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Which transactions does UAE eInvoicing cover? B2B, B2G, cross-border and VAT registration under Decision 243/2025

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

Most UAE eInvoicing articles start with dates. This guide starts one step earlier, with the question every finance team has to answer before a date means anything: which of our transactions are inside the system at all? Businesses tend to ask it in familiar terms. Are business-to-business (B2B) sales covered? What about invoices to government customers (B2G)? Does it matter whether we are registered for VAT? What happens to sales to customers abroad?

The official texts do not use most of those labels. They work with their own defined terms: Person, Business, Business Transaction, Government Entity, Registrant and Excluded Transaction. This guide maps the everyday categories onto that legal wording, quotes the article that applies where one exists, and marks clearly where the texts we reviewed say nothing specific. Where a category is not addressed in the texts, we say so instead of guessing. It is written for finance managers, tax leads and advisers who need to build an inventory of invoice flows before choosing an accredited service provider (ASP).

Two decisions answer two different questions

The UAE eInvoicing rules are split across two ministerial decisions, and mixing them up is the most common source of confusion about scope.

Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System decides what is in scope: who is covered, which transactions are excluded and what the issuer and recipient must do. Its Article 4 (Exclusions) was replaced in full by Ministerial Decision No. 197 of 2026, in force from 1 October 2026.
Ministerial Decision No. 244 of 2025 on the implementation of the system decides when: the phased ASP appointment and go-live dates, and the temporary exclusion for business-to-consumer (B2C) transactions in Article 5(2). Its Article 5(1)(a) was replaced by Ministerial Decision No. 66 of 2026.

So a transaction can be within the scope of Decision 243/2025 and still not need to be issued through the system yet, because its issuer’s phase has not started. The dates are covered in our guide to UAE eInvoicing deadlines; this guide stays with scope.

How this guide relates to our Article 3 and Article 4 reading

This guide and our in-depth reading of Decision 243/2025 Article 3 and the replaced Article 4 do different jobs. That guide works through the legal text clause by clause: each of the seven Excluded Transactions, Excluded Persons and voluntary participation. This guide starts from the categories finance teams actually use (B2B, B2G, B2C, VAT status, exports and other cross-border flows) and sorts them against that text. If you need the wording of a particular exclusion, read the in-depth guide; if you need to place your own invoice flows, stay here.

The general scope rule in Article 3

What the text says

Article 3(a) of Decision 243/2025 applies the decision to any Person conducting Business in the State in respect of every Business Transaction, except where the Person or the Business Transaction is excluded under Article 4. Article 3(b) adds any other Person or Business Transaction that the Minister may determine.

The defined terms behind it

Article 1 defines a Person as any natural or juridical person. Business means an activity conducted regularly, on an ongoing and independent basis, such as industrial, commercial, agricultural, professional, vocational or service activities. A Business Transaction is any transaction conducted in full or in part by a Person in the course of its Business. Read together, the starting point is broad: the rule is framed around business activity in the UAE and every transaction made in the course of it, and it then removes what Article 4 excludes.

B2B transactions

The decision does not use the term B2B, but an ordinary sale by one business to another is a Business Transaction made in the course of the seller’s Business. Nothing in Article 4 excludes B2B sales as a category. On the text, a B2B sale by a Person conducting Business in the State is therefore within scope unless one of the specific exclusions applies, for example the temporary exclusion for transactions between members of the same Tax Group described below. Article 6 then places the obligations on both sides: the Issuer must issue and transmit an Electronic Invoice, or an Electronic Credit Note in listed cases such as cancellations, price reductions and errors, and the Recipient must process them through the system.

B2G transactions and transactions by Government Entities

Selling to a Government Entity

A supply made by a business to a ministry, authority or other Government Entity is a Business Transaction of the supplier. Article 4 contains no exclusion for sales to Government Entities. We therefore do not treat B2G sales as excluded, and they are not B2C sales either, so the Article 5(2) exclusion in Decision 244/2025 does not cover them. Whether a particular B2G flow is in scope still depends on the supplier’s own position under Article 3 and the exclusions.

Transactions made by Government Entities

The exclusion that does exist is narrower and runs the other way. Amended Article 4(1)(a) excludes Business Transactions conducted by Government Entities in a sovereign capacity which are not in competition with the private sector, in accordance with the VAT Law. A Government Entity’s other transactions are not excluded by that paragraph. Our guide to the scope of the Government Entity transactions exclusion looks at the conditions in Article 4(1)(a) more closely. Article 1 defines Government Entities as federal or local ministries, government departments, agencies, authorities and public institutions, and entities treated as such by Cabinet decisions for VAT purposes.

The government timetable

Article 5(1)(c) of Decision 244/2025 gives Government Entities their own dates: ASP appointment by 31 March 2027 and implementation by 1 October 2027. Our Government Entity timeline guide explains that phase.

B2C transactions

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. This is a timing exclusion in the implementation decision, not part of the Article 4 list. A business that sells to both companies and consumers is not engaged exclusively in B2C transactions. Our guide to the B2C exclusion covers this in detail.

Does VAT registration decide scope?

What Article 3 does not say

The general scope rule in Article 3 is framed around a Person conducting Business in the State. Its text does not refer to VAT registration or to holding a Tax Registration Number. On the wording we read, VAT registration is not written into Article 3 as a condition of scope. We have not, however, found official FTA guidance that applies this point to businesses that are not registered for VAT, so for unregistered businesses we treat the practical position as unconfirmed and recommend checking it with the FTA or an adviser.

Where VAT status does matter in the text

Issue timeline. Article 6(4) says that where the Issuer is a Registrant (a Person registered for VAT with a Tax Registration Number), the Electronic Invoice and Electronic Credit Note are issued and transmitted within the timeline in the VAT Law. Article 6(5), as replaced by Decision 197/2026, sets fourteen Business Days from the Date of Business Transaction, subject to Article 6(4). Our guide to issuer and recipient obligations under Article 6 explains these timing rules in more detail.
Self-billing. Article 9 allows the Recipient to issue an Electronic Invoice or Credit Note on behalf of the Issuer only where both are Registrants, under the conditions in the VAT Executive Regulation or as the Minister determines.
Tax Groups. Decision 197/2026 added definitions of Tax Group and Taxable Person by reference to the VAT Law, and new Article 4(1)(f) excludes Business Transactions between members of the same Tax Group for 24 months starting 1 January 2027. See our guide to Decision 197/2026 and our practical Tax Group exclusion guide.
Financial services. Article 4(1)(e) excludes financial services that are exempt from VAT or zero-rated under Article 42 of the VAT Executive Regulation. The VAT treatment of the service, not the size of the business, decides this exclusion.

Revenue is a separate test again: it decides the phase for persons subject to the system, not whether they are subject to it. Our guide to the AED 50 million threshold explains it.

Cross-border transactions

What the text covers

Article 3 refers to a Person conducting Business “in the State”. The decision does not contain a separate rule for exports, imports, supplies by non-resident businesses or sales to customers outside the UAE. The only cross-border situations it addresses directly are in the airline sector: amended Article 4(1)(b) to (d) excludes international passenger transport by an Airline where an Electronic Ticket is issued, ancillary passenger services where an Electronic Miscellaneous Document is issued, and, for 24 months from the date on which the system becomes effective, international transport of goods by an Airline where an Airway Bill is issued. Our guide to sector exclusions for airlines, financial services and Government Entities examines the conditions in each of these paragraphs in more detail.

Exports are not on the exclusion list

Article 4(1) contains no exclusion for exports or for sales to customers abroad as a category. An export is therefore not excluded simply because the buyer is outside the UAE. That is a statement about the exclusion list only: whether a particular export flow is within Article 3 is a separate question, and we have not found official guidance that confirms it for every case. The next section explains why the existence of an export endpoint does not settle that question either.

Scope and addressing are two different questions

An earlier version of this guide described the exchange of invoices with foreign buyers as entirely unverified. Since then we have read the MoF’s UAE Electronic Invoicing Guidelines, Version 1.1 dated 01 June 2026 (read on 24 October 2026) for our guide to Participant Identifiers and predefined endpoints. Those Guidelines answer part of the exchange question, but not the scope question, so it helps to keep the two apart.

Question 1: is the transaction in scope? (Decision 243/2025 Articles 3 and 4)

Scope is decided by the legal text: Article 3 brings in Business Transactions of a Person conducting Business in the State, and Article 4 removes the Excluded Transactions listed above. Nothing about how an invoice is addressed changes that analysis. A flow that is excluded under Article 4 does not come back into scope because an endpoint exists for it, and a flow that is in scope is not removed because the buyer has no identifier.

Question 2: where is the invoice sent? (the MoF Guidelines)

Addressing is an operational question. Invoices travel over the Peppol network from the supplier’s ASP to the buyer’s ASP, and each buyer is normally reached by its own Participant Identifier. The Guidelines specify three predefined endpoints for buyers that cannot be reached that way:

0235:9900000098 where the buyer does not have a Participant Identifier.
0235:9900000099 for exports where the buyer does not have a Peppol ID.
0235:9900000097 as the buyer address for deemed supplies.

A foreign buyer that is on Peppol is reached by its own Peppol identifier; the …99 endpoint is for the export buyer that has none. Whether a transaction is a deemed supply is a VAT question that has to be decided before the …97 endpoint is chosen.

What the endpoints do and do not tell you

They do tell you that the Guidelines expect some invoices to be issued to export buyers, to buyers without an identifier and for deemed supplies, and they give a fixed address for each case.
They do not tell you that every export, every sale to a buyer without an identifier or every deemed supply is in scope. Our guide does not read them as deciding scope, and neither should your project plan.
They do not settle the mechanics. As our identifier guide records, we have not verified how the FTA treats invoices sent to these endpoints, whether extra buyer data must be included, which document types may use them, or how the buyer then receives the invoice.

What still remains unconfirmed

The following cross-border and registration questions are not verified in the official texts and guidance we have read, and we leave them open rather than guess:

Non-resident suppliers. Whether a supplier without a UAE establishment is a Person conducting Business in the State under Article 3.
Imports. How purchases from abroad are treated, including whether the UAE buyer has any role in the system for them.
Unregistered businesses. How a Person conducting Business in the State that is not registered for VAT is treated in practice (see the VAT registration section above).
Whether a specific export is in scope. Exports are not excluded as a category, but we have not confirmed official guidance applying Article 3 to every export flow.

Raise these flows with your ASP and adviser, ask your ASP to show in testing what happens when each predefined endpoint is used, and check the MoF eInvoicing programme page for later guidance.

The full list of excluded transactions

After Decision 197/2026, Article 4(1) of Decision 243/2025 treats the following as Excluded Transactions:

Business Transactions by Government Entities in a sovereign capacity, not in competition with the private sector, in accordance with the VAT Law.
International passenger transport by an Airline via an Aircraft where an Electronic Ticket is issued.
Ancillary services provided directly to passengers by an Airline where an Electronic Miscellaneous Document is issued.
International transport of goods by an Airline where an Airway Bill is issued, for 24 months from the date the system becomes effective.
Financial services exempt from VAT or zero-rated under Article 42 of the VAT Executive Regulation.
Business Transactions between members of the same Tax Group, for 24 months starting 1 January 2027.
Any other Business Transaction the Minister may determine.

Article 4(2) leaves Excluded Persons, or categories of them, to a separate ministerial decision. We did not identify such a decision on the MoF legislation list when it was last checked on 22 October 2026. Article 4(3) allows a Person to join voluntarily for transactions that would otherwise be excluded; once it does, the eInvoicing decisions apply to it mandatorily, except those on violations and administrative penalties. Our guide to voluntary participation under Article 4(3) explains that option. The MoF summarised the October changes in its announcement of 19 October 2026.

Scope at a glance

B2B sale by a UAE business: within Article 3 unless an Article 4 exclusion applies. Basis verified.
Sale to a Government Entity (B2G): no exclusion in Article 4; not a B2C sale. Basis verified.
Sovereign, non-competing transaction by a Government Entity: excluded under Article 4(1)(a). Verified.
B2C sale: not subject until a further ministerial decision under Decision 244/2025 Article 5(2). Verified.
Transaction within the same Tax Group: excluded for 24 months from 1 January 2027 under Article 4(1)(f). Verified.
Business not registered for VAT: Article 3 does not mention registration; practical treatment unconfirmed.
Export sale: not excluded as a category under Article 4; whether a given export is in scope is unconfirmed. Where the export buyer has no Peppol ID, the MoF Guidelines give the endpoint 0235:9900000099. Addressing verified; scope unconfirmed.
Sale to a buyer without a Participant Identifier: scope follows Articles 3 and 4 as for any other sale; the Guidelines give the endpoint 0235:9900000098. Addressing verified.
Deemed supply: the Guidelines give the buyer endpoint 0235:9900000097; whether a transaction is a deemed supply is a VAT question. Addressing verified.
Import or non-resident supplier flows (outside the airline exclusions): not specifically addressed; unconfirmed.

A practical order of checks

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

Inventory every invoice flow. List each type of sale and purchase by counterparty: businesses, Government Entities, consumers, Tax Group members and foreign parties.
Apply Article 3. Confirm that the flow is a Business Transaction of a Person conducting Business in the State.
Run the Article 4 list. Test each flow against exclusions (a) to (g), noting the two that end after 24 months.
Separate B2C. Tag consumer sales for Decision 244/2025 Article 5(2).
Record VAT facts. Note whether you and each counterparty are Registrants, because that affects issue timing and self-billing.
Check exports separately for scope and address. Do not drop an export flow from the inventory because the buyer is abroad: Article 4 has no export exclusion. Record whether each export buyer has a Peppol ID or would need the 0235:9900000099 endpoint, and keep the scope question open with your adviser.
Find buyers without an identifier. List buyers, other than export buyers, that have no Participant Identifier and any deemed-supply scenarios, and agree with your ASP how invoices to 0235:9900000098 and 0235:9900000097 are handled. Our identifier and endpoint guide covers the customer master data side.
Flag the unconfirmed. Put import, non-resident supplier and unregistered-business flows on a list for your adviser and ASP.
Then turn to timing. Find your phase in the key dates summary and, if you are subject to the system, read our guide to appointing an ASP under Decision 168/2026. Our free eInvoicing readiness check can help you plan the work.

Frequently asked questions

Are B2B and B2G invoices both in scope?

On the text of Decision 243/2025, both are Business Transactions of the supplier and neither is excluded as a category. Specific exclusions, such as the Tax Group exclusion, can still apply to individual flows.

We are not registered for VAT. Are we outside the system?

Article 3 does not make VAT registration a stated condition. We have not verified official guidance on unregistered businesses, so confirm your position with the FTA or an adviser.

Are export invoices excluded?

No. Article 4(1) does not exclude exports as a category, so an export is not excluded simply because the customer is abroad; only the airline paragraphs deal with international transport. Whether a particular export flow is in scope is still unconfirmed in the official guidance we have read.

If the MoF Guidelines have an export endpoint, does that make every export in scope?

No. The endpoint 0235:9900000099 answers where an invoice is sent when an export buyer has no Peppol ID. It is an addressing rule in the Guidelines, not a scope rule in Decision 243/2025, and it does not decide whether a given export is in scope.

Our customer has no Participant Identifier. Is the sale outside the system?

Not for that reason. Scope is decided by Articles 3 and 4, not by whether the buyer has an identifier. The Guidelines give the endpoint 0235:9900000098 for buyers without one; how the buyer then receives the invoice has not been verified, so agree the handling with your ASP.

Can we join voluntarily for excluded transactions?

Yes. Article 4(3) allows it, and the eInvoicing decisions then apply to you mandatorily, except the decisions on violations and administrative penalties. Those penalties are set out in Cabinet Decision 106/2025, explained in our penalties guide.

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. Categories marked unconfirmed have not been verified against official guidance. Decisions 243/2025 and 197/2026 were read on 23 October 2026, the MoF Guidelines V1.1 on 24 October 2026 and the other official sources on 22 October 2026; the Minister may add or remove exclusions by later decisions. Always check the current Ministry of Finance and Federal Tax Authority publications and consult a qualified UAE tax adviser. For plain-English explanations of the defined terms used here, see our UAE eInvoicing glossary. Once you have mapped which transactions are in scope, our customer and supplier master data readiness guide explains how to prepare the counterparty records those transactions depend on. See all our guides.