The Ministry of Finance of the UAE has published a public consultation document detailing the planned implementation of eInvoicing in the country. This document, titled the eInvoicing Programme Consultation Paper, spans 168 pages and outlines the main features and framework of the proposed eInvoicing model, including specific use cases and anticipated data requirements.

According to EY, the Ministry invites stakeholders to submit their comments on the proposed eInvoicing regime by 27 February 2025. The document sets forth mandatory fields for eInvoicing and notes that additional conditional fields will be included in a forthcoming Data Dictionary, which is yet to be released.

In October 2024, the UAE MoF formally announced that eInvoicing will be introduced in the UAE starting June 2026. This initiative is part of the broader digital transformation and tax compliance efforts within the country. The consultation aims to help businesses evaluate how the new eInvoicing data fields will affect their billing systems and overall processes.

The consultation framework indicates that eInvoicing requirements will apply to all businesses in the UAE, regardless of their VAT registration status. The document emphasizes the importance of compliance with data requirements, detailing mandatory fields for both tax invoices and commercial invoices in XML format. The minimum requirements include 50 fields for tax invoices and 49 fields for commercial invoices, many of which are currently not addressed by UAE VAT legislation.

The Consultation Document also presents 16 use cases for generating tax invoices and tax-credit notes, with five identified as mandatory. These include standard tax invoices and self-billing tax invoices, while others cater to specific scenarios like zero-rated supplies and reverse-charge mechanisms.

Although further details on the implementation strategy are pending, the Ministry has reiterated that the rollout will occur in phases. Stakeholders are encouraged to provide feedback in response to a set of specific questions outlined in the Consultation Document.

This initiative offers interested parties an opportunity to contribute to the refinement of the eInvoicing framework and enhance the Data Dictionary before the feedback deadline of 27 February 2025.