UAE Amends E-Invoicing Rules for Tax Groups and Overseas Data Storage

The UAE Ministry of Finance has amended the national electronic invoicing framework under Ministerial Decision No. 197 of 2026, which took effect on 1 October 2026 following an announcement on 19 October 2026. The decision amends Ministerial Decision No. 243 of 2025, introducing operational flexibility for companies preparing for mandatory e-invoicing.

Under the amended rules, transactions between members of the same tax group are granted a 24-month temporary exclusion from the e-invoicing system starting 1 January 2027 and running until 31 December 2028. However, external supplies by group members to non-group entities remain subject to standard e-invoicing obligations. The decision also clarified that e-invoices and e-credit notes must be issued and transmitted within 14 business days of the transaction.

In addition, amended Article 11 removes the statutory requirement to store electronic invoices, credit notes, and associated records exclusively inside the UAE. Businesses are now permitted to use overseas and cloud-based storage, provided records are retained for the statutory period mandated by the Tax Procedures Law and made available to the Federal Tax Authority (FTA) upon request.

The amendment also repeals Article 12, removing the previous requirement for businesses to notify the FTA of system failures within two business days. Despite these reliefs, the Ministry reaffirmed that implementation deadlines under Ministerial Decision No. 244 of 2025 remain in place. Businesses generating AED 50 million or more in gross revenue must appoint an Accredited Service Provider by 30 October 2026 ahead of going live on 1 January 2027, while businesses below that threshold must appoint a provider by 31 March 2027.