needs a due date (the issue date), and a commercial invoice from a seller with no VAT registration is still told to use the default scheme value “VAT”. Neither is a drafting error to be “fixed” by IT — omitting them causes rejection.
Field 49 is ambiguously described
“The total amount payable for each line item expressed in AED” can be read as net or VAT-inclusive. PINT-AE semantics and the ASP’s validation rules, not the narrative description, should settle it — our example uses the VAT-inclusive reading. Agree the treatment with your ASP in writing.
A small drafting point with a large consequence
By removing MD 243 and MD 244 from its “read in conjunction with” list, V1.1 no longer signposts the legal obligations at all. Readers who rely on the Guidelines V1.1 of 1 June 2026 should note those still print the superseded 31 July 2026 ASP date. The interaction with FTA Decision No. 13 of 2026 (Article 54(bis) supplier verification before input tax deduction) is also worth flagging: from 2027, a structured e-invoice whose field 15 TRN and endpoint TIN do not reconcile is precisely the kind of document that undermines a buyer’s input tax claim.
UAE e-invoicing checklist: what businesses should do now
- If your Revenue is AED 50 million or more, confirm now that a signed ASP appointment exists and that the provider appears on the MoF register as accredited under MD 168, not merely pre-approved under MD 64.
- Reconcile TIN, CT TRN and VAT TRN for every legal entity and every VAT and CT group member, and correct any endpoint built from a representative’s number.
- Complete field-by-field mapping of the 51/49 lists in the ERP, treating fields 5, 15, 24–25 and 48–49 as the high-risk fields.
- Identify all VAT Tax Group intra-group flows, apply the MD 197 exclusion to 31 December 2028, but map them now.
- Agree with the ASP the treatment of rounding, field 49 and foreign buyer identifiers, and test each of the eight scenarios that applies to your business in the pilot environment.
- Re-engineer billing processes to issue and transmit within 14 Business Days of the transaction.
- For businesses below AED 50 million, use the period to 31 March 2027 to run the same exercise without the year-end pressure.
How TSAC can help
TSAC supports UAE businesses end-to-end on e-invoicing: scoping and Revenue-threshold analysis, TIN/TRN master-data reconciliation for groups, field-mapping reviews against the MoF mandatory fields and PINT-AE scenarios, ASP selection and accreditation due diligence (including access to accredited solutions through our partner network), and VAT technical review of tax categories, Tax Group exclusions and credit note flows. The field list is now final; the only open question is whether your data is ready for it on 1 January 2027. Book a free consultation with our e-invoicing team, or read how outsourced accounting can prepare your business for e-invoicing.
Frequently asked questions about the UAE e-invoice mandatory fields
What are the UAE e-invoice mandatory fields?
They are the minimum data every structured e-invoice must carry under the Ministry of Finance document. V1.1 (28 October 2026) keeps 51 mandatory fields for an electronic Tax Invoice and 49 for a commercial Electronic Invoice, unchanged from V1.0.
What changed in the UAE e-invoice mandatory fields V1.1?
No field was added, removed or renamed. V1.1 changes the legal references: MD 243 and MD 244 of 2025 now apply “and its amendments”, and ASP accreditation is governed by Ministerial Decision No. 168 of 2026, which repealed MD 64 of 2025.
What was the ASP appointment deadline for UAE e-invoicing?
Persons with Revenue of AED 50 million or more had to appoint an Accredited Service Provider by 30 October 2026 and must implement e-invoicing by 1 January 2027. Persons below that threshold must appoint by 31 March 2027 and implement by 1 July 2027.
Which TIN does a VAT group member use on an e-invoice?
Its own TIN, the first 10 digits of its own Corporate Tax TRN, as the electronic address in field 11. The group’s shared VAT TRN goes in field 15 as the seller tax identifier, so one invoice carries two different identifiers.
Are intra-group transactions in a VAT Tax Group excluded from e-invoicing?
Under Ministerial Decision No. 197 of 2026, transactions between members of the same VAT Tax Group are Excluded Transactions until 31 December 2028. They should still be mapped now, because the switch-on is only deferred to 1 January 2029.
Is my ASP appointment compliant if the provider only had pre-approval?
In our view, no. MD 168 of 2026 abolished pre-approval and gave pre-approved providers 30 days from 1 October 2026 to complete full accreditation. Check that your provider appears on the MoF register as accredited under MD 168.
Which mandatory fields carry the most mapping risk?
Field 5 (transaction type flag), field 15 (seller tax identifier), fields 24 to 25 (buyer identifiers) and fields 48 to 49 (AED line amounts on a Tax Invoice). Field 49 is also ambiguously described, so agree its treatment with your ASP in writing.
This publication is for general information only and does not constitute tax advice. It is based on the Ministry of Finance’s UAE Electronic Invoice Mandatory Fields V1.1 (28 October 2026) and the Ministerial Decisions referred to; where an Arabic text exists, the Arabic text prevails. Please contact TSAC for advice specific to your circumstances.