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Decision 197/2026 explained: the Tax Group exclusion and new record-keeping rules in UAE eInvoicing

Published · Official sources last reviewed 22 October 2026 · 12 min read

On 19 October 2026 the UAE Ministry of Finance (MoF) announced amendments to the electronic invoicing regulations, presented as a step to ease the burden on businesses. The legal instrument behind the announcement is Ministerial Decision No. 197 of 2026, which amends Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. It is stated to be in force from 1 October 2026, so it was already effective when it was announced.

This guide explains what Decision 197/2026 changed, what it did not change, and what a finance team should check next. It is written for finance managers, tax and compliance staff, and the advisers who support them. It describes only changes that we have traced to the official texts, and it says plainly where we have not described the content of a provision. If you mainly need the rollout dates, start with our guide to UAE eInvoicing deadlines or the key dates summary on our home page.

Two decisions, two different jobs

Most confusion about the UAE eInvoicing rules comes from mixing up the two main ministerial decisions. They work together, but they answer different questions.

Decision 243/2025: who and what is covered

Ministerial Decision 243/2025 is the decision on the Electronic Invoicing System itself. It contains, among other things, the rules on scope and the list of Excluded Transactions in its Article 4. When you ask “do these transactions have to go through the eInvoicing system?”, Decision 243/2025 and its amendments are where the answer starts. Decision 197/2026 amends this decision.

Decision 244/2025: when each group must be ready

Ministerial Decision 244/2025 deals with implementation. Its Article 5 sets the phased timetable: the date by which persons subject to the system must appoint an accredited service provider (ASP), and the date from which eInvoicing becomes mandatory for them. It also contains the Article 5(2) exclusion for business-to-consumer (B2C) transactions until a future ministerial decision. When you ask “by when?”, this is the decision to read.

Keeping the two apart matters because an amendment to one does not automatically affect the other. Decision 197/2026 changes the scope and operational rules in Decision 243/2025. It does not touch the dates in Decision 244/2025.

Change 1: a temporary exclusion for transactions within a Tax Group

What the amended Article 4 says

Decision 197/2026 replaces Article 4 of Decision 243/2025, the article that lists Excluded Transactions. The replacement adds a new Article 4(1)(f): Business Transactions between members of the same Tax Group are Excluded Transactions for a period of 24 months starting 1 January 2027. Our practical guide to the Tax Group exclusion explains how to separate intra-group and external flows.

Why it matters in practice

A VAT Tax Group brings related businesses together under a single VAT registration, and many groups invoice heavily between their own members for shared services, management fees, goods and recharges. Without this exclusion, those internal invoices would have to be issued through the eInvoicing system from go-live. The 24-month period begins on the same date as mandatory implementation for the first phase, 1 January 2027, so members of a Tax Group in that phase can concentrate first on invoices to and from third parties.

What the exclusion does not do

The exclusion is limited in three ways. It is temporary: it applies for 24 months, so plan now for intra-group invoices to come into the system when the period ends unless a later decision changes this. It covers transactions between members of the same Tax Group, not every transaction with a related company; a sister company outside the Tax Group is not covered by this paragraph. And it is an exclusion of transactions, not of the business itself: the same Tax Group members still need to deal with their transactions with customers and suppliers outside the group under the normal rules. Because the whole of Article 4 was replaced, read the complete new list of exclusions in the official text rather than relying on an older summary. Our guide to sector exclusions for airlines, financial services and Government Entities explains the other items of the replaced Article 4.

Change 2: record retention under Article 11

The retention period now follows the Tax Procedures Law

Decision 197/2026 replaces Article 11 of Decision 243/2025, which deals with keeping eInvoicing records. Under the replacement, the retention period is the period that applies under the UAE Tax Procedures Law. In other words, eInvoicing records are tied to the same retention framework that already governs tax records, rather than to a separate rule inside the eInvoicing decision. We do not restate the number of years here; check the current Tax Procedures Law and its implementing rules, or ask your tax adviser, for the period that applies to your records.

The UAE storage requirement

According to the MoF announcement of 19 October 2026, the requirement to store eInvoicing data inside the UAE has been removed. For businesses that use cloud platforms or group IT systems hosted abroad, this may remove a constraint on where invoice archives can be kept. It is worth reading the replaced Article 11 in full before changing your archiving set-up, and remember that other legal and contractual obligations about data location may still apply to your business independently of the eInvoicing rules. Our record keeping and archiving guide turns these changes into a practical archive checklist.

Change 3: Article 6(5) replaced and Article 12 repealed

Article 6(5)

Decision 197/2026 also replaces paragraph 5 of Article 6 of Decision 243/2025. The original paragraph required the Electronic Invoice or Electronic Credit Note to be issued and transmitted through the system within 14 days from the Date of Business Transaction. The replacement text sets fourteen (14) Business Days from the Date of Business Transaction, and it remains subject to Article 6(4), under which an Issuer that is a Registrant follows the timeline prescribed by the VAT Law. If your processes rely on the original Article 6(5), update them to the replacement wording in the official PDF. Our guide to issuer and recipient obligations under Article 6 explains how the two paragraphs fit together.

Article 12 (System Failure) repealed

Article 12 of Decision 243/2025, headed System Failure, is repealed. If your internal procedures or your provider’s contract refer to Article 12, update those references, and check the official texts and current guidance for how outages and failures are now handled rather than relying on the repealed article.

The repeal does not mean that outages stop mattering. Cabinet Decision 106/2025, which sets the administrative penalties for eInvoicing violations, includes a penalty of AED 1,000 for each day of delay, or part of a day, where an Issuer fails to notify the Authority of a System Failure within the required timeline, and a matching row for a Recipient. We have not identified which provision now sets that notification timeline after Article 12 was repealed. Our guide to eInvoicing penalties under Cabinet Decision 106/2025 explains the full penalty table and what remains unconfirmed about it.

Who is affected by each change

Decision 197/2026 is short, but its changes land on different people inside a business. The breakdown below is our editorial reading of which teams are most likely to need to act; it is not an official allocation of responsibilities, and in a smaller business one person may hold several of these roles.

Members of a VAT Tax Group

The new Article 4(1)(f) matters most to businesses that are members of a VAT Tax Group. Business Transactions between members of the same Tax Group are Excluded Transactions for 24 months starting 1 January 2027. The tax or group finance lead should confirm which entities are actually members of the Tax Group, as registered, rather than relying on common ownership or branding, and should decide how intra-group flows will be identified in the billing and purchasing systems. Remember that the exclusion covers transactions between members only: the same entities still deal with outside customers and suppliers under the normal rules. Our VAT Tax Group exclusion guide sets out membership checks, invoice-flow tests and records to keep.

Accounting and accounts receivable teams

The replaced Article 6(5) changes how the issuing period is expressed: fourteen (14) Business Days from the Date of Business Transaction, subject to Article 6(4), under which an Issuer that is a Registrant follows the timeline prescribed by the VAT Law. Billing teams should check any internal procedure, system rule or service-level target that was written against the original wording. Credit notes need the same attention, because adjustments and cancellations often follow different approval paths from ordinary invoices. Our guide to issuer and recipient obligations under Article 6 explains how Articles 6(4) and 6(5) fit together, and our Electronic Credit Notes guide covers the credit note cases in Article 6.

IT, data and archive owners

The replaced Article 11 ties eInvoicing record retention to the period under the Tax Procedures Law, and the MoF announcement states that the requirement to store eInvoicing data inside the UAE has been removed. Whoever owns the invoice archive, the ERP and any cloud hosting should review retention settings and storage location together with the tax team, and should check other legal and contractual data-location obligations before moving anything. Our record keeping and archiving guide gives a practical archive checklist, and our guide to data security and governance for eInvoicing covers access, ownership and control questions around the same data.

Incident and continuity owners

With Article 12 repealed, any internal outage procedure that relied on it needs a new reference point. Decision 197/2026 also deleted the definition of System Failure from Article 1 of Decision 243/2025, while the penalty table in Cabinet Decision 106/2025 still refers to notifying the Authority of a System Failure. The person responsible for operational continuity should keep an incident log, agree escalation paths with the accredited service provider, and watch for official guidance on how failures should now be handled. Our system failure and operational continuity guide explains a practical approach without inventing a statutory procedure.

What did not change: the rollout dates

Decision 197/2026 does not amend Decision 244/2025, so the phased dates are unchanged. The only amendment to Decision 244/2025 listed on the MoF eInvoicing legislation page when we checked it is Ministerial Decision 66/2026, which replaced Article 5(1)(a) only. The current position for persons subject to the system is:

  • Revenue of AED 50 million or more (including exactly AED 50,000,000): appoint an ASP by 30 October 2026; implement by 1 January 2027.
  • Revenue below AED 50 million: appoint an ASP by 31 March 2027; implement by 1 July 2027.
  • Government Entities: appoint an ASP by 31 March 2027; implement by 1 October 2027.

The B2C exclusion in Article 5(2) of Decision 244/2025 is also unaffected; our guide to the B2C exclusion for B2C-only and mixed businesses explains how it works. Our deadlines guide explains each phase and how revenue is measured, and our guide to the AED 50 million revenue threshold covers the boundary in more detail.

What Decision 197/2026 does not change

It is just as useful to know which rules stayed where they were. Based on our reading of the official text, Decision 197/2026 amends Article 1 of Decision 243/2025 (definitions), replaces Article 4, Article 6(5) and Article 11, and repeals Article 12. It does not amend the other provisions we have checked, including:

  • The rollout timetable. As explained above, Decision 244/2025 is untouched by Decision 197/2026, so the ASP appointment and implementation dates for each phase are unchanged.
  • Article 8 (agents). The rule that allows an agent to act on behalf of a principal through the system is not amended. Article 1 still contains no definition of “agent” or “principal”, so the open questions about mandates and responsibility remain. Our guide to agents and representatives under Article 8 explains what the article says and what it does not say.
  • Article 6(1) and Article 6(7). The core obligations of the Issuer and Recipient, and the rule that obligations are fulfilled through the appointment of an accredited service provider, are not amended. Only paragraph 5 of Article 6 was replaced.
  • Article 9 (self-billing) and Article 10 (access to records). Self-billing remains limited to cases where both parties are Registrants, and the Federal Tax Authority’s access to system data is not changed by this decision.

In practice, this means a team that has already planned its agent arrangements, self-billing agreements and ASP appointment around Decision 243/2025 does not need to redo that work because of Decision 197/2026, although it should still check that its documents do not cite the replaced or repealed provisions.

What remains unconfirmed

Several practical questions raised by Decision 197/2026 are not answered by the texts we have reviewed. We list them so that you can raise them with your tax adviser or provider, rather than assume an answer.

  • The number of retention years. Article 11 now points to the period under the Tax Procedures Law. We do not state the number of years here because we have not verified it for eInvoicing records; check the current Tax Procedures Law and its implementing rules.
  • The procedure that replaces Article 12. We have not identified an official replacement procedure for system failures, a prescribed notification form or timeline, or any suspension of ordinary invoicing obligations during an outage.
  • How the Article 6(5) period applies to credit notes. The replaced paragraph runs from the Date of Business Transaction. We have not confirmed how that period is applied to Electronic Credit Notes in practice, for example where a credit note is issued well after the original invoice.
  • What happens after the 24 months. We do not calculate an exact end date for the Tax Group exclusion, and we have not seen official guidance on transition treatment when the period ends, or on companies that join or leave a Tax Group during it.

If any of these points affects a decision you need to make now, record the question, the date you raised it and the answer you received, so that your position can be revisited if official guidance is published later.

A practical order of checks after Decision 197/2026

The steps below are an editorial planning sequence, not an official checklist.

  1. Download the official text. Save the Decision 197/2026 PDF alongside Decisions 243/2025 and 244/2025 so your team works from the same version.
  2. Confirm your phase. The dates have not moved; confirm which phase applies to each entity and that your ASP plan still meets it.
  3. List your Tax Group members. If you are in a VAT Tax Group, list the members exactly as registered and identify which invoice flows run only between them.
  4. Separate intra-group and external flows. Make sure your systems can tell apart transactions between Tax Group members and transactions with anyone else, so that only the right invoices are treated as excluded.
  5. Plan for the end of the 24 months. Put the end of the temporary period in your roadmap and decide when to bring intra-group invoicing into scope technically.
  6. Review archiving. Align eInvoicing record retention with the Tax Procedures Law period, and review where archives are stored in light of the replaced Article 11.
  7. Update references. Remove references to the repealed Article 12 and the old Article 6(5) from policies, procedures and provider contracts.
  8. Brief your provider. Ask your ASP how its service handles the Tax Group exclusion and the retention rules. If you are still choosing one, our guide to choosing and appointing an ASP under Decision 168/2026 explains the current accreditation rules.

Our free eInvoicing readiness check covers the wider preparation areas in eight questions and produces a printable action list.

Frequently asked questions

When did Decision 197/2026 take effect?

It is in force from 1 October 2026. The Ministry of Finance announced it on 19 October 2026.

Does Decision 197/2026 delay the 1 January 2027 go-live?

No. It amends Decision 243/2025, not the timetable in Decision 244/2025. The first-phase ASP appointment date of 30 October 2026 and implementation date of 1 January 2027 still stand.

Are all transactions with related companies excluded?

No. The new Article 4(1)(f) covers Business Transactions between members of the same Tax Group, for 24 months starting 1 January 2027. Related companies that are not members of the same Tax Group are not covered by this paragraph.

Does a Tax Group still need to appoint an ASP?

The exclusion applies to transactions between group members, not to the group’s dealings with third parties. If a member is subject to the system, its other transactions follow the normal timetable. Confirm your own position against Decision 243/2025 as amended and with your adviser.

Can eInvoicing records now be stored outside the UAE?

The MoF announcement states that the UAE storage requirement was removed. Read the replaced Article 11 in full, and consider any other legal or contractual data-location obligations, before moving archives.

Did Decision 197/2026 change the rules for agents under Article 8?

No. Decision 197/2026 does not amend Article 8 of Decision 243/2025. The points that were unclear before, such as what formalities an agent needs and whether responsibility moves from the principal to the agent, remain unclear. See our Article 8 guide for the details.

What happens to intra-group invoices when the 24 months end?

The exclusion is temporary, and we have not seen official guidance on the transition when it ends. The safe planning assumption is that transactions between Tax Group members will need to go through the system after the period unless a later decision says otherwise. Our Tax Group exclusion guide explains how to prepare intra-group flows in advance.

Where can I find the latest version of the rules?

The MoF keeps the current list of eInvoicing legislation on its eInvoicing programme page. Check it regularly; these decisions have been amended several times. Our legislation map and amendment history shows what each of the five decisions does and which wording is current.

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 or excluded from it. The official texts were last reviewed on 22 October 2026; rules may change after that date. Always check the current Ministry of Finance and Federal Tax Authority publications and consult a qualified UAE tax adviser before making decisions. See all our guides.