A supplier operating under a self-billing arrangement has, for years, been able to treat invoicing as someone else's process. Section 10.3 of the Guidelines makes that arrangement conditional on a fact the buyer controls: whether the buyer is on the Electronic Invoicing System. Where the buyer is still outside it, the arrangement stops producing a compliant document, and the supplier’s own obligation arrives on its own schedule.
The Condition
The Guidelines state it in one line — self-billing of electronic Tax Invoices requires the buyer to be on the Electronic Invoicing System. Subject to agreement between the two parties, the buyer may issue the Electronic Invoice on behalf of the supplier, and that self-billed document must fulfil the Tax Invoice criteria in the VAT Decree-Law and the VAT Executive Regulation in the same way a supplier-issued invoice would.
Self-billing also stays inside VAT. It applies only under the conditions in the VAT Decree-Law and is unavailable to suppliers who are not registered for VAT, which is why Section 10.3 confirms there is no option for self-billing of Commercial Invoices.
Where the Timing Breaks
The mandatory implementation dates in MD No. 244 of 2025 apply to each Person by reference to their own category. A supplier's date and its buyer's date are set independently, and nothing aligns them.
Section 10.3 draws out what that means. Once a supplier is in scope for mandatory Electronic Invoicing, the obligation extends to all Business Transactions, including those made under a self-billing arrangement. If the buyer who has been raising those documents sits in a later phase, the arrangement stops short of a compliant Electronic Invoice, and the supplier is the Person carrying the unmet obligation. The Guidelines direct suppliers to check self-billing arrangements with customers for exactly this reason: the buyer may still sit outside mandatory implementation at the point the supplier’s own date arrives.
The Exposure Is Concentrated
Self-billing in the UAE tends to appear in a few recognisable relationship types. The ones that come up most often are construction subcontracting, agency and distribution structures, commodity supply into large industrial buyers, and recurring services where the buyer holds the measurement data. In each of these, the self-billing counterparty tends to be the larger party, which usually means an earlier mandate date and a working system. That is the comfortable case.
The uncomfortable case is the smaller buyer who self-bills because it holds the consumption or measurement records rather than because it is large. A supplier crossing into Phase 1 with such a buyer in a later phase has a live gap, and the remedy sits in the contract rather than the system: either the buyer moves voluntarily, or the arrangement reverts to supplier issuance for the intervening period.
The Action This Generates
Pull the list of customers who currently self-bill you, and put each one's expected mandate date against your own. Any relationship where the buyer’s date falls after yours needs a decision taken before your go-live, and that decision is commercial: reverting to supplier issuance changes a settlement process both parties built their accounts payable and receivable cycles around.
The legal mechanics of who may issue on whose behalf sit in Articles 8 and 9 of MD No. 243 of 2025, which cover the agent and self-billing provisions separately and are worth reading alongside this section.