The decision concerns the providers of the service, not the businesses that issue invoices. It matters, however, to anyone who has already chosen a provider for the 30 October appointment deadline: if the provider does not complete accreditation in time, its preliminary approval ends.
What happened
The UAE Ministry of Finance (MoF) issued Ministerial Decision No. 168 of 2026, which sets the eligibility criteria and the accreditation procedure for Service Providers under the Electronic Invoicing System, the providers of the e-invoicing service (also known as Accredited Service Providers, or ASPs). The MoF announcement is dated 9 October 2026 and the decision is in force from 1 October 2026. It repeals Ministerial Decision No. 64 of 2025, its amendments and Ministerial Decision No. 56 of 2026.
What changes in practice
Previously there was a preliminary approval stage, followed by accreditation. The new decision removes that stage: a provider must complete the defined assessment and testing before accreditation is granted. It may still use third-party Peppol products (Peppol is the international network for exchanging electronic invoices) and outsource parts of its service, but it remains fully responsible for compliance. The decision also covers renewal, ongoing evaluation, termination and an objection process against termination. Providers that received preliminary approval have a transition period of up to 30 days from 1 October 2026 to meet the new requirements, which is about 31 October; the announcement does not state the exact date. A new application is not required unless the MoF determines otherwise. If the requirements are not met in time, the preliminary approval is terminated.
Who it applies to
Directly, to service providers. Indirectly, to businesses that have to choose a provider for e-invoicing: the first phase covers groups with revenue of AED 50 million or more (about USD 13.6 million), with the provider to be appointed by 30 October 2026 and go-live on 1 January 2027. A smaller business has no such obligation today and can treat the decision as information only.
The exposure
A business that has chosen a provider holding only preliminary approval may reach the appointment deadline with a supplier whose status changes at around 31 October. The announcement does not say what happens to contracts already signed, or whether the business has to repeat its appointment, and neither point should be assumed. No penalties for the client business appear in the announcement.
What to do now
First, ask the provider in writing whether it is already accredited or holds preliminary approval only, and by what date it will complete the requirements. Second, if it holds preliminary approval only, agree a fallback with it before 30 October. Third, read the decision itself on the MoF website, as the announcement only summarises the transition conditions. Fourth, record the date of the check and the reply received in the compliance file.
Sources
Published 11 October 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.