Appendix 1 of the UAE Electronic Invoicing Guidelines V1.1 expands the four-step readiness framework from Section 9 into detailed operational guidance. Where Section 9 sets out what must be done, Appendix 1 explains how each step is executed, with specific reference to EmaraTax, the ASP onboarding portal, and the technical preparation required before go-live.
Step 1: Understand Electronic Invoicing Requirements
All Persons and Government Entities subject to MD No. 243 of 2025 and MD No. 244 of 2025 must carry out a gap analysis of the PINT-AE requirements against their current activities. This involves identifying which categories of Electronic Invoices will be required for each transaction type, and which data points — including mandatory fields and scenario-specific fields — must be present on each invoice type.
The system gap analysis must confirm that the entity's accounting, ERP, or invoicing system can generate and extract all required data points. Where the system cannot currently produce a required field, data migration or master data remediation must be planned and executed before go-live. The Guidelines specify that this analysis should be completed as part of Step 1 — before the ASP is selected — so that the entity can accurately brief candidate ASPs on its integration requirements.
Step 2: Select and Onboard with an ASP
The ASP selection process begins with consulting the Ministry of Finance's published list of Accredited Service Providers. The contract with the selected ASP must be finalised and all commercial obligations fulfilled before onboarding begins.
Onboarding is initiated by the entity via EmaraTax. The Account Admin of the Taxable Person accesses EmaraTax through the FTA's website, selects the E-Invoicing tile from the left-hand menu to view the ASP list, selects the required ASP, and clicks Proceed to ASP. The entity is then redirected to that ASP's portal to complete the onboarding process and obtain a Peppol participant identifier.
For Persons not already registered with the FTA, or not required to register for any Tax type, the entity must register with the FTA to obtain a TIN before onboarding can proceed. The Peppol participant identifier is derived from the TIN and is issued through the ASP onboarding process.
Each member of a Tax Group must complete onboarding individually, using their individual TIN. Tax Group members may use different ASPs. The onboarding process for each member follows the same steps as for a standalone entity.
Step 3: Test Electronic Invoice Exchange and Reporting
Prior to go-live, the entity must agree with its ASP on the technical approach for transmitting invoice data. This agreement covers the integration method (API, SFTP, flat file, or ERP connector), the data format and mapping from the entity's internal data to PINT-AE UBL XML, and the handling of error responses from the ASP's Access Point and from the FTA's Corner 5 platform.
The entity must confirm that its systems can generate and transmit all required data to the ASP and must run end-to-end tests. Testing should cover all Electronic Invoice categories relevant to the entity's transactions, all applicable special scenarios (from the eight scenarios defined in Section 10), and error resolution flows to confirm that failed invoices can be identified and resubmitted without data loss.
Step 4: Go Live and Ongoing Governance
Before commencing live Electronic Invoice exchange, the entity and its ASP must agree on roles and responsibilities for transmission oversight and error resolution. The Guidelines specify that this agreement must address how issues emerging during go-live are identified and addressed promptly.
Post go-live, the entity is responsible for keeping the ASP informed of changes in circumstances — including changes to trade licence status, corporate structure, or the scope of Electronic Invoicing transactions — using the reverification or offboarding processes in EmaraTax. The governance arrangement with the ASP must be sufficiently documented that changes can be processed systematically without disruption to the live Electronic Invoice exchange.
Practical Considerations for ERP-Driven Implementations
Appendix 1 makes clear that the initiation of each step — including the EmaraTax onboarding — sits with the Person or Government Entity, not with the ASP. For large enterprises running ERP platforms such as SAP or Oracle, the gap analysis in Step 1 must include an assessment of whether the existing invoice output format can be mapped to PINT-AE UBL XML, or whether a middleware or transformation layer is required between the ERP output and the ASP's input interface. This assessment is a prerequisite to both ASP selection and to accurate estimation of the time required for Step 3 testing.
