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Shared Tax Research Memo

What's new with the new e-invoicing guide 1.1 vs the previous 1.0?

By Samar Boulos June 22, 2026

Research Question

What's new with the new e-invoicing guide 1.1 vs the previous 1.0?

AI Analysis

UAE E-Invoicing Guidelines: What Changed from Version 1.0 to Version 1.1

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  • [UAE Electronic Invoicing Guidelines Version 1.1](#LEG:267) — Issued 1 June 2026
Version 1.1 is a meaningful expansion of the original guidelines, adding several new sections and refining existing content to give businesses a clearer operational roadmap. Here are the key differences:

New content added in v1.1:
- Appendix 4 — Detailed guidance on storage obligations under Article 11 of [Ministerial Decision No. 243 of 2025](#LEG:63), clarifying how and where Electronic Invoice data must be retained.
- Appendix 5 — New clarification on the treatment of advance payments and retention amounts, addressing how these common commercial arrangements interact with e-invoicing obligations.
- Provisional Invoice — A new defined term has been introduced, covering invoices issued before final transaction details (quantity, price, taxes) are confirmed, used for interim accounting or payment purposes. The guide notes these are often replaced by a Tax Invoice once all particulars are finalised.
- Revenue definition refined — Revenue is now explicitly defined as gross income from the most recent Accounting Period based on financial statements, or if unavailable, other FTA-acceptable documentation. This matters because Revenue is the metric used to determine phased implementation timelines.
- Expanded glossary — Additional terms including Airline, Aircraft, Airway Bill, Electronic Ticket, and Electronic Miscellaneous Document have been added, signalling that the e-invoicing framework now explicitly addresses airline and aviation-sector billing documents (IATA-standard documents).

Structural and scope refinements:
- The guide now explicitly references four underlying legislative instruments (MD No. 243 of 2025, MD No. 244 of 2025, MD No. 64 of 2025, and CD No. 106 of 2025), whereas v1.0 referenced fewer.
- The Participant Identifier definition has been tightened: it is now described as "0235 followed by the 10-digit TIN," making the Peppol endpoint format unambiguous.
- The Highlights section now includes a specific reminder that Tax Group members must use their own TIN (first 10 digits of their own TRN), not the Tax Group representative's TRN — a practical clarification to prevent onboarding errors.
- The table of contents confirms the guide has grown from a shorter document to 51 pages, reflecting the additional appendices and expanded guidance.

> Simply put: Version 1.1 adds practical guidance on storage obligations, advance payments and retention, airline-sector documents, and the provisional invoice concept — businesses should update their implementation plans and internal procedures to reflect these additions before their go-live phase.

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