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The UAE eInvoicing revenue threshold explained: how to tell which side of AED 50 million you are on

Published · Official sources last reviewed 22 October 2026 · 10 min read

The UAE eInvoicing rollout is phased. For businesses that are subject to the system, the phase they fall into, and therefore the dates by which they must appoint an accredited service provider (ASP) and go live, depends on a single figure: revenue measured against a threshold of AED 50 million. Get that figure wrong and a business can plan for a deadline that is months later than the one that actually applies to it.

This guide explains how the threshold works in the official texts: how Revenue is defined, why a business with revenue of exactly AED 50 million is in the first phase, why some announcements use slightly different wording, which groups are not sorted by revenue at all, and what the revenue figure does not tell you. It also sets out a practical order of checks and lists the questions that the official texts, as we read them, do not settle. For the complete timetable, see our guide to UAE eInvoicing deadlines or the key dates summary on our home page.

Where the threshold comes from

Decision 244/2025 sets the phases

The rollout timetable is set by Ministerial Decision 244/2025 on the implementation of the Electronic Invoicing System. Article 5(1) divides persons into groups and gives each group an ASP appointment date and a mandatory implementation date. Two of those groups are defined by revenue: one at or above AED 50 million and one below it. The third group, Government Entities, is defined differently and is covered further down.

Decision 66/2026 replaced the first-phase paragraph

Article 5(1)(a), the paragraph covering the larger businesses, was replaced by Ministerial Decision 66/2026. The replacement text covers persons subject to the system whose Revenue is equal to or exceeding AED 50,000,000. Decision 66/2026 replaced only that paragraph; it did not directly replace Article 5(1)(b), Article 5(1)(c) or Article 5(2). The original appointment date in Decision 244/2025 for the first phase, 31 July 2026, is therefore superseded and no longer current.

How Revenue is defined

The definition in Article 1

Revenue is not left to ordinary meaning. Article 1 of Decision 244/2025 defines both Revenue and Accounting Period. In summary, Revenue means the gross income during the most recent Accounting Period, based on the financial statements the business is required to prepare, or on other documentation that the Federal Tax Authority (FTA) accepts as an alternative. Read the definitions of both terms in the official text before you rely on any figure, because the definition of Accounting Period decides which period you look at.

What that means in practice

Three practical points follow from the definition. First, the figure is gross income, so it should not be confused with profit or with a net amount after costs. Second, it is the most recent Accounting Period that counts, not a forecast, a budget or an average of several years. Third, the starting point is the required financial statements; where those are not available, the definition refers to documentation acceptable to the FTA rather than to any figure a business chooses for itself. If your finance team uses a different revenue measure for internal reporting, note the difference and explain which figure you used for eInvoicing planning.

What the definition does not settle for you

The texts we reviewed do not answer every case. In particular, this guide does not determine how revenue should be treated for a group of related entities, whether amounts are aggregated across entities, how the definition applies to unusual accounting structures, or what happens when a business changes its accounting period. These are open questions for us, not points we have verified, so we do not state an answer. If any of them applies to you, take advice from a qualified UAE tax adviser and record the basis of the conclusion.

The AED 50 million boundary: exactly where the line falls

Exactly AED 50,000,000 is in the first phase

Under Article 5(1)(a) as replaced by Decision 66/2026, the first phase covers Revenue equal to or exceeding AED 50,000,000. The boundary is inclusive. A business subject to the system with revenue of exactly AED 50,000,000 belongs to the first phase, not to the below-threshold phase, and its dates are the earlier ones.

Why some announcements say "exceed"

The Ministry of Finance announcement of 10 May 2026, which explained the extension of the first-phase appointment deadline from 31 July to 30 October 2026, describes the group as businesses whose revenue exceeds AED 50 million. Read literally, that wording would leave out a business at exactly AED 50 million. The later FTA announcement of 29 September 2026 uses the wording equal to or exceeding, which matches the binding text. Where a press release and a ministerial decision differ, the legal text governs. The decision says equal to or exceeding, so that is the rule we follow.

Dates by category

The dates below apply to persons subject to the eInvoicing system. They come from Article 5(1) of Decision 244/2025, with Article 5(1)(a) as replaced by Decision 66/2026.

  • Revenue of AED 50 million or more, including exactly AED 50,000,000: appoint an ASP by 30 October 2026; implement eInvoicing by 1 January 2027.
  • Revenue below AED 50 million (Article 5(1)(b)): appoint an ASP by 31 March 2027; implement by 1 July 2027.
  • Government Entities (Article 5(1)(c)): appoint an ASP by 31 March 2027; implement by 1 October 2027.

The gap between the two revenue phases is several months, which is why the classification matters. Our guide to choosing and appointing an ASP explains what the appointment involves and why an earlier pre-approval label should be reconfirmed under the current accreditation framework.

Who is not sorted by revenue

Government Entities follow their own paragraph

Article 5(1)(c) applies to Government Entities and sets its own dates. It is not a revenue category: a Government Entity does not need to measure its revenue against AED 50 million to find its phase. Unlike the two revenue paragraphs, that paragraph is not phrased in terms of persons subject to the system, but whether a particular body is a Government Entity, and which of its transactions are covered, still has to be checked against the official texts.

The dates apply only to persons subject to the system

The revenue threshold places a business in a phase. It does not decide whether the business is covered at all. The revenue paragraphs apply to persons subject to the eInvoicing system, and the FTA announcement repeats that qualification. Scope and exclusions are dealt with in Ministerial Decision 243/2025, which is listed on the MoF eInvoicing programme page. That decision has been amended by Decision 197/2026, which among other things introduced a temporary exclusion for transactions between members of the same VAT Tax Group; we explain it in our guide to the Decision 197/2026 changes. A revenue figure above AED 50 million is not, by itself, proof that a business is subject to the system.

Two of our guides take the scope question further. The Decision 243/2025 scope and exclusions guide walks through who is covered and which transactions are left out, and the VAT Tax Group exclusion guide looks at the temporary exclusion for transactions between members of the same Tax Group. Read them before treating your revenue phase as the whole answer.

B2C transactions are excluded for now

Article 5(2) of Decision 244/2025 provides that business-to-consumer (B2C) transactions, and persons engaged exclusively in them, are not subject to the system until a future ministerial decision determines otherwise. A business that sells only to consumers is therefore in a different position from a business with the same revenue that also sells to other businesses. Check whether any later decision has changed this before relying on it. Our guide to the B2C exclusion for B2C-only and mixed businesses explains why revenue does not decide this question.

A practical order of checks

The steps below are an editorial planning sequence based on the official texts. They are not an official test and they do not replace legal or tax advice.

  1. Check scope first. For each legal entity, read Decision 243/2025 as amended and Article 5(2) of Decision 244/2025, and record whether the entity appears to be subject to the system.
  2. Check whether it is a Government Entity. If so, Article 5(1)(c) applies and the revenue threshold is not the test.
  3. Identify the most recent Accounting Period. Use the Article 1 definition and note the start and end dates of the period you are relying on.
  4. Take gross income from the required financial statements. Where those are not available, identify documentation the FTA accepts, and keep a copy.
  5. Compare with AED 50,000,000. Equal to or above means the first phase; below means the second phase.
  6. Flag the open questions. If group aggregation, an unusual accounting structure or a change of accounting period could affect the answer, record that and take advice before relying on the result.
  7. Write down the dates and the evidence. Put the appointment and implementation dates on the project plan, and keep the calculation and documents together.

Our free eInvoicing readiness check lets you choose a category to see the matching dates and covers the wider preparation areas in eight questions.

After you know your phase: what to do next

Sorting yourself into a phase is only useful if it changes what you do this week. The three paths below send you to the guide that picks up where this one stops. They assume you have already checked that you are subject to the system; if you have not, start with scope.

Revenue of AED 50 million or more, including exactly AED 50,000,000

You are in the first phase. Under Article 5(1)(a) as replaced by Decision 66/2026, the ASP appointment date is 30 October 2026 and eInvoicing must be implemented by 1 January 2027. Because the boundary is inclusive, a business sitting right on the line should not plan against the later dates.

Missing the appointment date has a cost that is written down. Row 1 of the table annexed to Cabinet Decision 106/2025 covers an Issuer that fails to implement the system, including failing to appoint an ASP within the Minister's timeline, and sets a penalty of AED 5,000 for each month of delay or part of a month. Article 2(2) of that decision says it does not apply to a person who takes part in eInvoicing on a voluntary basis. The decision takes effect on the day after its publication in the Official Gazette; we have not confirmed that publication date, so we do not state the exact date from which the penalty applies or how the FTA counts the months. Our guide to the Cabinet Decision 106/2025 penalties covers the full table.

Revenue below AED 50 million

You are in the second phase under Article 5(1)(b): appoint an ASP by 31 March 2027 and implement by 1 July 2027. The later dates give you room, but not unlimited room, and the revenue figure you relied on should be kept with the project file in case it is questioned. Our month-by-month roadmap for businesses below AED 50 million works back from those two dates. If you are close to the line, recheck the calculation once the next set of financial statements is ready, because the definition looks at the most recent Accounting Period.

Government Entities: not a revenue question

A Government Entity does not use the revenue test at all. Article 5(1)(c) gives it its own dates: appoint an ASP by 31 March 2027 and implement by 1 October 2027. The harder questions are whether a particular body is a Government Entity and which of its transactions are covered. Our Government Entity timeline guide sets out the dates and planning steps, and our guide to Government Entity transactions and the exclusion scope explains which transactions the texts deal with.

Frequently asked questions

Is a business with revenue of exactly AED 50 million in the first phase?

Yes, if it is subject to the system. Decision 66/2026 uses the wording equal to or exceeding AED 50,000,000, so the appointment date is 30 October 2026 and implementation is from 1 January 2027.

Which revenue figure should be used?

Under Article 1 of Decision 244/2025, gross income during the most recent Accounting Period, based on the required financial statements or other documentation acceptable to the FTA. Forecasts and budgets are not the measure.

The 10 May 2026 announcement says "exceed". Does that change the boundary?

No. The binding text in Decision 66/2026 says equal to or exceeding, and the FTA announcement of 29 September 2026 uses the same wording. The legal text governs.

Do Government Entities need to check their revenue?

Not to find their phase. Article 5(1)(c) gives Government Entities their own dates regardless of revenue.

Is a Government Entity classified by its revenue if it also earns commercial income?

The texts we reviewed do not use revenue to place a Government Entity in a phase; Article 5(1)(c) is a separate paragraph with its own dates. Which of its transactions are covered is a scope question, not a revenue question. See our Government Entity transactions guide.

Our Revenue is exactly AED 50 million and we did not appoint an ASP by 30 October 2026. What now?

Because the boundary is inclusive, the first-phase appointment date applied to you. Appoint an accredited provider as soon as you can and keep working towards implementation by 1 January 2027, which Article 5(1)(a) sets as a separate date. Row 1 of Cabinet Decision 106/2025 sets AED 5,000 for each month of delay or part of a month, but we have not confirmed its exact entry-into-force date or how the FTA applies it in practice. Our missed-deadline guide sets out an editorial recovery order.

Are revenues of related companies added together?

We have not verified how revenue is treated across a group of entities, so we do not give an answer. Take advice from a qualified UAE tax adviser.

Does revenue above the threshold mean we are definitely covered?

No. Revenue only places a business in a phase. Whether it is subject to the system depends on Decision 243/2025 as amended and on the Article 5(2) B2C exclusion.

If your Revenue is below AED 50 million, our month-by-month roadmap for businesses below AED 50 million works back from your ASP appointment and go-live dates.

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 is subject to the UAE eInvoicing system or which phase applies to 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. For plain-English explanations of the defined terms used here, see our UAE eInvoicing glossary. See all our guides.