Businesses with Revenue of AED 50 million or more must appoint an Accredited Service Provider (ASP) by 30 October 2026 and begin e-invoicing on 1 January 2027. Before the conversation turns to providers, one prior question deserves a precise answer: which phase does the business actually fall into?
With the second Corporate Tax filing season behind them, UAE finance teams have turned to the next date in the calendar. The Ministry of Finance moved the first-phase ASP appointment deadline from 31 July to 30 October 2026 through Ministerial Resolution No. 66 of 2026. The go-live date of 1 January 2027 stayed where it was.
Much of the current discussion is about choosing a provider. That discussion rests on an earlier one. The phases turn on a single number – AED 50,000,000 – and it is a number that is easy to misread.
What the threshold measures
The phases are set by Ministerial Decision No. 244 of 2025. A Person subject to the Electronic Invoicing System whose Revenue equals or exceeds AED 50,000,000 is in the first phase. A Person below that figure appoints an ASP by 31 March 2027 and goes live on 1 July 2027, and Government Entities follow on 1 October 2027.
The decision defines Revenue in a single sentence: the gross income earned by a Person during the most recent Accounting Period, based on financial statements prepared in accordance with applicable legislation in the State. Where such statements are not available, other documentation acceptable to the Federal Tax Authority may be used. The Accounting Period is the period for which the Person is required to prepare financial statements.
Three features of that wording do most of the work. The measure is gross income, not profit. The source is the financial statements, not a tax return. And the test is applied to a Person – each entity on its own.
Where the reading tends to slip
Several working assumptions now in circulation do not sit comfortably with that text.
The figure is not VAT turnover
Some commentary ties the threshold to taxable supplies reported on VAT returns. The decision does not mention VAT returns. It points to gross income in the financial statements, which can differ from the figures reported for VAT – through income outside the scope of VAT, for instance, or differences in timing.
The test is applied entity by entity
The decision measures the Revenue of each Person and contains no rule that aggregates the income of related entities. Within a group, one company may therefore sit in the first phase while its sister companies sit in the second – a point that bears on intra-group billing, shared systems and the choice of a single provider. The decisions do not address VAT groups directly, so the Ministry's guidelines should be read alongside them.
Income outside e-invoicing still counts
Under Article 5(2) of the decision, business-to-consumer transactions are not subject to the system, nor is a Person engaged exclusively in them – until such time as the Minister determines otherwise by decision. The definition of Revenue, however, carries no carve-out for consumer income. On the plain wording, a business with substantial retail sales and a smaller business-to-business line may find that its total gross income places it in the first phase for the business invoices it does issue.
Gross income is not always the top line
The decision speaks of gross income, not of revenue in the accounting sense. It does not say whether interest, dividends or gains form part of the figure. Holding companies, and businesses with meaningful income below the operating line, should take a considered view rather than read the answer off the first line of the income statement.
Close to the line
For a calendar-year business, the most recent Accounting Period is the year ended 31 December 2025. These are the same financial statements that supported the Corporate Tax return filed last month, so the starting figure is already reviewed and on file. Businesses with a non-calendar year-end should first identify which period is the most recent one before drawing any conclusion.
The cost of a misreading runs in both directions. A business that wrongly places itself in the second phase misses 30 October; Cabinet Decision No. 106 of 2025 sets an administrative penalty of AED 5,000 for each month, or part of a month, of delay in appointing an ASP or implementing the system. A business that wrongly places itself in the first compresses a significant systems project into a timetable it did not need.
Sources
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System
- Ministerial Resolution No. 66 of 2026 Amending Certain Provisions of Ministerial Resolution No. 244 of 2025
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System
- Cabinet Decision No. 106 of 2025 on e-invoicing violations and administrative penalties
- Ministry of Finance – eInvoicing