What changed
| Topic | What Decision 168 says |
|---|---|
| Route to accreditation | Instead of "pre-approval, then final", accreditation is now direct: application, assessment and every test come before accreditation is granted. The Ministry answers an application within 90 business days (Articles 11 and 12) |
| Validity | Two years from the date granted (Article 13) |
| Renewal | Apply at least 70 business days before expiry; the Ministry decides within 60 business days (Article 15) |
| Termination and objection | Defined grounds for termination, and 40 business days to object (Articles 16 and 17) |
The eligibility conditions themselves changed little: an active Peppol provider that passed the OpenPeppol tests, a product in operation for at least two years, and a third-party product is allowed as long as the provider keeps full responsibility (Article 4). That is what Decision 56 introduced in May, carried over unchanged.
The three providers "under assessment"
Article 19 gives anyone pre-approved before 1 October 30 days to complete the accreditation requirements. If they do not, the Ministry terminates the pre-approval. On the Ministry's 16 October list, three were left in that section: Fyient Line Technology, Global Experts and SNB Accounting Management & Tax Consultancy. The same day, Avalara and UHY James moved to full accreditation.
If you are negotiating with one of the three, do not sign until its name appears in the accredited table with an accreditation number. If your own deadline is 30 October, their window and yours close in the same week.
Two years: why it matters to you, not just the provider
Article 15 says that a provider that does not apply for renewal in time, or does not fix the reasons for a rejection within the deadline, has its accreditation cancelled and its links to every person it represents revoked from the expiry date. Your invoicing stops if your provider neglects its paperwork.
Article 16 lets the Ministry terminate accreditation in three cases: the provider asks to stop, it no longer meets the conditions, or a breach is proven on the basis of documented complaints from customers. On termination, the provider must tell its customers within 5 business days, and it is removed from the register within 5 business days.
So a written complaint from you to the Ministry now carries weight in the text itself.
Conditions you can ask to see
- Insurance (Article 10): professional indemnity of at least AED 2,500,000, crime insurance of at least AED 5,000,000 and cyber fraud insurance of at least AED 5,000,000, all with insurers operating in the UAE.
- Information security (Article 8): multi-factor authentication, encryption in transit and at rest, regular security monitoring, ISO/IEC 27001 certification for the product, and compliance with hosting and data residency rules.
- Business continuity (Article 5): ISO 22301 certification, paid-up capital of at least AED 50,000, and audited financial statements.
The 100 free invoices
In the self-declaration form (Article 9 and Schedule 1), every provider commits to 100 free e-invoice exchange and reporting services a year for each customer, counted from the date the customer signs. When an offer says "100 free invoices", that is the minimum every accredited provider has promised, not a special feature. Compare on the price after the first 100.
What to put in the contract
- The accreditation number and its expiry date. Accreditation now expires, so get it in writing, and ask the provider to tell you when it files for renewal.
- A fee-free exit if the provider's accreditation is terminated or not renewed, with your data and invoices handed over in a portable format.
- Copies of the insurance policies and the ISO 27001 certificate. These are accreditation conditions, so every accredited provider must have them.
- How the 100 free invoices are counted and from when.
- The name of the product owner if the provider runs a third-party product.