The UAE Ministry of Finance issued Electronic Invoicing Guidelines Version 1.1 on 1 June 2026, introducing two new appendices that clarify record-storage obligations under Ministerial Decision No. 243 of 2025 and set out treatment of advance payments and retention amounts under PINT AE invoicing rules.
The UAE Ministry of Finance has issued the UAE Electronic Invoicing Guidelines Version 1.1, dated 1 June 2026. The key updates introduced in Version 1.1 include the addition of:
- Appendix 4 – Further guidance in respect of storage obligations under Article 11 of Ministerial Decision No. 243 of 2025; and
- Appendix 5 – Advance Payments and Retention Clarification.
The updates are as follows:
Appendix 4 – Further guidance in respect of storage obligations under Article 11 of Ministerial Decision No. 243 of 2025
This appendix clarifies storage and retention obligations under the Electronic Invoicing System, as set out under Article 11 of Ministerial Decision No. 243 of 2025.
Obligation of the Person (as defined in the Ministerial Decision No. 243 of 2025)
Any Person subject to the Electronic Invoicing System must retain all Electronic Invoices, Electronic Credit Notes, and related data for the retention period set under the Tax Procedures Law, and must be able to produce these records to the Authority on request.
Role and Obligations of Accredited Service Providers (ASPs)
- Transactional Logs and Technical Traceability: ASPs must keep transactional logs separate from invoice content itself. These logs need unique transaction identifiers covering the full invoice exchange and reporting cycle, including transmission status and routing data. This technical data is treated as part of the ASP’s own operational/compliance duties, not as business document data the Person is required to retain under Article 11. Logging must follow both the Service Provider Agreement with OpenPeppol and the UAE Peppol Authority Specific Requirements (PASR).
- Delegation of Storage: A Person may contractually delegate storage to an ASP, but this doesn’t shift the underlying legal retention obligation under Article 11 — the Person remains ultimately responsible. ASPs may store invoices, credit notes, and associated data on the Person’s behalf, subject to their commercial agreement.
- Storage Location and Architecture: There’s no requirement that storage sit at any particular system layer (e.g., C1/C4). Any storage setup is acceptable as long as data is kept for the required period, integrity and security are maintained, and records can be produced to the Authority on request.
- Transmission Confirmation: ASPs must notify Persons, on an event-driven basis and without undue delay, once Electronic Invoices or Tax Data Documents have been successfully transmitted to the Authority — so the Person stays aware of compliance status.
Appendix 5 – Advance Payments and Retention Clarification
This Appendix clarifies how advance payments and retention should be treated for PINT AE e-invoicing purposes.
Advance Payments
In cases where the businesses receive an advance payment, a tax invoice must be issued at the time of receipt.
Therefore, when issuing the final invoice, it should cover only the remaining balance, not the full amount, as a tax invoice has already been issued for the advance.
A reference to the original invoice may be included under IBT-25 and IBT-26, or a note can be provided in IBT-022. The cbc: PrepaidAmount field may be left blank, since the subsequent invoice reflects only the outstanding amount and does not require any further adjustment of the advance.
For example, the total contract is for AED 10,000 plus VAT of 5 %. An advance payment is received for AED 1,000 + 5% VAT.
Retention
In contracts where retention arrangements apply, Businesses may continue following their existing commercial and accounting practices, provided such practices remain compliant with the applicable VAT and Electronic Invoicing requirements.
One such acceptable practice is outlined below:
- An Electronic Invoice may be issued for the amount payable by the Supplier after adjusting for the retention amount.
- A separate Electronic Invoice may subsequently be issued for the retained amount at the point in time when the Buyer becomes liable to release and settle the retained amount.
Businesses should ensure that the relevant contractual arrangements and payment obligations are appropriately reflected in the corresponding Electronic Invoices issued.
Earlier, the UAE Ministry of Finance (MoF) issued the Electronic Invoicing Guidelines (v1.0) on 23 February 2026, detailing the scope, operational framework, and phased rollout of mandatory e-invoicing.
