Selling through a marketplace moves the invoicing mechanics to the platform and leaves the legal obligation with the seller. The Guidelines state the position for e-commerce supplies in one line: the responsibility to issue an Electronic Invoice remains with the supplier even if the e-commerce platform issues one on its behalf. Every downstream question about platform selection, contracting and reconciliation follows from that sentence.
What the Scenario Covers
Scenario 7 applies to an electronic commerce supply through an Electronic Commerce Medium as defined by Ministerial Decision No. 26 of 2023 on Criteria and Conditions for Electronic Commerce for Purposes of Keeping Records of the Supplies Made. The examples given are a retailer selling products through its own website and goods sold via an e-commerce platform. The scenario applies to Commercial Invoices as well as electronic Tax Invoices.
Delegated Execution, Retained Liability
A merchant selling through a third-party marketplace typically has no direct control over invoice generation. The platform holds the order data, calculates the totals, applies the tax treatment and produces the customer-facing document. Under Scenario 7 the merchant remains the Issuer for the purposes of the Electronic Invoicing System, which means the merchant carries the exposure if the platform transmits late, transmits with incorrect data, or does not transmit at all.
Cabinet Decision No. 106 of 2025 penalises the Issuer for failure to issue and transmit an Electronic Invoice within the prescribed timeline at AED 100 per document, capped at AED 5,000 per calendar month. That penalty attaches to the merchant. A platform's operational failure becomes the merchant's administrative penalty, and the merchant's remedy against the platform is whatever the commercial contract provides, which is a separate matter from the tax position.
The Questions to Put to a Platform
Three come up in every marketplace arrangement. Which ASP does the platform transmit through, and is that ASP accredited by the Ministry. Whose Participant Identifier appears as the Issuer on the transmitted document, given that the merchant's TIN is the identifier that must be there. What evidence does the merchant receive that a specific order was transmitted successfully, and how quickly.
A merchant selling across several marketplaces will get different answers from each, and will need to reconcile transmitted documents back to its own sales records across all of them. That reconciliation belongs to the merchant, because the merchant is the party the Authority holds to the obligation.
Own-Website Sales Sit in the Same Scenario
A retailer selling directly through its own website is inside Scenario 7 as well. The obligation and the execution sit with the same entity, which removes the counterparty risk and replaces it with an integration question: whether the e-commerce platform, the order management system and the ERP produce a single invoice record that can be transmitted, or three partial records that have to be assembled first.
For any business with material marketplace revenue, the platform review belongs in readiness planning rather than in contract renewal cycles. A platform that cannot answer the transmission and identifier questions is a compliance dependency the merchant cannot control and cannot transfer.