On 19 October 2026 the UAE Ministry of Finance issued Ministerial Decision No. 197 of 2026, amending the rules on electronic invoicing (e-invoicing in the UAE). The amendment eases three previously painful points for business — intra-group transactions, storage of e-invoices and the duty to notify the FTA about system failures.
What exactly changes
Decision No. 197 amends the earlier Ministerial Decision No. 243 of 2025 — the base document on UAE e-invoicing adopted last autumn. Three key changes concern tax groups, storage of e-invoices and incident notifications. The text takes effect on 1 October 2026.
According to the MoF, the amendments aim to reduce the operational burden on business during the rollout, add flexibility and preserve a comfortable business environment in the UAE. The same approach has already been applied to the 9% UAE corporate tax: deadlines are shifted and softened where companies simply cannot integrate the requirements in time.
24-month grace for tax groups
The headline change is a transition period for intra-group operations. From 1 January 2027 to 31 December 2028 — exactly two years — intra-group transactions between companies in the same tax group are excluded from mandatory e-invoicing.
This is a tangible relief for holding structures. At the rollout stage, companies get a full 24 months to align internal ERP processes, onboard an ASP (Accredited Service Provider certified by the FTA) and run their document flow — without the risk of being fined for a late intra-group transfer between subsidiaries. From 1 January 2029 onwards, intra-group transactions will fall under e-invoicing on the usual basis.
Overseas storage of e-invoices — now permitted
The second change concerns Article 11 of Decision No. 243. The previous wording required e-invoices to be stored strictly on servers inside the UAE. That requirement is now removed: what matters is that invoices are stored securely and remain accessible to the FTA on request — the physical data centre no longer matters.
For international groups that already run on unified cloud infrastructure (SAP, Oracle NetSuite, Microsoft Dynamics on regional AWS or Azure regions), this removes a separate cost item of relocating data to UAE-local servers. The one condition is that the storage provider guarantees invoice integrity, logging and the ability to produce any document on FTA demand.
System-failure notice — repealed
The third change is the full repeal of Article 12 of Decision No. 243 together with the corresponding definition in Article 1. The previous rule required business to notify the FTA within two working days of any e-invoicing system failure. That procedure is scrapped — a separate formal letter on every technical issue is no longer required.
This is not a removal of accountability for the accuracy of reporting, but a removal of paper duplication. All incidents and their consequences continue to be reflected in standard ASP quality-control processes and in the final VAT and corporate-tax returns.
Rollout timeline: who onboards when
The overall UAE e-invoicing calendar after the amendments is unchanged and still consists of three waves:
- July 2026 — large businesses with annual revenue of Dh50 million and above. The first mandatory wave.
- January 2027 — SMEs (small and medium-sized enterprises).
- 2028 — full coverage: all VAT and corporate-tax payers, including intra-group transactions (after the 24-month grace ends).
For each wave, companies must choose and onboard an FTA-accredited ASP in advance. The FTA maintains the list of accredited ASPs and updates it as new providers join.
What this means for UAE business
Decision No. 197 is part of the government’s broader line of easing the operational burden when rolling out new tax regimes. For companies, three practical takeaways stand out.
First, holding structures with two or three or more entities in a tax group now have a real 24 months to agree on a single ASP, upgrade their ERP and set up intra-group reconciliations — without rushing. Second, international groups no longer need to relocate data into UAE-local data centres — it is enough to ensure FTA access and archive integrity. Third, finance and IT teams get rid of the routine of separate FTA notifications on every incident.
This article is for information only and does not constitute tax advice. Verify timelines and conditions against the latest MoF and FTA publications before making decisions.
