The United Arab Emirates (UAE) is progressing quickly on its e-invoicing journey, and it is on track to roll out the new regime by July 2026. The government aims to improve invoicing efficiency and accuracy and reduce tax fraud with this move. And it is aligned with the region’s ‘We the UAE 2031 Vision’ and global best practices in digital taxation.

In February 2025, the Ministry of Finance (MoF) issued it Public Consultation Document on e-Invoicing that elaborates on the new regime. It explains the main features of the e-invoicing model, the framework to be used, the expected Data Dictionary, and some use cases. In this article, we will look at the use cases specified by the Ministry of Finance.

Public Consultation Document, February 2025

The Public Consultation Document released in February this year aims to help businesses evaluate the impact of e-invoicing on their processes and billing systems. Feedback from stakeholders, including businesses and service providers, will help the MoF understand their on-ground requirements, highlight gaps, and identify additional needs.

The document provides a Data Dictionary (PINT AE), that defines the required data elements for different invoice types such as tax invoices, credit notes, self-billing. It specifies the minimum mandatory fields (50 for tax invoices and 49 for commercial invoices). The full scope of the Data Dictionary is expected to include additional conditional fields, which are yet to be released.

The document also states that UAE’s e-invoicing regime will follow the PEPPOL-based 5‑Corner Decentralized Continuous Transaction Control and Exchange (DCTCE) model.

The Use Cases

The Consultation Document also provides 16 use cases that represent common invoice or credit-note scenarios in the UAE.¹ Five of these are mandatory and businesses must ensure that their e-invoicing systems always support these. The remaining 11 include special business scenarios that require additional data.  Given the details provided in the Consultation Document, and depending on scenario complexity, data elements per invoice can reach up to 120 fields, classified as mandatory, conditional, or optional. Total across all scenarios may cover more than 135 business terms in the PINT AE Data Dictionary, ensuring detailed structuring and precise compliance.

The 5 Mandatory Use Cases

These use cases establish the fundamental requisites for any e‑invoicing implementation in the UAE.²

1. Standard tax invoice: This is the basic e-invoice for taxable supplies. This must include mandatory as well as frequently used optional fields defined in the Data Dictionary. Standard tax invoices demand 50 mandatory data points, including 15 new ones not currently stipulated by UAE VAT law.

2. Standard tax credit note: This will be used to correct or adjust previously issued e-invoices. This also requires both mandatory and frequently used optional fields.

3. Commercial invoice: This is to be used for shipping, exports, or customs processes. It includes the same core data fields as the first two. Commercial invoices (and exempt/out-of-scope supplies) require 49 mandatory data fields.

4. Self‑billing invoice: This is to be created by the buyer on behalf of the supplier. It will include standard invoicing data elements.

5. Self‑billing tax credit note: This will be used to correct or adjust a self-billing invoice and will include the mandatory data fields as specified by the Data Dictionary.

The 11 Additional (Conditional) Use Cases

These use cases add scenario-specific data requirements beyond the standard invoice fields:

1. Supply under reverse‑charge mechanism: Additional details required to specify reverse-charge nature of transaction.

2. Zero‑rated supplies: Must include zero-rating reason and exemption reason codes. These are new fields that were not previously required under VAT regulations.

3. Deemed supply: This includes defined additional information beyond standard.

4. Disclosed agent billing: Here the agent will issue an e-invoice on behalf of the principal. This requires additional data beyond standard fields.

5. Summary tax invoice: This is a consolidated invoice (e.g., for multiple transactions. It requires additional data elements.

6. Continuous supplies: This is for subscription or recurring services/invoices and has additional specific data requirements.

7. Supply involving free trade zones: This mandates additional identifiers and free-zone specifics.

8. Supply through e‑commerce: Built for the digital economy, this requires details of digital or e‑commerce-related metadata.

9. Exports: This requires export-specific data elements beyond the standard invoice fields.

10. Margin scheme: This is for special tax-scheme pricing edges and requires related information beyond standard invoicing.

11. Disclosed agent billing tax credit note: This adjusts agent-issued invoices and requires extra fields beyond the standard credit note template.

The UAE’s 2025 e‑Invoicing consultation document sets out a robust, standardized framework for digital invoicing that applies across a wide array of transaction types. Businesses in the region must now prepare to comply with the requirements of the 16 use cases, especially the 5 mandatory ones. They must align with the PINT AE Data Dictionary, integrate with accredited PEPPOL partners, and modernize their own legacy invoicing and revenue management systems to ensure compliance and a seamless transition to the e-invoicing regime by next year.

Write to us to discover how SunTec Xelerate E-Invoicing can help your business move beyond compliance to efficiency and control. Our product can empower your Finance, Tax, and IT teams with real-time visibility and insights. As the July 2026 deadline approaches, partner with us to future-proof your invoicing, safeguard compliance, and unlock operational agility.