UAE eInvoicing agents and representatives: a practical reading of Article 8 of Decision 243/2025

Published 24 October 2026 · Updated 25 October 2026 · Official texts of Decisions 243/2025 and 197/2026 read 25 October 2026 · Other source links last reviewed 22 October 2026 · 13 min read

Many businesses do not have one person doing every step of an invoice process. A sales team may confirm the transaction, finance may check the accounting data, an enterprise resource planning (ERP) system may create a document, and a shared-service team or an outside firm may send it. UAE eInvoicing therefore raises a practical question: when someone else acts for a business, who may issue and transmit the Electronic Invoice, and what remains the business’s own responsibility?

This guide explains Article 8 of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System, the provision headed “Agent”. It sets out, in our own words, what the article actually says, what it leaves open, how it relates to Articles 6, 9 and 10, and how an agent differs from an accredited service provider, a software vendor or a tax adviser. It ends with editorial scenarios, a checklist and short answers to common questions. It is an operational reading aid, not legal or tax advice.

What Article 8 says

We read the official English text of Decision 243/2025 on the Ministry of Finance website on 25 October 2026. Article 8 is a single sentence. Paraphrased, it provides that where an agent is acting on behalf of a principal, the agent is permitted to issue and transmit the Electronic Invoice or the Electronic Credit Note through the Electronic Invoicing System on that principal’s behalf.

Broken into its parts, the provision contains five elements:

• Who: an agent who is acting on behalf of a principal. The article presupposes an existing agency relationship; it does not create one.
• What acts: issuing and transmitting. These are the same two verbs Article 6(1) uses for the Issuer’s core obligation.
• Which documents: both the Electronic Invoice and the Electronic Credit Note, each defined in Article 1 as a document issued, transmitted and received in a structured electronic format that enables automatic and electronic processing.
• Which channel: through the Electronic Invoicing System, not by email, PDF or paper outside it.
• On whose behalf: the principal’s. The document is issued for the principal, not in the agent’s own name.

The wording is permissive: the agent may do these things. Read on its own terms, the article allows an agent to perform the issuing and transmitting step for a principal; it does not oblige a business to use an agent, and it does not oblige an agent to act.

We also checked Ministerial Decision No. 197 of 2026, which amends Decision 243/2025 and came into force on 1 October 2026. It changes Article 1 (the Accredited Service Provider definition, new Tax Group and Taxable Person definitions and deletion of the System Failure definition), replaces Article 4, Article 6(5) and Article 11, and repeals Article 12. It does not amend Article 8, Article 6(1), Article 6(7), Article 9 or Article 10. On the texts we read, Article 8 therefore still stands in its original wording.

What Article 8 does not say

A short provision invites over-reading. Several points that teams often assume are not in the text, and this guide does not supply them:

• No definition of agent or principal in Decision 243/2025. Article 1 does not define either term. The separate VAT framework is relevant context but does not automatically supply every answer for the eInvoicing rule. The VAT Decree-Law, Article 9(1), treats a supply made through an agent acting in the name and on behalf of a principal as a supply by the principal. The VAT Executive Regulation, Article 59(11), separately permits an agent who is a Registrant to issue a VAT Tax Invoice for a supply made for and on behalf of its principal, subject to the stated record-keeping conditions and provided the principal does not issue a Tax Invoice for that supply. These are VAT supply and Tax Invoice rules; do not treat them as additional words in Article 8.
• No word “representative”. The heading of Article 8 is “Agent”. This site uses “agent or representative” because businesses use both words, but the legal text speaks only of an agent and a principal.
• No conditions or formalities. The article does not mention VAT registration of either party, a written mandate, a power of attorney, notification to the Federal Tax Authority (FTA) or any approval. We have not found such a requirement in Decision 243/2025 and do not assert one; equally, we cannot confirm that no other rule imposes one.
• No transfer of obligations or liability. The article says the agent may issue and transmit on the principal’s behalf. It does not say that the principal stops being the Issuer, that reporting under Article 6(6) moves to the agent, or that the agent becomes liable for the principal’s failures.
• No mention of receiving or reporting. Article 8 covers issuing and transmitting. It is silent on the Recipient side (processing under Article 6(3)) and on reporting to the FTA (Article 6(6)).

Where a real arrangement depends on any of these points, treat the answer as unconfirmed by this guide and take qualified UAE tax or legal advice.

VAT agency rules: what they establish—and what they do not

Two separate VAT provisions provide useful context for identifying the principal and agent. Under Federal Decree-Law No. 8 of 2017 on VAT, Article 9(1), a supply of goods or services through an agent acting in the name and on behalf of a principal (a disclosed agent) is treated as a supply by the principal and for the principal’s benefit. The commercial label alone is not decisive: the actual contractual and transactional arrangement matters.

Article 59(11) of the VAT Executive Regulation addresses a different question: when an agent who is a Registrant makes a supply for and on behalf of its principal, the agent may issue a VAT Tax Invoice as if it made the supply, provided the principal does not issue a Tax Invoice for that supply and the agent and principal each retain sufficient records to determine the other party’s name, address and Tax Registration Number. This is a VAT Tax Invoice rule. It does not state that the agent must obtain a particular power of attorney or notify the FTA specifically for the purposes of eInvoicing Article 8.

The official UAE Electronic Invoicing Guidelines, version 1.1 dated 1 June 2026, section 10, “Electronic Invoice categories, special scenarios and tax codes”, scenario “Agent billing” (PDF page 27), states that responsibility to issue an Electronic Invoice remains with the supplier even if an agent issues it on the supplier’s behalf. Decision 243/2025 Article 6(6) separately requires the Issuer and Recipient to report the relevant Electronic Invoices and Electronic Credit Notes to the FTA within the timeline prescribed by the Minister. Article 8 does not say that an agent replaces the Issuer or Recipient for that reporting obligation. The cited materials therefore support keeping the supplier’s issuing responsibility clear and assigning reporting controls explicitly; they do not establish that every reporting act must be performed personally by a particular employee, nor do they resolve every possible liability question.

Mandate, power of attorney and FTA notification: Article 8 itself prescribes none of these formalities. The VAT provisions cited above establish the specific conditions described in the preceding paragraphs, not a general eInvoicing appointment procedure. In the official sources checked for this guide, we did not identify a rule requiring a prescribed power-of-attorney form or a separate FTA notification solely to use Article 8. This is a bounded search result, not proof that no other law, contract, sector rule or fact-specific requirement can apply. Keep the underlying agency agreement and evidence of authority as a prudent control, and verify any transaction-specific formalities against the complete applicable legislation.

How Article 8 fits with Articles 6, 9 and 10

Article 6(1) sets the central rule: the Issuer issues and transmits an Electronic Invoice to the Recipient for any Business Transaction. That rule is expressly made subject to Articles 8, 9 and 10. In other words, the drafting tells the reader that the core Issuer obligation has to be read together with the agent provision, the self-billing provision and the access-records provision. The Article 6 Issuer and Recipient obligations guide walks through the full article.

Article 9 (self-billing) also lets someone other than the supplier produce the document, but its conditions are different. Paraphrased, the Recipient may issue an Electronic Invoice or Electronic Credit Note on behalf of the Issuer for a supply of goods or services, provided both are Registrants, in line with the conditions in the VAT Executive Regulation or as the Minister otherwise determines. The self-billing guide covers it in detail. The practical differences on the face of the two articles are:

• Actor. Under Article 9 the document is produced by the customer, the other party to the transaction. Under Article 8 it is produced by an agent of the principal, who is not described as the counterparty.
• Conditions. Article 9 requires both parties to be Registrants and points to the VAT Executive Regulation conditions. Article 8 states no registration condition.
• Acts. Article 9 refers to issuing; Article 8 refers to issuing and transmitting through the system.

A customer that prepares invoices for its supplier is therefore usually an Article 9 question, not an Article 8 question, even if the commercial contract calls the customer an “agent” for that task. Classify the arrangement by its facts, not its label.

Article 10 (access records) gives the FTA power to access and use data processed, received and stored under the Electronic Invoicing System, and, subject to the Tax Procedures Law and its executive regulations, to share that data with other government entities or foreign government bodies under the State’s international obligations. The decision does not explain why Article 6(1) refers to Article 10. Practically, it is a reminder that documents an agent issues on a principal’s behalf are system data the FTA can access, in the same way as documents the principal issues itself.

Agent, ASP, ERP vendor or tax adviser: separating the roles

Several outside parties can touch an invoice. They are not interchangeable, and only one of them is the subject of Article 8.

• Accredited Service Provider (ASP). Article 6(7) says the Issuer and the Recipient fulfil their Article 6 obligations through the appointment of an ASP, and Article 5(1) requires that appointment without prejudice to the Issuer’s and Recipient’s own obligations. As amended by Decision 197/2026, an ASP is a service provider accredited to provide Electronic Invoicing Services under the legislation regulating the system; those services are sending, receiving and exchanging Electronic Invoices and Electronic Credit Notes to Ministry standards. An ASP is the channel every in-scope business needs, whether or not an agent is involved. See the ASP accreditation guide.
• Agent of a principal. A person acting for the principal in a relationship that exists independently of the invoicing system. Article 8 allows that agent to issue and transmit through the system for the principal. The agent still needs an ASP channel to do so; Article 8 does not replace Article 6(7).
• ERP or software vendor. Supplies or configures software that produces invoice data. Providing software does not, by itself, make the vendor an agent acting on behalf of a principal in any legal sense, and the vendor is not an ASP unless it holds accreditation.
• Tax adviser or accounting firm. May advise, review or prepare data. Whether it is also acting as an agent for issuing and transmitting depends on what it actually does and under what relationship, which Article 8 does not define.

One organisation can wear more than one of these hats. A group company may run the ERP, act as agent for its affiliates and contract with an ASP. Record each role separately so that a reviewer can see which one applies to each step. The functional responsibility matrix guide gives a template for recording who owns each task.

Separate the parties and the work they actually perform

Before calling anyone an agent, map the real process. Identify the business that makes the supply, the people who agree commercial terms, the team that prepares invoice information, the system that generates the structured document, and the ASP that transmits it. Record whether one organisation performs several of these functions. This is an internal mapping exercise, not a claim that the law requires a particular organisational chart.

Use plain descriptions rather than job titles alone. “Finance manager” does not tell a reviewer whether that person approves a transaction, edits data, releases a document or merely monitors exceptions. “Agent” is similarly too broad to explain the actions performed. A role map should describe actions, systems and hand-offs so the business can compare the arrangement with the two acts Article 8 actually covers: issuing and transmitting on the principal’s behalf.

Note in particular that employees of the business acting within their own employer are not obviously “agents” in the Article 8 sense; they are the business itself acting through its staff. Article 8 matters most where a separate person, such as another legal entity or an outside firm, issues or transmits for the business.

Practical checks before an agent touches invoice data

The following are recommended internal controls, not legal requirements attributed to Article 8. Adapt them to the actual arrangement and the organisation’s existing governance.

1. Define the task. Write down whether the agent collects source data, prepares a draft, changes master data, triggers document creation, transmits through the ASP or handles rejected messages. Avoid a single vague permission covering every step.
2. Identify the principal and transaction. Record which legal entity is the principal and which transactions the agent covers. Confirm scope separately; an agency relationship does not prove that a transaction is in or out of the system. The transaction scope guide helps here.
3. Record the business arrangement. Keep the contract, engagement letter or intra-group agreement the organisation already uses. This is audit-trail practice, not a statement that Article 8 prescribes a document.
4. Confirm the ASP channel. Establish whose ASP the agent will use and how documents issued for the principal will be identified as the principal’s. Article 6(7) still applies.
5. Limit system access. Give each user or integration only the access needed. Separate preparation from release where appropriate, and avoid shared accounts that hide who performed an action.
6. Preserve evidence. Retain source records, changes, timestamps, transmission results and exception handling under the organisation’s documented retention process.
7. Test exceptions. Check how wrong recipient details, duplicates, rejected transmissions, credit notes and the agent’s loss of access are handled, and who escalates corrections.
8. Recheck changes. Review the arrangement when the contract, legal entity, system, scope of work or legal text changes.

Editorial scenarios: how Article 8 questions arise in practice

The three scenarios below are editorial examples written for this guide. They are simplified, they are not taken from any official guidance, and they do not state how the FTA would treat a real arrangement. Their purpose is to show which questions to ask.

Scenario 1: a group shared service centre

A group runs a shared service centre in one legal entity that prepares and sends invoices for five trading subsidiaries. Each subsidiary is the supplier in its own transactions. If the centre is a separate legal entity acting for each subsidiary under an intra-group agreement, the arrangement looks like an agent issuing and transmitting on behalf of a principal, which is the situation Article 8 describes. Questions to settle: is each subsidiary still the Issuer for its own supplies; whose ASP channel carries the documents; how is each document attributed to the right subsidiary; and who handles each subsidiary’s reporting under Article 6(6), which Article 8 does not mention. If the centre is simply a department of the same legal entity, it is not a separate agent at all. Where the entities form a VAT Tax Group, also check the temporary exclusion in the Tax Group exclusion guide for transactions between members.

Scenario 2: an external accounting firm

A smaller business engages an accounting firm to raise its monthly invoices from timesheets and send them to customers. If the firm actually issues and transmits the documents for the business, the Article 8 permission is the relevant reference point. Questions to settle: does the firm use the client’s ASP connection or its own; who approves each invoice before release; what happens to the audit trail if the engagement ends; and how the client confirms that every document was transmitted. If the firm only prepares data that the client’s own staff then release, the firm is a preparer, not an agent issuing on the client’s behalf. Customers on the receiving end should be told who will be sending documents; see the trading partner onboarding guide.

Scenario 3: another group company selling as agent

A UAE group company sells products as a commercial agent for a sister company that owns the stock. The question is first a commercial and VAT one: whose supply is it? If the sister company is the supplier and the selling company acts as its agent, Article 8 lets the agent issue and transmit for the principal. If instead the selling company buys and resells in its own name, it is the Issuer of its own invoices and Article 8 is not engaged. Article 8 does not determine which arrangement applies. The underlying agreement and relevant VAT rules must be assessed for the actual facts. This guide summarises the cited VAT agency provisions as context, but it has not verified the current consolidated VAT Executive Regulation, including whether Article 59(11) remains unchanged after later amendments. Treat that specific current-law point as unverified.

Contrast: a customer preparing the supplier’s invoices

If a large customer prepares invoices for its suppliers from goods-received data, the customer is the Recipient producing the document for the Issuer. That is the self-billing situation in Article 9, with its Registrant and VAT Executive Regulation conditions, even if the parties’ contract uses the word “agent”.

Penalties and record-keeping when an agent is involved

Violations and administrative penalties for the eInvoicing system are set out in the annexed table of Cabinet Decision No. 106 of 2025, which applies to violations of the eInvoicing legislation under the Tax Procedures Law and does not apply to a person participating on a voluntary basis. Our penalties guide explains the table. Article 8 does not say that using an agent changes who is responsible for a violation, and we have not identified any provision that moves liability from a principal to its agent. Do not assume that appointing an agent reduces the principal’s exposure.

For records, Article 11 as replaced by Decision 197/2026 requires any person subject to the system to keep Electronic Invoices, Electronic Credit Notes and associated data for the period prescribed under the Tax Procedures Law and to be able to produce them to the FTA on request. Where an agent issues documents, the principal should make sure it can still retrieve and produce them, for example after the agent relationship ends. The record-keeping and archiving guide covers retention in more detail.

How this topic fits with the wider UAE eInvoicing rules

First determine whether the business and transaction are in scope. Then use the master data readiness guide to prepare reliable party and transaction data, and the data mapping and system integration guide to map that information across the principal’s and agent’s systems. The accounts receivable and Issuer guide and accounts payable and Recipient guide cover the ordinary supplier and customer sides. Before go-live, the go-live testing checklist helps teams test normal and exception flows, including documents issued by an agent.

The Ministry of Finance eInvoicing programme portal lists the official legislation. Check that the version you rely on is current; a later decision could amend Article 8 after the date of our reading.

Agent workflow checklist

Before enabling an agent in a live process, the business can document the following internal checks:

• The principal, the agent, the transactions covered and the invoice workflow are identified.
• The agent’s tasks are described in operational language, and it is clear whether the agent issues and transmits or only prepares data.
• The arrangement has been compared with Article 8 and, where relevant, Articles 6 and 9 of Decision 243/2025.
• The ASP channel used for the principal’s documents is confirmed.
• System permissions and hand-offs match the approved task description.
• Reporting, credit notes, exceptions and record retrieval have named owners.
• Open legal questions, such as the VAT treatment of the agency or any formality, are recorded and escalated.

For more, browse all UAE eInvoicing guides, use the free readiness assessment as an educational planning aid, and consult the homepage’s key dates for the published timetable. The readiness assessment is not a legal applicability decision.

Frequently asked questions

What does Article 8 allow, in one sentence?

Where an agent acts on behalf of a principal, the agent may issue and transmit the Electronic Invoice or Electronic Credit Note through the Electronic Invoicing System for that principal.

Does Article 8 mean any third party can issue invoices for a business?

No. It applies to an agent acting on behalf of a principal. A software vendor, an ASP or a customer is not automatically an agent in that sense, and the decision does not define the term.

Does appointing an agent transfer the principal’s obligations?

The text does not say so. Article 8 permits the agent to issue and transmit on the principal’s behalf. The MoF’s official eInvoicing Guidelines state that the supplier’s responsibility to issue remains even where an agent issues the document. Article 6(6) separately names the Issuer and Recipient as responsible for reporting the relevant documents. Do not assume that using an agent transfers the principal’s obligations or removes the need to assign and monitor reporting controls; the precise liability outcome depends on the applicable provisions and facts.

Must a business use a particular power-of-attorney form?

Article 8 does not prescribe a particular form, registration or FTA notification. VAT Executive Regulation Article 59(11) contains separate conditions for a registered agent issuing a VAT Tax Invoice, including reciprocal record-keeping and no duplicate Tax Invoice from the principal. We did not identify a prescribed power-of-attorney form or a separate FTA notification requirement solely for Article 8 in the official sources checked. That limited finding does not exclude requirements arising under another applicable law, contract or the facts of a particular arrangement.

Is an ASP the same as an agent under Article 8?

No. An ASP is the accredited channel through which Issuers and Recipients fulfil their Article 6 obligations under Article 6(7). An agent is a person acting for a principal. An agent issuing documents for a principal still sends them through an ASP.

How is Article 8 different from self-billing?

Self-billing under Article 9 is the Recipient issuing for the Issuer, only where both are Registrants and under VAT Executive Regulation conditions. Article 8 concerns an agent of the principal and states no registration condition.

Did Decision 197/2026 change Article 8?

No. On our reading of the official text, Decision 197/2026 amends Articles 1, 4, 6(5) and 11 and repeals Article 12, but leaves Article 8 unchanged.