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UAE eInvoicing issuer and recipient obligations: credit notes, the 14 Business Day deadline and self-billing under Article 6 and Article 9

Published · Decisions 243/2025 and 197/2026 read in the official English text on 23 October 2026 · Other official sources last reviewed 22 October 2026 · 9 min read

Once a business knows that a transaction is inside the UAE eInvoicing system, the next questions are operational. Who has to create the invoice? What does the customer have to do with it? When must a credit note be issued instead of a new invoice? How many days are there to get the document through the system? And can a customer raise the invoice on the supplier’s behalf?

Those answers sit mainly in Article 6 (Exchange and Reporting Obligation) and Article 9 (Self-Billing) of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. One paragraph of Article 6 was replaced by Ministerial Decision No. 197 of 2026, in force from 1 October 2026. This guide walks through each paragraph in plain language, separates what the text says from our own reading, and lists the points we have not been able to confirm. It is written for finance teams, accounts payable and receivable leads, and the people who will brief an accredited service provider (ASP).

The defined terms you need first

Article 6 is short, but it relies on definitions in Article 1 of Decision 243/2025. Reading it without them leads to mistakes.

Issuer and Recipient

An Issuer is any Person obligated to issue, transmit, share and exchange Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System. A Recipient is any Person who receives them through the system. In an ordinary sale, the supplier is the Issuer and the customer is the Recipient. Both roles carry obligations, so a business that both sells and buys will usually be an Issuer on one side of its ledger and a Recipient on the other.

Electronic Invoice and Electronic Credit Note

Both are documents issued, transmitted and received in a structured electronic format that enables automatic and electronic processing. A PDF attached to an email is not what the definition describes. Article 7 adds that 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, Registrant and Business Day

The Date of Business Transaction is the earlier of the date on which the Business Transaction occurred or the date payment for it was received. A Registrant is a Person registered for VAT with a Tax Registration Number under the VAT Law. A Business Day is any day of the week except weekends and official holidays of the Federal Government. The decision does not list which days those are; check the current federal calendar rather than assuming a particular weekend or holiday list.

Article 6(1): the Issuer’s core obligation

Article 6(1) requires the Issuer to issue and transmit an Electronic Invoice to the Recipient in respect of any Business Transaction. The paragraph opens with the words “subject to Article 8, 9 and 10”. Article 8 lets an agent acting on behalf of a principal issue and transmit the document for that principal, and Article 9 is the self-billing rule discussed below. For practical checks before an agent or representative touches invoice data, see the agent and representative guide.

The obligation is tied to the Business Transaction, not to a separate request from the customer. Combined with the broad scope rule in Article 3, the starting assumption for an in-scope supplier is that every in-scope sale needs an Electronic Invoice, unless an exclusion applies. Our transaction scope guide explains which transactions are inside Article 3 and which the amended Article 4 excludes. Remember too that B2C transactions are outside the system for now under Article 5(2) of Decision 244/2025; see our B2C exclusion guide.

Article 6(2): when an Electronic Credit Note is required

Article 6(2) requires the Issuer to issue and transmit an Electronic Credit Note to the Recipient in four listed cases:

  1. the Business Transaction is cancelled;
  2. the agreed consideration is reduced for any reason;
  3. the consideration is returned in full or in part;
  4. an administrative or numerical error has occurred in relation to the Business Transaction.

What this means in practice

The list maps onto familiar events: a cancelled order, a post-sale discount or price adjustment, a refund, and a correction of a wrong amount or detail. The useful point for process design is that each of these is handled with a credit note that travels through the same system as the original invoice, rather than by editing or quietly replacing the original document. The text does not set out how an increase in price should be handled, how a credit note must reference the original invoice, or how partial returns should be calculated. We have not verified official guidance on those points, so agree the treatment with your adviser and ASP. Our Electronic Credit Notes guide works through each of the four cases with editorial examples.

Article 6(3): what the Recipient must do

Article 6(3) requires the Recipient to process Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System. The obligation is not only on the seller. A buyer that is in scope cannot simply wait for a PDF; its accounts payable process has to be able to receive and handle structured documents through the system.

Two further paragraphs of Article 6, which Decision 197/2026 did not replace, complete the picture. Article 6(6) requires 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. Article 6(7) says both fulfil their Article 6 obligations through the appointment of an Accredited Service Provider. We have not identified the ministerial timeline for reporting, so this guide gives no reporting deadline. Our dedicated Article 6(6) reporting obligations guide explains the Issuer and Recipient roles, a process for verifying the official timeline, and the details that remain unconfirmed. Our guide to choosing and appointing an ASP under Decision 168/2026 covers the appointment side.

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

Article 6(4): Registrants 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 this guide does not state a number of days for it. Check the VAT Law and its Executive Regulation, or ask your tax adviser, for the period that applies to your invoices and credit notes.

Article 6(5): fourteen Business Days, as replaced by Decision 197/2026

The original Article 6(5) 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. Decision 197/2026 replaced that paragraph. 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).

Our reading of how the two paragraphs fit

Because Article 6(5) is “subject to” Article 6(4), our reading is that a Registrant Issuer follows the VAT Law timeline, and the fourteen Business Day period is the rule for Issuers to which Article 6(4) does not apply. This is an editorial reading of the wording, not an official interpretation. Two practical consequences follow. First, the clock starts at the Date of Business Transaction, which can be the payment date if payment comes first, so advance payments matter. Second, counting Business Days rather than calendar days means weekends and federal holidays are skipped. The MoF described the October amendments in its announcement of 19 October 2026, and our Decision 197/2026 guide covers the other changes made at the same time.

Article 9: self-billing only between two 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. Our self-billing guide covers Article 9 in detail.

So self-billing is not available where either party is not registered for VAT. Where both are Registrants, the VAT Executive Regulation conditions still apply; we have not reviewed those conditions and do not summarise them here. If you run self-billing today, for example with suppliers paid on a buyer-generated statement, check each supplier’s VAT registration and the regulation’s conditions before you assume the arrangement carries over into the system.

Voluntary participation under Article 4(3)

The replaced Article 4(3) lets a Person voluntarily issue, transmit, share, exchange and report Electronic Invoices and Electronic Credit Notes for Business Transactions even where an exclusion would otherwise apply. If it does, the provisions of the decision and all related eInvoicing decisions apply to it mandatorily, except the decisions on violations and administrative penalties. In other words, a business that opts in takes on the Article 6 obligations described above for those transactions. Decide deliberately, flow by flow, rather than switching everything on because the system is available. Our guide to voluntary participation under Article 4(3) sets out the factors to weigh and what remains unconfirmed.

For how these duties play out technically, with the Issuer as “corner 1”, the Recipient as “corner 4” and each party’s ASP reporting tax data to the FTA, see our guide to the 5-corner model and the PINT AE data standard.

What we have not been able to confirm

  • The number of days in the VAT Law timeline referred to in Article 6(4).
  • The ministerial reporting timeline under Article 6(6).
  • How the penalties for late or missing documents are applied in practice. Cabinet Decision 106/2025 sets AED 100 per Electronic Invoice or Electronic Credit Note the Issuer fails to issue and transmit on time, up to AED 5,000 per calendar month, and AED 5,000 for each month or part of a month of delay in implementing the system, including late ASP appointment. It 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 technical specifications and mandatory data fields under Article 7.
  • Which specific days count as weekends and federal holidays for Business Day counting.
  • The self-billing conditions in the VAT Executive Regulation.

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.

A practical order of checks

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

  1. Confirm scope and phase. Use our scope guide and the key dates summary. For example, persons subject to the system with revenue of AED 50 million or more must implement by 1 January 2027.
  2. Map your roles. List where you are the Issuer, where you are the Recipient and where an agent issues for you under Article 8.
  3. 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.
  4. Define the clock. Capture the Date of Business Transaction, including payment received before delivery, and decide how Business Days are counted.
  5. Map credit note triggers. Link cancellations, price reductions, refunds and error corrections in your ERP to an Electronic Credit Note.
  6. Prepare accounts payable. Make sure incoming Electronic Invoices and Credit Notes can be processed through the system under Article 6(3). Our accounts payable and Recipient guide sets out the buyer-side steps in more detail, and our accounts receivable and Issuer guide does the same for the billing side.
  7. Brief your ASP and adviser. Take the open questions above to them, and use our free eInvoicing readiness check to plan the remaining work. The phase dates are explained in our deadlines guide, and our readiness project plan guide shows where credit note and correction flows fit in the wider project. Use the go-live testing checklist to record end-to-end tests, exception handling and unresolved issues.

Frequently asked questions

Is the deadline 14 days or 14 Business Days?

Since Decision 197/2026 came into force on 1 October 2026, Article 6(5) reads fourteen Business Days from the Date of Business Transaction. The earlier wording said 14 days. In both versions the paragraph is subject to Article 6(4).

We are VAT registered. Does the 14 Business Day rule apply to us?

Article 6(4) says a Registrant Issuer follows the timeline in the VAT Law. On our reading, that timeline governs rather than the fourteen Business Day period. Confirm the VAT Law period with your adviser.

Can we correct a wrong invoice by sending a new one?

Article 6(2)(d) requires an Electronic Credit Note where an administrative or numerical error has occurred. How the correction should then be completed is not set out in the text we read.

Can our customer issue our invoices for us?

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

Does the customer have obligations too?

Yes. Article 6(3) requires the Recipient to process the documents through the system, and Article 6(6) includes the Recipient in the reporting obligation.

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 what deadline applies to it. 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.