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UAE eInvoicing and VAT Tax Groups: a practical guide to the 24-month intra-group exclusion under Decision 197/2026

Published 23 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

Members of a VAT Tax Group often invoice each other constantly: shared services, management charges, recharges of costs and transfers of goods between group companies. When the UAE eInvoicing rules were amended in October 2026, these internal invoices received their own, temporary treatment. For finance, tax, accounts payable (AP) and accounts receivable (AR) teams inside a group, the change raises a set of practical questions. Which invoices are excluded? Which ones are not? Does the group still need an Accredited Service Provider (ASP) and the usual go-live date? And what happens when the temporary period ends?

This guide answers those questions from the text of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System as amended by Ministerial Decision No. 197 of 2026, together with the timetable in Ministerial Decision No. 244 of 2025. It separates what the text says from our own editorial reading and lists, near the end, what we have not been able to confirm. For a wider summary of the October amendments, read our guide to the Decision 197/2026 changes.

What the new Article 4(1)(f) says

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.

Decision 197/2026 did not add a single sentence to the old exclusion list. It replaced the whole of Article 4 of Decision 243/2025, the article that defines which transactions are outside the system. Item (f) of the new Article 4(1) is the Tax Group item. The Ministry of Finance explained the October amendments in its announcement of 19 October 2026, and Decision 197/2026 has applied since 1 October 2026.

Three limits built into the wording

It is about transactions. The item makes certain Business Transactions Excluded Transactions. It does not make a group member an Excluded Person. A member that also deals with outside customers and suppliers remains within the system for those dealings, unless another exclusion applies.
It is about the same Tax Group. Both parties must be members of the same Tax Group. A related company that is not a member of that Tax Group is not covered by this item, however closely it is owned or managed.
It is temporary, with a separate start date. Decision 197/2026 took effect on 1 October 2026, but Article 4(1)(f) specifies a 24-month exclusion period starting 1 January 2027. Do not treat the amendment's effective date as the start of this period. The text establishes a limited period; check the current official decision and any later amendment before changing invoice treatment when it ends.

How Tax Group and Taxable Person are defined

Decision 197/2026 also added two definitions to Article 1 of Decision 243/2025: Tax Group and Taxable Person. Both are defined by reference to the VAT Law rather than by a stand-alone eInvoicing test. We have not reproduced the full wording here, and readers should read Article 1 as amended in the official PDF. Our glossary of key terms explains how these terms sit alongside the other Article 1 definitions.

The practical consequence, on our reading, is that the eInvoicing question “is this counterparty in our Tax Group?” should be answered from the group’s VAT position, not from the organisation chart. Ownership, shared management or a common brand do not, by themselves, answer it. Start with the Tax Group membership evidence held for VAT purposes; reconcile the legal entity and VAT identifiers in the customer and supplier masters against that evidence, and have the responsible tax adviser resolve any ambiguous or recently changed membership before applying the exclusion. Keep a dated record of the evidence and decision used for each affected entity. This is a control recommendation, not an additional legal condition stated in Article 4(1)(f).

What the exclusion does not cover

Article 3(a) of Decision 243/2025 brings into scope any Person conducting Business in the State in respect of every Business Transaction, unless the person or the transaction is excluded under Article 4. Item (f) removes one kind of transaction from that broad rule. It leaves everything else where it was.

On our editorial reading, this means that a group member’s sales to customers outside the group and its purchases from suppliers outside the group are not excluded by item (f). They follow the normal rules, including the Issuer and Recipient obligations in Article 6, unless a different exclusion applies to them. This is an interpretation of how item (f) fits into Articles 3 and 4, not a determination for any particular group. Our transaction scope guide explains how to check those external flows, and the guides for accounts receivable and Issuers and accounts payable and Recipients describe the obligations from each side.

The category dates still apply to external transactions

The exclusion changes which transactions are in scope. It does not change the timetable in Article 5(1) of Decision 244/2025, with Article 5(1)(a) as replaced by Decision 66/2026. Decision 197/2026 amended Decision 243/2025, not Decision 244/2025. The revenue-based dates apply to persons subject to the system, and Government Entities have their own timetable:

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

Our editorial reading is that a group member whose external transactions are in scope should plan for the ASP appointment and implementation dates of its category as usual. The intra-group exclusion does not postpone them. Our deadlines guide and the key dates summary explain the categories, and our revenue threshold guide explains how a business finds its side of the AED 50 million line.

The same start date as the first phase

The 24-month period starts on 1 January 2027, which is also the implementation date for persons subject to the system with Revenue of AED 50 million or more. For a group member in that category, intra-group invoices can be kept out of the go-live scope while external sales and purchases go live on the same day. For members in the later categories, the exclusion has already been running by the time their own implementation date arrives. Our roadmap for businesses of AED 50 million and above shows how this fits a week-by-week plan.

The ASP still matters

Article 6(7) of Decision 243/2025 says the Issuer and the Recipient fulfil their Article 6 obligations through the appointment of an Accredited Service Provider. Because external sales and purchases remain in scope on our reading, a group member with external in-scope transactions still needs an ASP for them. The accreditation rules were revised recently. 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 described the change in its announcement on Decision 168/2026.

For a Tax Group, two editorial prompts are worth adding to provider discussions. First, ask how the service will tell intra-group transactions from external ones, so that excluded invoices are not sent through the system by mistake and external invoices are not held back. Second, ask how intra-group flows could be brought into the service later, when the 24-month period ends. These are planning questions, not official criteria, and we do not name or compare providers. Our guide to choosing and appointing an ASP covers selection more generally.

How the exclusion relates to other rules

Article 9 self-billing

Article 9 allows the Recipient to issue an Electronic Invoice or Electronic Credit Note on behalf of the Issuer only where both are Registrants, and in accordance with the conditions in the VAT Executive Regulation or as otherwise determined by the Minister. Self-billing arrangements are sometimes used inside groups. If the transaction is between members of the same Tax Group, item (f) excludes it for the 24-month period, so on our reading the self-billing question does not arise for the system during that time. Self-billing with outside customers or suppliers still needs the Article 9 check. We have not reviewed the VAT Executive Regulation conditions.

Article 4(3) voluntary participation

Article 4(3) lets a Person take part voluntarily for transactions that would otherwise be excluded. In that case the decisions apply to it on a mandatory basis, except the provisions on violations and penalties. A group might consider this to keep one process for all invoices from the start. It is a deliberate choice with consequences, so decide it with your adviser rather than by default. Our guide to voluntary participation under Article 4(3) sets out the factors and open questions.

The B2C rule in Decision 244/2025

Article 5(2) of Decision 244/2025 provides that B2C transactions, and persons engaged exclusively in them, are not subject to the system until a ministerial decision determines otherwise. That is a different rule from item (f). The B2C rule concerns sales to consumers; item (f) concerns transactions between Tax Group members. A group member that sells to consumers and to businesses needs to look at both rules. Our B2C exclusion guide explains the Article 5(2) rule.

What we have not been able to confirm

The exact calendar end date and transition treatment after the 24-month period that starts on 1 January 2027. The decision states the duration and start date; this guide does not infer a final day or assume what operational steps, if any, apply at transition. Check the current official text and any later decision before changing invoice treatment.
Whether and how the Revenues of group members are combined to decide which revenue category applies. Revenue is defined in Article 1 of Decision 244/2025, but we have not verified group or aggregation treatment.
How changes in group membership, such as a company joining or leaving the Tax Group during the period, are treated.
How the penalties in Cabinet Decision 106/2025 would apply if transactions are classified wrongly; we have not confirmed this. Our penalties guide explains what the decision itself says.
The technical specifications, including whether and how intra-group or excluded transactions are marked, and any reporting of excluded transactions.
The full wording of the Tax Group and Taxable Person definitions and the related VAT Law provisions.

We state these gaps rather than filling them with estimates. Check the official texts on the MoF eInvoicing programme page, which also lists later decisions, and ask a qualified adviser. Our legislation map shows which decision answers which question.

A step-by-step checklist for separating intra-group and external flows

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

Confirm and date the membership evidence. Take the Tax Group membership from the group’s VAT records and confirm it with your tax adviser. Note related companies that are not members, record when the evidence was checked, and route any joiner, leaver or disputed membership to a tax adviser rather than assuming the exclusion applies.
Flag members in master data. Mark fellow group members in both the customer and the supplier master, so that every invoice can be classified automatically. Our master data readiness guide covers this clean-up.
Map the flows and exceptions. List every intra-group and external invoice flow by system, entity and direction, including manual invoices, recharges and credit notes. Assign an owner to investigate unmatched counterparties and record how each ambiguous transaction was resolved.
Confirm each member’s category. Note the ASP appointment and implementation dates that apply to each member’s external transactions, and record any open question about revenue.
Check other exclusions. Review the B2C rule, the sector items in Article 4 and any self-billing under Article 9.
Brief the ASP. Confirm current accreditation and agree how intra-group and external transactions are separated.
Test both routes and retain evidence. Test representative intra-group and external sales and purchases, including recharges, credit notes and manual exceptions. Confirm that external in-scope invoices follow the required system route and that transactions treated as excluded are not accidentally routed as in-scope. Record test results, failed cases, owners and corrections using our go-live testing checklist. These are operational controls, not official technical specifications for identifying or reporting excluded transactions.
Plan for the end of the period. Put the end of the 24-month period on the project calendar as a future workstream, check for later decisions regularly and fit the work into the readiness project plan. You can score your overall preparation with the free readiness check.

Preparing for the end of the period

Because the exclusion is temporary, the intra-group routes are a deferred project rather than a cancelled one. On our reading, a group that builds its process around a clean classification of intra-group and external transactions now will find the later change smaller: the same flags that keep intra-group invoices out of the system during the period can route them into it afterwards. Keep the intra-group data quality high, keep the issuing systems for internal charges on the roadmap, and review the position whenever the Ministry publishes a new decision. The Article 6 rules that will then apply are summarised in our guide to Issuer and Recipient obligations under Article 6.

Frequently asked questions

Are all invoices between our group companies excluded?

Only Business Transactions between members of the same Tax Group, for 24 months starting 1 January 2027. Transactions with related companies outside the Tax Group are not covered by item (f).

Do we still need an ASP if we are in a Tax Group?

On our reading, yes, for any member with in-scope transactions with customers or suppliers outside the group. Article 6(7) links the Article 6 obligations to the appointment of an Accredited Service Provider.

Does the exclusion move our implementation date?

No. Decision 197/2026 did not amend the Decision 244/2025 timetable. The category dates continue to apply to in-scope external transactions.

Can we include intra-group invoices in the system anyway?

Article 4(3) allows voluntary participation for otherwise excluded transactions. If you choose it, the decisions apply on a mandatory basis except the provisions on violations and penalties.

When does the 24-month period end?

The text sets 24 months starting 1 January 2027. We have not calculated or confirmed an end date, so check the official text and any later decision.

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, Tax Group 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.