The 100 free invoices: every customer's right, not a provider's perk

The short version. Article 9 of Ministerial Decision 168 of 2026 makes a written declaration a condition of any provider's accreditation: that it "is committed to providing 100 free eInvoice exchange and reporting services per annum to each End-User, commencing from the date of the signature of each End-User agreement" (Schedule 1, item d). So the 100 are your right at all 67, and the real comparison is what comes after.

What the text says exactly

100 a year per customer. Not 100 once, but every contract year.
Starting from the day you sign with the provider, not from 1 January. Sign in March and your year starts in March.
"Exchange and reporting services". The text says e-invoice exchange and reporting services; it does not spell out whether a received invoice counts like a sent one, or a credit note. That is the first question to ask your provider.
It was in Decision 64 of 2025 too. Decision 168 replaced it on 1 October 2026 and carried the commitment over unchanged.

Who gives more than the minimum

Provider	Published	Note
InvoiceNow biz	120 invoices a year free (sales and purchases)	For one user, no setup fee
Fatorly	100 documents a year free per company	"Documents" covers more than invoices; the subscription is not charged before 1 January 2027
TronStride	100 documents free, then 500 for AED 1,470 a year	Every tier published up to 240,000 documents
Zoho Books	100 transactions free, then 100 for AED 41 or 500 for 185	One-off packs on top of the Professional subscription
Ravera	First 100 invoices free	The rest on quote, confirmed to us on 11 October
DocFlow	First 100 e-documents free	Beyond that, not published

The rest say "first 100 free" or do not mention it at all; either way it is yours. You can filter providers that publish prices in the directory.

How to work out the real price

Take your invoices per year, subtract 100, and price the remainder at the provider's rate. Example: 600 invoices a year at Zoho = 100 free + a 500 pack for AED 185, on top of the Professional subscription (AED 90 a month). At TronStride = the 1,200-document tier at AED 2,205 a year, because 600 exceeds the 500 tier. The difference between providers shows here, not in the 100.

Three questions about counting

Does an incoming invoice from my supplier count against the 100? And a credit note?
Do the 100 start from the contract date or from the first invoice?
If I do not use all 100 in the first year, do they carry over? (The decision does not say; the provider decides.)