Article 6 of Ministerial Decision No. 243 of 2025 is the operational centre of the UAE electronic invoicing mandate. It establishes the issuance obligation, the four circumstances requiring a credit note, the Recipient's processing obligation, the timing rules for VAT-registered and non-registered Issuers, and the reporting obligation to the Authority. Every compliance programme for UAE e-invoicing traces its core workflow requirements back to this article.
Clause 1: The Issuance Obligation
Article 6(1): "Subject to Articles 8, 9 and 10 of this Decision, the Issuer shall issue and transmit an Electronic Invoice to the Recipient in respect of any Business Transaction."
The obligation is on the Issuer to issue and transmit — both verbs are mandatory. Generating the XML document internally and holding it in a queue is not compliance. The document must be transmitted through the Electronic Invoicing System (via the ASP) to be compliant. The words "in respect of any Business Transaction" reflect the full Article 3 scope — not just taxable supplies, not just transactions above a value threshold, but any Business Transaction conducted by the Issuer within the scope of the Decision.
The cross-references to Articles 8, 9, and 10 build in the agent and self-billing exceptions: where an agent issues on behalf of a principal (Article 8), or where the Recipient issues on behalf of the Issuer in a self-billing arrangement (Article 9), the Clause 1 obligation is modified but not extinguished. The transaction still requires an electronic invoice through the system; the question Article 8 and 9 address is who generates and transmits it.
Clause 2: The Four Credit Note Triggers
Article 6(2) establishes four circumstances that require an Electronic Credit Note to be issued and transmitted. These are:
(a) Where the Business Transaction is cancelled. A full cancellation of an issued invoice requires a credit note for the full invoice amount — not a revised invoice, not a deletion. The cancellation credit note must reference the UUID of the original electronic invoice.
(b) Where the agreed consideration is reduced for any reason. A price adjustment, a volume discount applied retrospectively, or a commercial settlement that reduces the originally agreed amount all trigger a credit note for the difference. "For any reason" is deliberately open — the reduction does not need to be error-based or dispute-based to require a credit note.
(c) Where the consideration is returned in full or in part. A refund — whether of the full invoice amount or a partial amount — requires a credit note. The credit note documents the return of consideration through the system, creating a traceable record in the FTA's reporting layer.
(d) Where an administrative or numerical error has occurred in relation to the Business Transaction. A keying error in the invoice amount, a wrong VAT treatment applied to a line, or a quantity error — these require a credit note against the original and a corrected invoice. This trigger covers the most common AR correction scenarios and will produce the highest volume of credit notes in practice.
Clause 3: The Recipient's Processing Obligation
Article 6(3): "The Recipient shall process Electronic Invoices and Electronic Credit Notes through the Electronic Invoicing System." This clause is the Recipient's counterpart to the Issuer's Clause 1 obligation. A Recipient cannot opt out of receiving electronic invoices by directing suppliers to send PDFs instead. Once the supplier is within the Electronic Invoicing System, the Recipient is obligated to process the incoming electronic documents through the system — which means having an active ASP appointment and an onboarded Peppol Participant Identifier that the supplier's ASP can route to. The Recipient obligation is the most frequently underestimated compliance requirement in Phase 1 implementations, particularly for businesses where procurement is managed separately from tax and finance.
Clauses 4 and 5: The Dual Timing Regime
Articles 6(4) and 6(5) create two overlapping timing rules depending on whether the Issuer is a VAT Registrant.
Clause 4: "Where the Issuer is a Registrant, the Issuer shall issue and transmit the Electronic Invoice and the Electronic Credit Note to the Recipient within the timeline prescribed by the VAT Law." For VAT Registrants, the VAT Law's tax invoice timing provisions — primarily Article 67 of the UAE VAT Decree-Law — govern. Article 67 requires a Tax Invoice to be issued within 14 days of the date of supply. For Registrants, the electronic invoice issuance obligation aligns with this existing VAT obligation.
Clause 5: "Subject to Clause 4, the Electronic Invoice or Electronic Credit Note must be issued and transmitted by the Issuer through the Electronic Invoicing System within 14 days from the Date of Business Transaction." For non-Registrant Issuers — those within the scope of Article 3 but not VAT-registered — the 14-day rule runs from the Date of Business Transaction as defined in Article 1: the earlier of the date the transaction occurred or the date payment was received. For advance payment scenarios, the 14-day clock begins on the payment receipt date. For non-Registrant businesses with subscription or retainer income, advance receipts are a common scenario that accelerates the issuance obligation significantly compared to current practice.
Clause 6: Reporting to the Authority
Article 6(6): "The Issuer and the Recipient must report Electronic Invoices and Electronic Credit Notes issued under Clauses 1, 2 and 3 of this Article to the Authority within the timeline prescribed by the Minister." This clause establishes the Corner 5 reporting obligation — the transmission of invoice data to the FTA's reporting layer — as a separate obligation from the exchange obligation between Issuer and Recipient. The Minister prescribes the reporting timeline by separate determination. For most transaction types in the current PINT-AE architecture, reporting occurs automatically as part of the ASP exchange flow, not as a separate subsequent step. But the legal obligation is distinct: exchange and reporting are two separate duties under Clause 6, both of which must be satisfied.
Clause 7: Fulfilment Through the ASP
Article 6(7): "The Issuer and the Recipient shall fulfil their obligations under this Article through the appointment of an Accredited Service Provider." This clause completes the circle: the Article 5 ASP appointment obligation is the mechanism through which the Article 6 exchange and reporting obligations must be fulfilled. An Issuer cannot comply with Article 6 without first complying with Article 5. And as Clause 1 of Article 5 makes clear, the ASP appointment does not transfer the Article 6 obligation from the Issuer or Recipient to the ASP — it provides the technical pathway through which that obligation must be discharged.