UAE e-invoicing for agencies & consultancies: deadlines and billing

Ministerial Decision No. 244 of 2025 sets a phased rollout based on revenue. Revenue here means gross income in your most recent accounting period, taken from your financial statements (or other documents the FTA accepts if you have none). Most agencies and consultancies in the UAE fall in the second row of the table below.

In May 2026 the Ministry of Finance moved the ASP appointment deadline for the AED 50 million band from 31 July 2026 to 30 October 2026. The go-live date for that band did not move. The official guidelines (v1.1, dated 1 June 2026) still show the original July date, so check the Ministry's eInvoicing portal before you plan around either figure.

Anyone can start voluntarily from 1 July 2026. E-invoicing penalties apply only from the date you are required to comply, so a voluntary start lets you test with real clients without that exposure.

E-invoicing applies to every person conducting business in the UAE, for every business-to-business and business-to-government transaction, whether or not they are registered for VAT. A two-person studio below the VAT threshold is still in scope. Sales to individual consumers are out of scope.

Your electronic address on the network is your Tax Identification Number (TIN): the first 10 digits of your Corporate Tax TRN. If you are in scope but not registered for Corporate Tax, you need to register with the FTA to get a TIN. Members of a VAT group each use their own TIN, not the group representative's.

A PDF emailed to a client does not count as an e-invoice. An e-invoice is structured XML, sent through your ASP to your client's ASP and reported to the FTA. You appoint one ASP for both sending and receiving invoices, so your supplier bills reach you through the same provider.

The UAE uses a five-corner Peppol model. You (corner 1) send invoice data to your ASP (corner 2). Your ASP validates it against the UAE specification, PINT-AE, and delivers it to your client's ASP (corner 3), which passes it to your client (corner 4). In parallel, the ASPs report the tax data to the FTA (corner 5). Each step returns a status message, so a rejected invoice comes back with a reason instead of disappearing.

For a tax invoice, the Ministry lists 51 mandatory fields. Most already exist in a well-kept invoice: number, dates, parties, TRNs, totals and tax. The ones service firms tend to miss are covered below.

Every invoice carries an eight-flag transaction type code. Retainers, recurring fees and milestone billing fall under the 'continuous supply' flag. Mark monthly retainers and staged project fees that way instead of treating each as a one-off sale.

Every line needs an invoiced quantity and a unit of measure. For time-and-materials work that means hours as the unit, with the quantity and rate on each line. For a fixed-fee milestone, it means deciding how you express one deliverable (for example, one unit at the milestone price) and doing it the same way every time.

Retention works in two parts. When a client holds back part of each milestone payment, the calculation of the retained amount goes on a separate commercial document and does not appear on the e-invoice. When the retention becomes payable, you issue an electronic tax invoice for it with VAT.

Many agencies send a pro-forma so a client can raise a purchase order or pay a deposit. The UAE scheme has no category for provisional invoices. Every provisional invoice you issue must itself be an e-invoice, and you correct it later with an electronic credit note or an extra invoice.

If a pro-forma is only a quote, call it a quotation or an estimate and keep it out of your invoicing system. If money changes hands against it, the advance-payment rule above applies: issue a tax invoice when the payment arrives.

You can invoice in USD, SAR or EUR. The invoice declares its currency, but two mandatory line-level fields must be in AED: the VAT amount and the line total. Your system has to hold an exchange rate for each invoice and apply it line by line. A single converted total at the bottom is not enough.

Exports of services are in scope. A Dubai agency billing a client in Riyadh or Paris still issues an e-invoice with the export flag set. If that client has no Peppol ID, you use the predefined address 0235:9900000099 so the invoice is still reported.

Your clients will join the network at different times. When a UAE client has not onboarded yet, you address the e-invoice to the predefined endpoint 0235:9900000098 and also send them a regular tax invoice, for example a PDF, so they can recover input VAT. Expect to run both formats during 2027.

If your client is a free zone entity and the end user of your work is a different entity (for example, you contract with a holding company for a subsidiary's brand), the e-invoice records that end user as the beneficiary.

Firms below AED 50 million have until 31 March 2027 to appoint an ASP. That is enough time if you start with your data rather than your software.

Wakti is not an ASP, and you still need to appoint one. Wakti is where hours, retainers, milestones and expenses are approved and turned into invoice lines, with the client's TRN, the invoice currency and English and Arabic descriptions attached, ready to hand to the ASP you appoint.