UAE e-invoicing decisions of September 2025: a timetable for packaging distributors

On 29 September 2025 the UAE Ministry of Finance issued Ministerial Decisions No. 243 and No. 244 of 2025, setting the framework and the phased timetable for electronic invoicing. As EY’s alert of 30 September 2025 summarises, the system applies to businesses conducting commercial transactions in the UAE, including non-residents, unless a transaction is specifically excluded, and the decisions take effect on publication in the Official Gazette. B2C transactions are excluded until further notice, according to Andersen’s summary of the same date.

For distributors of strapping and packaging components, the change is less about the look of an invoice and more about the data behind it. Structured e-invoices expose inconsistent item codes, units and descriptions that a PDF invoice could hide.

The timetable announced in September 2025

Group	Appoint an Accredited Service Provider by	E-invoicing required from
Selected pilot participants	Not applicable	1 July 2026
Voluntary adopters	Not applicable	1 July 2026
Businesses with revenue of AED 50 million or more	31 July 2026	1 January 2027
Businesses with revenue below AED 50 million	31 March 2027	1 July 2027
Government entities	31 March 2027	1 October 2027

The exclusions listed in the decisions include government entities acting in a sovereign capacity, certain international airline services, international goods transport with airway bills for 24 months, and exempt or zero-rated financial services. E-invoice data must be stored in the UAE.

Work out which date is yours

The revenue test decides the phase, so start there. Confirm which legal entities trade in the UAE, which revenue figure applies to each and whether any of them is likely to join the pilot or adopt voluntarily from 1 July 2026. A group with one large trading company and one small one may face two different deadlines.

A distributor with revenue below AED 50 million has until 1 July 2027 to go live, but its larger customers will be issuing and receiving e-invoices from 1 January 2027. Expect those customers to ask about your readiness before your own deadline arrives, and plan the answer.

A phase-by-phase plan from October 2025

Period	Distributor task
Late 2025	Map invoicing flows: sales invoices, credit notes, any self-billing and any billing through agents
Late 2025	Review the item master and customer master data (see below)
First half of 2026	Shortlist Accredited Service Providers and test the ERP connection
By 31 July 2026	Appointment deadline for businesses with revenue of AED 50 million or more
Second half of 2026	Test with customers and train the sales administration team
1 January 2027 or 1 July 2027	Go live on the date for your group

The structured data fields come from the e-invoicing technical specifications; EY notes that a data dictionary was released for public consultation in February 2025. Master data cleaned in late 2025 can be mapped to whatever fields the final specifications require.

For a packaging catalogue, that clean-up has a specific shape. Near-identical items need one code per variant (width, wire diameter or sheet thickness, finish and pack size), a fixed description pattern and a stored base unit with its carton or roll conversion. Customer records need correct tax registration numbers and legal names, and discontinued codes should be blocked so they cannot reach a new invoice.

Credit notes, returns and short deliveries

Distributors issue credit notes for short shipments, damaged cartons and returns. Credit notes fall within the system alongside invoices, and Andersen’s summary states that both must be issued within 14 days of the transaction. Review how often your team issues manual credits, who approves them and how each one references the original invoice. A clear process before the go-live date avoids rushed corrections afterwards.

Check pricing units at the same time. If a customer is invoiced per thousand pieces and credited per carton, the two documents will not reconcile automatically, however good the provider is.

Choosing an Accredited Service Provider

In-scope businesses must appoint an Accredited Service Provider by the deadline for their group, and the Ministry has published a pre-approved list. Questions worth asking a provider:

1. How will it connect to your ERP or accounting system, and who maps the fields?
2. How are item codes, units and descriptions transmitted, and can they be validated before sending?
3. How are credit notes linked to the original invoice?
4. Where is the data stored, given the requirement to keep it in the UAE?
5. What testing environment is available before your mandatory date?

Purchasing from overseas suppliers

Import purchasing has its own documents: the supplier’s commercial invoice, the packing list and the customs declaration. Make sure supplier item references map cleanly to your own codes, so that a buckle cleared through customs is the same item you then sell on an e-invoice. Whether a particular foreign supplier falls within the UAE system depends on its own UAE tax position; that is a question for a tax adviser rather than for the purchasing team.

Keep the component data consistent

Start the clean-up with the families you sell most. The galvanized wire buckle, sheet metal clip and PET strap pages show the attributes that distinguish each variant, which makes a useful template for an item master. Questions about specific items can be sent through the enquiry page.