Appendix 2 of the UAE Electronic Invoicing Guidelines V1.1 provides an indicative readiness checklist for all Persons and Government Entities subject to Ministerial Decision No. 243 of 2025 and Ministerial Decision No. 244 of 2025. The Ministry is explicit that this is a minimum baseline — each business may have additional activities to address depending on its structure, ERP landscape, and transaction complexity.
The checklist spans four operational phases: understanding the regulatory framework, selecting and onboarding with an Accredited Service Provider (ASP), completing testing, and confirming go-live readiness. Working through these in sequence matters because the later steps are technically dependent on the earlier ones — testing cannot be meaningful until the ASP integration is configured, and the governance model for resolving errors cannot be agreed until both parties understand what the exchange and reporting process looks like end-to-end.
The Checklist Items
The Guidelines present the following items for confirmation:
Regulatory understanding: Have you reviewed MD No. 243 of 2025 and the amendments to the VAT Decree-Law, VAT Executive Regulation, and Tax Procedures Law arising from the introduction of the Electronic Invoicing System? Have you identified when you will be required to go-live as per the phased implementation plan in MD No. 244 of 2025? Have you reviewed the administrative penalties in Cabinet Decision No. 106 of 2025?
Data and systems: Have you identified the mandatory data points required on an Electronic Invoice and confirmed that your accounting or ERP system can extract them? Have you completed the necessary changes to your ERP or accounting applications to generate the required fields? Have you completed integrations between your ERP and ASP systems for sending and receiving invoice data?
ASP onboarding: Have you selected an ASP and completed all contractual and commercial obligations? Have you created a profile on your ASP's system? Have you registered with the FTA and created a Tax Identification Number (TIN) if you do not already have one? Have you completed the onboarding procedures with your ASP via EmaraTax? Have you obtained a Peppol participant identifier through your ASP?
Transmission and confirmation: Have you agreed with your ASP on how you will transmit invoice data to and from the ASP? Have you agreed on how you will receive confirmation messages regarding the success or failure of Electronic Invoice exchange and reporting? Have you agreed on data hosting and data security requirements?
Testing and go-live: Have you and your ASP completed testing of Electronic Invoice exchange and reporting? Have you established a governance model with the ASP on how to resolve errors? Are you ready to go-live as per the roll-out plan?
What the Checklist Reveals About Implementation Risk
Read as a diagnostic rather than a to-do list, Appendix 2 maps the points at which implementation commonly stalls. The ERP data extraction question — whether your systems can produce the mandatory PINT-AE fields at line-item level — is the one that most frequently surfaces a gap that was invisible during the contractual and procurement phase. Businesses that have selected an ASP and signed a service agreement often discover at the integration stage that their ERP master data does not carry the fields the ASP expects. The ASP is ready; the ERP is not.
The governance model for error resolution is similarly underweighted in most project plans. The Guidelines require a model to be in place before go-live, which means it needs to be designed when both parties understand the transaction types in scope, the failure modes that testing has surfaced, and the contractual obligation each party carries. A generic escalation process agreed at the point of ASP selection is not the same thing.
The TIN question catches non-VAT registered businesses. Under the Corporate Tax-based scope of the UAE Electronic Invoicing System, Corporate Tax registrants with revenues above the relevant threshold are in scope — not just VAT registrants. A business that holds a VAT registration has a TRN, and the first ten digits of that TRN are the TIN. A business that is CT-registered but not VAT-registered will need to generate a TIN through EmaraTax if it does not already have one.
The Peppol participant identifier (formatted as 0235 followed by the ten-digit TIN) is generated through the ASP during the onboarding process, not independently. Businesses should not assume this step is trivial — it requires the ASP to have completed the EmaraTax onboarding steps on the business's behalf, and any discrepancy between the business's EmaraTax registration data and its ASP profile data will block the identifier from being issued.