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    E-invoicing

    Do invoices between your group companies need e-invoicing? What Ministerial Decision 197 of 2026 changed

    Invoices between companies in the same VAT tax group are out of UAE e-invoicing for 24 months from 1 January 2027. Invoices between group companies outside that tax group are not. Ministerial Decision No. 197 of 2026 also removed the e-invoicing requirement to store records in the UAE and the FTA system-failure notice. Here is what each change means and what to fix in your ERP before go-live.

    12 November 2026
    7 min readLast reviewed: 12 November 2026 · Reviewed by Muhammad Imran, ACMA

    Not if both companies are members of the same VAT tax group. Ministerial Decision No. 197 of 2026, in force since 1 October 2026, takes invoices between members of the same VAT tax group out of the UAE e-invoicing system for 24 months from 1 January 2027. Invoices between group companies that are not in that VAT tax group stay in scope, even when the owners are the same.

    The decision changed three other things. The e-invoicing rules no longer require e-invoice records to be stored in the UAE, the duty to notify the FTA of a system failure is repealed, and the general time limit for issuing an e-invoice is now 14 business days instead of 14 days.

    The dates for appointing an Accredited Service Provider (ASP) and going live sit in Ministerial Decision No. 244 of 2025, as amended by Ministerial Resolution No. 66 of 2026. For in-scope businesses, the fines in Cabinet Decision No. 106 of 2025 apply today. Cabinet Decision No. 173 of 2026 repeals and replaces Cabinet Decision No. 106 of 2025 from the day after its publication in the Official Gazette. Decision 197 amends none of these.

    Why this matters now: a Phase 1 business goes live on 1 January 2027, the same day the exclusion starts. If your ERP cannot tell an invoice to a tax group member from an invoice to a sister company outside the tax group, you will either send invoices you did not need to send or miss invoices you had to send, and missed invoices carry fines. Both are avoidable with work done before go-live, and the checklist at the end of this article sets it out.

    What are the changes at a glance?

    ChangeWhat it meansSourceDate checked
    Tax group exclusionBusiness transactions between members of the same VAT tax group are excluded from the system for 24 months starting 1 January 2027Ministerial Decision No. 243 of 2025, Article 4(1)(f), as replaced by Ministerial Decision No. 197 of 2026, Article 212 November 2026
    New and deleted definitionsTax Group and Taxable Person are now defined by reference to the VAT Law; the Accredited Service Provider definition is replaced; the System Failure definition is deletedMinisterial Decision No. 197 of 2026, Article 112 November 2026
    Record keepingKeep e-invoices, e-credit notes and associated data for the period in the Tax Procedures Law and be able to produce them to the FTA on request. The requirement to store them in the UAE is removedMinisterial Decision No. 243 of 2025, Article 11, as replaced by Ministerial Decision No. 197 of 2026, Article 212 November 2026
    System failure noticeThe duty to notify the FTA of a system failure within 2 business days is repealedMinisterial Decision No. 197 of 2026, Article 3, repealing Article 12 of Ministerial Decision No. 243 of 202512 November 2026
    Time limit to issueE-invoices and e-credit notes within 14 business days of the transaction date (previously 14 days), subject to Article 6(4)Ministerial Decision No. 243 of 2025, Article 6(5), as replaced by Ministerial Decision No. 197 of 2026, Article 212 November 2026
    Date in force1 October 2026Ministerial Decision No. 197 of 2026, Article 412 November 2026
    Deadlines and finesNot amended by Decision 197Ministerial Decision No. 244 of 2025, as amended by Ministerial Resolution No. 66 of 2026; Cabinet Decision No. 106 of 2025 (Cabinet Decision No. 173 of 2026 once in force)12 November 2026

    Facts checked on 12 November 2026 against the decision text and the Ministry of Finance news release of 19 October 2026, both listed under Sources.

    What does the tax group exclusion mean for your group?

    From 1 January 2027, and for 24 months, business transactions between members of the same tax group are outside the Electronic Invoicing System. The decision defines a tax group as two or more persons registered with the FTA as a single taxable person under the VAT Law.

    The test is therefore VAT tax group membership, not membership of a corporate tax group. Companies in the same corporate group that are not in the same VAT tax group are not covered by this exclusion, and their invoices to each other stay in scope.

    Sales from any tax group member to customers outside the group are unaffected and go through the system on your phase's timetable.

    Two further points. Article 4(3) of Ministerial Decision No. 243 of 2025, as amended, allows a business to issue e-invoices voluntarily for excluded transactions; if it does, Decision 243 and all related e-invoicing decisions apply to those transactions, except the decisions on violations and administrative penalties. And the exclusion ends after 24 months, so intra-group flows should be set up so they can move into the system later without rebuilding the ERP.

    Hypothetical example: a trading group has four UAE companies. Three of them, A, B and C, form one VAT tax group; D is registered for VAT on its own. From 1 January 2027, invoices from A to B are excluded. Invoices from A to D stay in scope, because D is outside the VAT tax group even though it has the same owners. Invoices from B to an outside customer are in scope as before. The finance team flags the intra-group customer accounts in each company's ERP and reviews the flags whenever the tax group membership changes.

    Do e-invoice records still have to be stored in the UAE?

    Not under the e-invoicing rules. The original Article 11 required any person subject to the system to store e-invoices, e-credit notes and associated data in the UAE. The new Article 11 drops that requirement. It requires you to keep those records for the period set by the Tax Procedures Law and to make sure they can be produced to the FTA on request.

    For businesses that were concerned about data residency, where the data sits is now a business choice under the e-invoicing rules. Make that choice deliberately and record it: other legal and contractual obligations may still apply to your data, and the duty to produce records on request has not changed.

    What happened to the system-failure notice?

    Article 3 of Decision 197 repeals Article 12 of Decision 243, which required issuers and recipients to notify the FTA of a system failure within 2 business days. The definition of system failure is deleted too. Since 1 October 2026, that notice no longer applies.

    The duty to issue and transmit e-invoices on time remains, and so do the fines for in-scope businesses, set out in the table below. An outage in your own systems or at your ASP is still a risk to plan for.

    Did the time limit for issuing an e-invoice change?

    Yes, slightly. Article 6(5) now gives the issuer 14 business days from the date of the transaction to issue and transmit an e-invoice or e-credit note through the system, where the earlier text said 14 days. The clause is subject to Article 6(4), under which an issuer registered for VAT follows the timeline in the VAT Law. Check which rule your ERP and invoice approval workflow are built around.

    What did Decision 197 not change?

    • The Phase 1 dates. In-scope businesses with revenue of AED 50 million or more had to appoint an ASP by 30 October 2026 and must implement the system by 1 January 2027 (Ministerial Decision No. 244 of 2025, Article 5(1)(a), as amended by Ministerial Resolution No. 66 of 2026).
    • The fines for in-scope businesses, set out in the table below.
    • The use of an ASP. Issuers and recipients still meet their obligations through an Accredited Service Provider.

    Cabinet Decision No. 173 of 2026 repeals and replaces Cabinet Decision No. 106 of 2025 from the day after its publication in the Official Gazette. Until then, the fines in Cabinet Decision No. 106 of 2025 apply.

    The main fines for in-scope businesses:

    ViolationToday: Cabinet Decision No. 106 of 2025Once Cabinet Decision No. 173 of 2026 is in force
    Failing to implement the system or appoint an ASPAED 5,000 for each month or part of a month of delayAED 5,000 for the first instance, and AED 5,000 for each month or part of a month that the failure continues, up to AED 50,000 in any 12 consecutive months
    E-invoice or e-credit note not issued or sent on timeAED 100 each, up to AED 5,000 per calendar monthAED 100 each not issued and transmitted, up to AED 5,000 per calendar month
    Late notice to your ASP of changes to registered dataAED 1,000 for each day of delay or part of a dayAED 250 for each day of delay or part of a day, up to AED 5,000 per calendar month

    If your business missed the 30 October deadline, our article on what Phase 1 businesses should do now, linked below, sets out a 30-day plan.

    What should finance teams do now?

    1. Map your VAT tax group in the ERP. List every member, flag intra-group customer and supplier accounts, and confirm that from 1 January 2027 those invoices are routed outside the e-invoicing flow, unless you decide to issue them voluntarily.
    2. List group companies that are outside the VAT tax group. Their transactions with each other and with tax group members stay in scope.
    3. Put the end of the 24 months in the compliance calendar, and build the ERP flag so it can be switched off without rework.
    4. Update the record-keeping policy: the retention period under the Tax Procedures Law, the format, who retrieves the records, and how quickly you can produce them to the FTA.
    5. Review the ASP contract terms on where data is stored, retention, access, retrieval and exit. The e-invoicing rules no longer fix the storage location, but other laws and contracts may, so record the decision and the reason.
    6. Remove system-failure steps from your procedures only where they referred to the FTA notice. Keep internal escalation, contact with your ASP and a catch-up plan for invoices delayed by an outage.
    7. Check the invoice timing rules in your ERP and approval workflow against Article 6: the VAT Law timeline for VAT-registered issuers, and 14 business days under Article 6(5).
    8. Leave your deadlines as they were; Decision 197 did not change them. Update your fine assumptions to Cabinet Decision No. 173 of 2026 from the day after its publication in the Official Gazette.

    How can Valorin help?

    Valorin is an independent advisory firm, not an ASP. We work through one window: a gap assessment against PINT AE (the UAE e-invoicing data standard) and of your master data, what to require from an ASP, onboarding, and ERP integration and testing to go-live. Your ASP exchanges and reports the e-invoices. To start, book a short call.

    For a group, we help your finance team list which entities and invoice flows sit inside and outside your VAT tax group, using your FTA registration records, so the business can decide how each flow is set up in the ERP. To book a short call, message us on WhatsApp at 058-2754282 or use the contact form.

    Sources

    Last reviewed: 12 November 2026 · Reviewed by Muhammad Imran, ACMA

    General information only, not legal or tax advice.

    Valorin is an independent advisory firm, not affiliated with the FTA or MoF.

    Frequently asked questions

    When did Ministerial Decision No. 197 of 2026 come into force?

    On 1 October 2026 (Article 4 of the decision). The Ministry of Finance announced it on 19 October 2026.

    Are transactions inside a VAT tax group excluded from UAE e-invoicing?

    Yes, for 24 months starting 1 January 2027 (Ministerial Decision No. 243 of 2025, Article 4(1)(f), as amended). Sales from tax group members to anyone outside the group stay in scope.

    Does a corporate tax group qualify for the exclusion?

    The decision defines a tax group by reference to the VAT Law: two or more persons registered as a single taxable person for VAT. The exclusion follows VAT tax group membership.

    Do we still have to store e-invoices in the UAE?

    The e-invoicing rules no longer require it. Article 11 now requires you to keep e-invoices, e-credit notes and associated data for the period in the Tax Procedures Law and to be able to produce them to the FTA on request.

    Do we still need to notify the FTA of a system failure?

    No. Article 3 of Decision 197 repealed Article 12 of Decision 243, which required that notice within 2 business days, and the definition of system failure was deleted.

    Did Decision 197 change the e-invoicing deadlines or fines?

    No. The deadlines are in Ministerial Decision No. 244 of 2025, as amended by Ministerial Resolution No. 66 of 2026, and Decision 197 does not amend them. It did not change the fines either: for in-scope businesses, the fines in Cabinet Decision No. 106 of 2025 apply today. Cabinet Decision No. 173 of 2026 repeals and replaces Cabinet Decision No. 106 of 2025 from the day after its publication in the Official Gazette.

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