MINSEONG / GUIDES

UAE eInvoicing self-billing under Article 9: a practical guide to the both-Registrant condition, buyer-issued flows, credit notes, timing, ASPs and record keeping

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

In most trading relationships the supplier raises the invoice and the customer pays it. Some businesses work the other way round: the customer prepares the invoice for goods or services it has received, usually because it holds the better data about quantities, usage or agreed rates. This arrangement is commonly called self-billing. Under the UAE eInvoicing system it is dealt with in a single short provision, Article 9 of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System.

Our other guides mention Article 9 in passing. This guide brings the points together in one place: who the Issuer and Recipient are, why Article 9 is available only where both parties are a Registrant, how a buyer-issued flow can be organised, and how self-billing interacts with credit notes, timing, Accredited Service Providers, exclusions and record keeping. We separate what the text says from our own reading, label examples as editorial, and list what we have not been able to confirm. For the general duties, read our Article 6 obligations guide alongside this one.

What self-billing means under the eInvoicing decision

Article 9 allows the Recipient to issue an Electronic Invoice or an Electronic Credit Note on behalf of the Issuer for a supply of goods or services. It is a permission, not an obligation: nothing in the text we read requires any business to self-bill. It must be done in accordance with the conditions set out in the VAT Executive Regulation, or as otherwise determined by the Minister.

The defined roles

Article 1 of Decision 243/2025 defines the roles we use throughout. We paraphrase them rather than quote them in full; our glossary of key terms covers the wider vocabulary.

Issuer: the Person obligated to issue and transmit Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System. In a normal sale this is the supplier.
Recipient: the Person who receives Electronic Invoices and Electronic Credit Notes. In a normal sale this is the buyer.
Registrant: a Person registered for VAT with a Tax Registration Number under the VAT Law.

Who issues and who remains the Issuer

The wording of Article 9 is that the Recipient issues the document on behalf of the Issuer. Our reading, which is editorial and not an official interpretation, is that the supplier keeps its role as Issuer for the supply, while the buyer performs the act of issuing for it. That is why both parties need to agree the arrangement and why both need clear records of it. The text we read does not describe how the system distinguishes a self-billed document from one issued by the supplier.

Article 9 requires both parties to be Registrants

The central condition is simple: self-billing is possible only where both the Recipient and the Issuer are Registrants. If either party is not registered for VAT, Article 9 is not available and the supplier issues its own Electronic Invoices and Electronic Credit Notes in the usual way.

In practice this turns VAT registration status into master data that a self-billing buyer must hold and keep current for every supplier in the arrangement. A supplier that deregisters, or a new supplier that has not yet registered, falls outside Article 9 even if the commercial contract still says the buyer will raise the invoices. Our master data readiness guide explains how to prepare the counterparty data your eInvoicing flows depend on.

The Registrant condition is necessary but, on the text, not sufficient. The VAT Executive Regulation conditions, or conditions determined by the Minister, must also be met. We have not reviewed those conditions, so this guide does not describe them.

How Article 6(1) reserves Article 9

Article 6(1) sets the Issuer's basic duty to issue and transmit an Electronic Invoice for any Business Transaction through the system. That duty is expressly made subject to Articles 8, 9 and 10. The reference to Article 9 is what allows the document to be raised by the Recipient instead of the supplier in a self-billing arrangement. Article 8 is a separate route that lets an agent issue and transmit documents for a principal; our agent and representative guide covers it. We do not describe the content of Article 10 here.

Article 9 does not, on our reading, remove the other Article 6 duties. The document still has to be issued and transmitted through the system, the other party still has to process it, and both parties still have the reporting duty described below.

A buyer-issued workflow: an editorial example

The sequence below is an editorial example written by us to show how a self-billing flow might be organised. It is not taken from the decision or from official guidance, and it does not describe any required procedure.

Agreement. Buyer and supplier, both Registrants, document that the buyer will issue Electronic Invoices and Electronic Credit Notes on the supplier's behalf, and check the arrangement against the VAT Executive Regulation conditions with their advisers.
Trigger. Goods are received or a service period closes, and the buyer's system calculates the amount due from its own receipt or usage records.
Issue. The buyer issues the Electronic Invoice through its Accredited Service Provider, identifying the supplier as the party on whose behalf it is issued.
Transmission and review. The document reaches the supplier through the supplier's ASP, and the supplier reviews it against its own delivery records.
Confirmation or query. The supplier confirms the document under the commercial agreement or raises a query, which is resolved before the next billing run.
Ledger and VAT records. Both parties post the document and keep it as part of their records.

The confirmation step in this example is a commercial control, not a step we have found in the decision. We have not confirmed any system-level acceptance or rejection step. Our accounts payable and Recipient guide and accounts receivable and Issuer guide describe how each side fits the documents into its wider process.

Self-billed credit notes and the four Article 6(2) cases

Article 9 covers Electronic Credit Notes as well as invoices. Article 6(2) lists four cases in which a credit note must be issued: the Business Transaction is cancelled; the agreed consideration is reduced for any reason; the consideration is returned in full or in part; or an administrative or numerical error has occurred.

In a self-billing arrangement, the buyer is often the first to know about a return, a quality reduction or a pricing error, because it controls the receipt data. Where both parties are Registrants and the conditions are met, the buyer can raise the credit note on the supplier's behalf. Where Article 9 does not apply, the supplier issues the credit note. A self-billing agreement should therefore say which party raises credit notes for each of the four cases. Our Electronic Credit Notes guide explains the four cases in detail.

Timing: Article 6(4) and the replaced Article 6(5)

Where the Issuer is a Registrant, Article 6(4) requires the Electronic Invoice and the Electronic Credit Note to be issued and transmitted within the timeline prescribed by the VAT Law. Since Article 9 only works between Registrants, the supplier in a self-billing arrangement is always a Registrant, so this rule is directly relevant. The decision does not repeat the VAT Law timeline and we have not confirmed the number of days.

Ministerial Decision No. 197 of 2026, in force from 1 October 2026, replaced Article 6(5). The new text requires issue and transmission within fourteen (14) Business Days from the Date of Business Transaction, expressly subject to Article 6(4). The MoF explained the amendments in its announcement of 19 October 2026; see our Decision 197/2026 guide.

Our editorial reading is that a self-billing buyer issuing on the supplier's behalf should plan its billing run so that documents meet the timeline that applies to the supplier, because the arrangement does not appear to create a separate clock. That is a planning assumption to confirm with an adviser, not an official interpretation.

Both parties need an Accredited Service Provider

Article 6(7) says the Issuer and the Recipient fulfil their Article 6 obligations through the appointment of an Accredited Service Provider. In a self-billing arrangement both sides are in the system, so on our reading both need their own ASP connection: the buyer to issue and receive, and the supplier to receive the documents raised on its behalf and to issue anything outside the arrangement. 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 framework in its news release on Decision 168/2026. Our ASP guide covers selection, and you should ask any provider directly how it supports documents issued on behalf of another party.

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 timeline.

How exclusions and voluntary participation affect self-billing

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. During that period, transactions between members of the same Tax Group are Excluded Transactions, so on our reading the question of Article 9 self-billing through the system does not arise for them. Purchases from suppliers outside the group are unaffected, and Article 9 applies to them in the normal way. 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. Self-billing under Article 9 also needs both parties to be Registrants, which a private consumer would not be, so the two rules point the same way. 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. If both parties to an excluded flow are Registrants and one or both opt in, the self-billing question may come back into play; our voluntary participation guide explains the choice.

When the rules apply, and counterparties in different categories

The duties apply to persons subject to the system from their category's implementation date. The list 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 self-billing buyer and its suppliers may fall into different categories. We have not been able to confirm how Article 9 operates where the buyer is already live and the supplier's implementation date is later, or the other way round, and we have not found official guidance on that transition. Until the position is clear, list every self-billed supplier with its category and date and agree the treatment with your adviser. Our deadlines guide explains the categories.

Record keeping for self-billing arrangements

Article 11, as replaced by Decision 197/2026, requires Electronic Invoices and Electronic Credit Notes to be kept for the period set by the Tax Procedures Law. Both parties should keep the self-billed documents themselves. As an editorial recommendation, they should also keep the self-billing agreement, evidence of each party's VAT registration at the time, and any confirmations or queries, so that they can show why the buyer issued the documents. Our record keeping guide covers archive design.

What we have not been able to confirm

The VAT Executive Regulation conditions for self-billing, and any conditions determined by the Minister under Article 9.
The Article 7 technical specifications and data fields, including how a self-billed document identifies the party on whose behalf it is issued.
The ministerial reporting timeline under Article 6(6), and any system-level acceptance or rejection step for the supplier.
The number of days in the VAT Law timeline under Article 6(4).
How Article 9 works where buyer and supplier fall into different categories with different dates.
Which party bears a penalty for a late or incorrect self-billed document. Cabinet Decision 106/2025 sets the eInvoicing penalties (see our penalties guide), but we have not confirmed how it applies to self-billing.
Which days count as federal holidays for counting Business Days.

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 self-billing readiness checklist

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

List self-billed suppliers. Identify every supplier for which you already raise invoices, or plan to.
Confirm both Registrants. Record your own and each supplier's VAT registration, and set a process to recheck it.
Check the conditions. Review the VAT Executive Regulation conditions with your adviser before relying on Article 9.
Update the agreements. Make sure each agreement covers invoices and credit notes, the four Article 6(2) cases and the confirmation process.
Map categories and dates. Note each supplier's category and date, and flag mismatches for adviser review.
Plan the clock. Agree which timeline your billing runs must meet and how Business Days are counted.
Confirm ASP support. Check that your ASP and your suppliers' ASPs handle documents issued on behalf of another party, under Article 6(7).
Test and archive. Include self-billed invoices and credit notes in the go-live testing checklist, keep the agreements with the documents, and use the free eInvoicing readiness check to track the remaining work.

Frequently asked questions

Can any customer self-bill under the eInvoicing system?

No. Article 9 is available only where both the Recipient and the Issuer are Registrants, and subject to the VAT Executive Regulation conditions or conditions set by the Minister.

Does self-billing remove the supplier's obligations?

On our reading, no. The document is issued on the supplier's behalf, the supplier still needs an ASP connection, and both parties have the Article 6(6) reporting duty.

Can the buyer raise credit notes too?

Yes, Article 9 covers Electronic Credit Notes as well as Electronic Invoices, on the same Registrant condition.

What if our supplier is not VAT registered?

Then Article 9 is not available and the supplier issues its own documents through the system.

Does self-billing apply inside our VAT Tax Group?

Intra-group transactions are excluded for 24 months, so on our reading the question does not arise for them during that period. More short answers are in our eInvoicing FAQ.

Official sources used in this guide

To re-confirm, supplier by supplier, that both parties are still Registrants and to agree credit note handling and timing before go-live, use the trading partner onboarding 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 may self-bill, whether any transaction is subject to the UAE eInvoicing system or what deadline applies. The workflow is an editorial example, 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.