E-invoicing exclusions UAE: transactions outside the system

Article 4 of Ministerial Decision No. 243 of 2025, as replaced by Ministerial Decision No. 197 of 2026, excludes:

• Business transactions by government entities acting in a sovereign capacity.
• International passenger transport provided by an airline by aircraft, and services an airline provides directly to passengers that are ancillary to it.
• Transport of goods under an air waybill, for a period of 24 months.
• Financial services that are exempt from VAT or zero-rated.
• Transactions between members of the same tax group, for 24 months from 1 January 2027.
• Any other transaction the Minister determines.

Separately, Article 5(2) of Ministerial Decision No. 244 of 2025 keeps business-to-consumer transactions out of the system until the Minister decides otherwise, and a person dealing exclusively in them is excluded for that period. The guidelines describe this as supplies to or from natural persons not acting in business. Excluded persons as a category are to be set by ministerial decision.

A Dubai café selling to walk-in diners has no e-invoicing duty for those sales. If the same café invoices a corporate client for catering, that invoice is in scope once the café's wave goes live.

An exclusion from e-invoicing does not remove VAT invoicing rules or record keeping. Exempt financial services still need proper records, and a tax group still prepares internal invoices for its own accounts. Article 4(3) also lets a person voluntarily issue and report e-invoices for transactions that would otherwise be excluded.

In HelloBooks you can tag customers as consumers, tax group members or businesses, and the AI agent carries that tag onto each invoice. Ask "which of last quarter's invoices would be in scope for e-invoicing?" for a rough split your adviser can check. HelloBooks does not decide legal scope and does not transmit e-invoices.