MINSEONG / GUIDES

UAE eInvoicing Electronic Credit Notes: a practical guide to the four Article 6(2) cases, Article 6(4) and 6(5) timing, self-billing and issuer and recipient flows

Published 24 October 2026 · Decisions 243/2025 and 197/2026 read in the official English text on 23 October 2026 · Other official sources last reviewed 22 October 2026 · 11 min read

Most eInvoicing projects start with the sales invoice, because it is the document everyone knows. In practice, a large share of the exceptions that slow a finance team down come from the other direction: orders that are cancelled, discounts agreed after delivery, refunds and corrections. Under the UAE eInvoicing system those events are handled with an Electronic Credit Note, a document that travels through the same system as the original invoice and is subject to its own rules.

This guide is dedicated to credit notes. It reads the relevant parts of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System, mainly Article 6 and Article 9, together with the paragraph replaced by Ministerial Decision No. 197 of 2026. It separates what the text says from our own reading, uses clearly labelled editorial examples, and lists the points we have not been able to confirm. For the full set of Issuer and Recipient duties, read our Article 6 obligations guide alongside this one.

The definitions behind a credit note

Article 6 depends on definitions in Article 1 of Decision 243/2025. We paraphrase them here rather than quote them in full; our glossary of key terms covers the wider vocabulary.

Electronic Credit Note

An Electronic Credit Note, like an Electronic Invoice, is a document issued, transmitted and received in a structured electronic format that allows automatic and electronic processing. A scanned or PDF credit memo sent by email is not what the definition describes. Article 7 says the data fields and particulars are those prescribed by the Ministry; we have not reviewed a field-by-field specification, so this guide does not describe the required fields.

Date of Business Transaction

The Date of Business Transaction is the earlier of the date on which the Business Transaction occurred or the date on which payment for it was received. It matters for credit notes because the timing rules in Article 6 are measured from it.

Business Day, Issuer, Recipient and Registrant

A Business Day is any day of the week except weekends and official holidays of the Federal Government. The decision does not list those days, so check the current federal calendar. The Issuer is the Person obligated to issue and transmit Electronic Invoices and Electronic Credit Notes through the system, the Recipient is the Person who receives them, and a Registrant is a Person registered for VAT with a Tax Registration Number under the VAT Law.

Article 6(2): the four reasons for issuing a credit note

Article 6(2) requires the Issuer to issue and transmit an Electronic Credit Note to the Recipient in four listed cases. The examples under each case below are editorial examples written by us to make the categories concrete. They are not taken from the decision or from official guidance, and they do not settle how any particular transaction should be treated.

(a) The Business Transaction is cancelled

Editorial example: a supplier invoices a customer for a consignment of office equipment, and the customer then cancels the order under the contract terms. The supplier records the cancellation by issuing a credit note through the system rather than deleting or quietly voiding the original invoice in its own ledger.

(b) The agreed consideration is reduced for any reason

Editorial example: after delivery, a supplier agrees a price reduction because goods arrived later than promised, or grants a volume rebate at the end of a quarter. The words “for any reason” make the case broad, so commercial reductions agreed after the invoice was issued are the obvious candidates.

(c) The consideration is returned in full or in part

Editorial example: a customer returns some of the goods and receives a refund for them, or a service fee is refunded after a complaint. The text speaks of the consideration being returned, in full or in part. How a partial return should be calculated is not set out in the text we read.

(d) An administrative or numerical error has occurred

Editorial example: an invoice shows the wrong unit price, a quantity typed twice, or an incorrect customer detail. The error case means corrections are handled through a credit note in the system. The text we read does not say how the correction is then completed, for example whether a replacement invoice must follow; agree that treatment with your adviser and ASP.

Article 6(4) and 6(5): how long the Issuer has

Article 6(4): Registrant Issuers follow the VAT Law

Where the Issuer is a Registrant, Article 6(4) requires it to issue and transmit the Electronic Invoice and the Electronic Credit Note within the timeline prescribed by the VAT Law. The decision does not repeat that timeline, and we have not confirmed the number of days. Check the VAT Law and its Executive Regulation, or ask your tax adviser, for the period that applies to your credit notes.

Article 6(5): fourteen Business Days after Decision 197/2026

Decision 197/2026, in force from 1 October 2026, replaced Article 6(5). The new text requires issue and transmission through the system within fourteen (14) Business Days from the Date of Business Transaction, and it remains expressly subject to Article 6(4). The original paragraph said 14 days. The MoF explained the October amendments in its announcement of 19 October 2026, and our Decision 197/2026 guide covers the other changes.

Does the fourteen Business Day period apply to credit notes?

We have not been able to confirm whether the replaced Article 6(5) itself covers Electronic Credit Notes, or how its clock would be measured for a credit note whose triggering event comes after the original transaction. Article 6(4) does name credit notes expressly for Registrant Issuers. Our reading, which is editorial and not an official interpretation, is that a Registrant Issuer should plan around the VAT Law timeline for credit notes, and any Issuer should confirm the position for credit notes with its adviser rather than assume the fourteen Business Day rule applies or does not apply.

The issuer side: raising and transmitting credit notes

For accounts receivable, the practical point is that every cancellation, price reduction, refund and error correction needs a route to an Electronic Credit Note. In many ERP systems those events start in different places: sales order cancellations, rebate accruals, returns processing and manual journal corrections. Each of them should end in a credit note that is issued and transmitted through the system rather than in an adjustment that only exists in the ledger.

Article 6(7) says the Issuer and the Recipient fulfil their Article 6 obligations through the appointment of an Accredited Service Provider. The credit note therefore goes through the same ASP connection as the invoice. Ministerial Decision 168/2026, in force from 1 October 2026, replaced the earlier service-provider rules (Decision 64/2025 and its amendments, including Decision 56/2026). It removed the former pre-approval stage and introduced direct accreditation, so an earlier pre-approval label is not the same as accreditation under the current framework. Reconfirm a provider's current accreditation status through official channels before you appoint it. The MoF announced the accreditation decision in its news release on Decision 168/2026; our ASP guide covers selection and appointment.

Article 6(1) also makes the Issuer’s duties subject to Article 8, which lets an agent issue and transmit documents for a principal. If an agent raises credit notes for you, see our agent and representative guide. Our accounts receivable and Issuer guide places credit notes in the wider billing process, and the data mapping and system integration guide covers how credit note data leaves your systems.

The recipient side: processing credit notes received

Article 6(3) requires the Recipient to process Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System. A buyer that is in scope cannot treat incoming credit notes as optional paperwork. Accounts payable needs to receive them through its ASP, match them to the purchase they adjust, and reflect them in the supplier balance and the VAT records.

Article 6(6), which Decision 197/2026 did not replace, requires both the Issuer and the Recipient to report Electronic Invoices and Electronic Credit Notes to the Federal Tax Authority within the timeline prescribed by the Minister. We have not identified that ministerial reporting timeline. We have also not confirmed any acceptance or rejection step for a Recipient who disagrees with a credit note. Our accounts payable and Recipient guide sets out the buyer-side steps in more detail, and the month-end reconciliation guide explains how to tie credit notes in the system back to the ledger.

Article 9: self-billed credit notes only between Registrants

Article 9 allows the Recipient to issue an Electronic Invoice or Electronic Credit Note on behalf of the Issuer for a supply of goods or services, provided both the Recipient and the Issuer are Registrants. It must be done in accordance with the conditions in the VAT Executive Regulation or as otherwise determined by the Minister.

For credit notes, this means a buyer that runs self-billing can raise the credit note for a price reduction or return only where both parties are VAT registered and the regulation’s conditions are met. Where either party is not a Registrant, the supplier remains the party that issues the credit note. We have not reviewed the VAT Executive Regulation conditions, so check them before you assume an existing self-billing arrangement carries over. Our self-billing guide covers Article 9 in full.

How the Tax Group, B2C and voluntary participation rules interact

Transactions within a VAT Tax Group

Ministerial Decision 197/2026, which amended Decision 243/2025 with effect from 1 October 2026, treats Business Transactions between members of the same VAT Tax Group as Excluded Transactions for 24 months starting 1 January 2027 (amended Article 4(1)(f)). Check the full list of exclusions in the official text. Our editorial reading is that a credit note adjusting a transaction between members of the same Tax Group follows the treatment of that excluded transaction during the period, but the decision does not address credit notes for excluded transactions separately and we have not confirmed this. Credit notes on sales to and purchases from customers and suppliers outside the group are unaffected by the exclusion. See our Tax Group exclusion guide.

B2C transactions

Under Article 5(2) of Decision 244/2025, B2C transactions are outside the system until a further ministerial decision. A refund to a consumer is therefore not, on our reading, an Electronic Credit Note event under the current rules. Mixed businesses need to separate the two flows; see our B2C exclusion guide.

Voluntary participation

A Person that opts in under Article 4(3) takes on the decisions on a mandatory basis, except the violations and penalties provisions, for the transactions it brings into the system. That includes the credit note duties in this guide. Our voluntary participation guide explains the choice.

When the credit note rules start to apply to you

The credit note duties apply to persons subject to the system from their category’s implementation date. The table below is rendered from the same constants as our key dates summary; the official basis is Decision 244/2025, with Article 5(1)(a) as amended by Decision 66/2026.

Annual revenue AED 50 million or more: ASP appointment by 30 October 2026; eInvoicing implementation from 1 January 2027. Including exactly AED 50,000,000. Decision 244/2025, Article 5(1)(a), as amended by Decision 66/2026.
Annual revenue below AED 50 million: ASP appointment by 31 March 2027; eInvoicing implementation from 1 July 2027. Decision 244/2025, Article 5(1)(b).
Government entities: ASP appointment by 31 March 2027; eInvoicing implementation from 1 October 2027. Decision 244/2025, Article 5(1)(c), which applies to Government Entities.

A credit note that adjusts an invoice issued before your implementation date raises its own question; we have not identified official guidance on that transition, so agree the treatment with your adviser. Our deadlines guide explains the categories in detail.

What we have not been able to confirm

Whether and how a credit note must reference the original invoice, and the Article 7 technical specifications and data fields generally.
How a price increase after invoicing should be handled, since Article 6(2) lists only reductions, returns, cancellations and errors.
How partial returns and partial refunds should be calculated and documented.
The number of days in the VAT Law timeline under Article 6(4), and whether the replaced Article 6(5) itself covers credit notes.
How the credit note penalty is applied in practice. Cabinet Decision 106/2025 sets AED 100 for each Electronic Credit Note the Issuer fails to issue and transmit on time, up to AED 5,000 per calendar month, and does not apply to voluntary participants. We have not confirmed its exact entry-into-force date (the Official Gazette publication date) or how the FTA applies it; see our Cabinet Decision 106/2025 penalties guide.
The ministerial reporting timeline under Article 6(6), and any Recipient acceptance or rejection step.
The self-billing conditions in the VAT Executive Regulation, and which days count as federal holidays.

We state these gaps rather than filling them with estimates. Check the official texts on the MoF eInvoicing programme page and ask a qualified adviser.

An eight-step credit note readiness checklist

This is an editorial planning sequence, not an official checklist or legal test.

Inventory credit note events. List every process that cancels, reduces, refunds or corrects a sale: order cancellations, rebates, returns and manual corrections.
Map each event to an Article 6(2) case. Record which of the four cases it falls under, and flag anything that fits none of them, such as price increases, for adviser review.
Record VAT status. Note whether you and each counterparty are Registrants. It decides whether Article 6(4) applies and whether Article 9 self-billing is possible.
Define the clock. Agree with your adviser which timeline applies to your credit notes and how Business Days are counted.
Route credit notes through your ASP. Make sure credit notes use the same accredited connection as invoices, under Article 6(7).
Prepare accounts payable. Make sure incoming credit notes are received, matched and processed under Article 6(3).
Separate excluded flows. Tag intra-Tax Group and B2C transactions so their adjustments follow the right treatment.
Test and archive. Include each credit note case in the go-live testing checklist, keep the documents as described in our record keeping guide, and use the free eInvoicing readiness check to track the remaining work.

Frequently asked questions

Can we correct an Electronic Invoice by editing it?

Article 6(2)(d) requires an Electronic Credit Note where an administrative or numerical error has occurred. The text we read does not describe editing or replacing the original document, so plan corrections around a credit note.

Is a post-sale discount a credit note event?

Article 6(2)(b) covers a reduction of the agreed consideration for any reason. A discount agreed after the invoice was issued reduces the consideration, so on our reading it falls within that case.

Can our customer issue credit notes on our behalf?

Only under Article 9, where both of you are Registrants and the VAT Executive Regulation conditions, or conditions set by the Minister, are met.

Do we need a credit note for a consumer refund?

B2C transactions are outside the system for now under Article 5(2) of Decision 244/2025, so on our reading a consumer refund is not an Electronic Credit Note event under the current rules.

How long do we have to issue a credit note?

A Registrant Issuer follows the VAT Law timeline under Article 6(4). Whether the fourteen Business Day period in the replaced Article 6(5) covers credit notes is unconfirmed. More short answers are in our eInvoicing FAQ.

Official sources used in this guide

Important notice

This guide is general information prepared by MINSEONG.COM, an independent website. It is not legal or tax advice, it is not an official government publication, and it does not determine whether any business or transaction is subject to the UAE eInvoicing system, when a credit note is required or what deadline applies to it. The examples are editorial illustrations, statements marked as our reading are editorial interpretations, and the items listed as unconfirmed have not been verified. Decisions 243/2025 and 197/2026 were read on 23 October 2026 and the other official sources on 22 October 2026; later decisions may change these rules. Always check the current Ministry of Finance and Federal Tax Authority publications and consult a qualified UAE tax adviser. See all our guides.