What changed
| Topic | Before (Decision 243) | After (Decision 197) |
|---|---|---|
| Transactions between members of a tax group | In scope. Guidelines v1.1 gave them a grace period only and said they were not excluded | Excluded Transactions for 24 months from 1 January 2027 (Article 4(1)(f)) |
| Window to issue and transmit | 14 days from the date of the transaction | 14 business days from the date of the transaction (Article 6(5)) |
| Where invoices are stored | "Within the State", for the Tax Procedures Law periods | Retain them for the period set by the Tax Procedures Law and produce them to the Authority on request. "Within the State" is gone (Article 11) |
| System failures | Notify the Authority within 2 business days of a failure (Article 12) | Article 12 repealed, and the definition of "System Failure" deleted |
The decision also touches the definitions. "Accredited Service Provider" now refers to the legislation regulating the e-invoicing system, which includes the new Decision 168. Two definitions are added: "Tax Group" and "Taxable Person". And a Minister's decision can now name excluded persons themselves, not only categories of them.
Tax groups: from a grace period to an exclusion
Guidelines v1.1 said plainly that transactions inside a tax group "fall within scope and are not excluded", and that the grace period only moved the timing. Decision 197 puts these transactions on the list of Excluded Transactions in Article 4 itself, for 24 months from 1 January 2027, so until 31 December 2028.
The difference is practical. Excluded transactions fall under Article 4(3): you may e-invoice them voluntarily, and if you do, the whole system applies to you except the decisions on violations and administrative penalties.
What did not change: the exclusion covers only transactions between members of the same tax group. The group's sales to customers, its purchases from suppliers, and its dealings with a sister company that is not in the same VAT group all follow the normal deadline.
14 business days instead of 14 days
Decision 243 defines a business day as any day of the week except weekends and official federal government holidays. Fourteen business days with no public holiday is close to three calendar weeks instead of two.
But note how the clause opens: "Subject to Clause 4". Clause 4 says a VAT-registered issuer issues within the timeline in the VAT Law, which is 14 days from the date of supply (Article 67). So the 14 business days mainly help issuers who are not VAT-registered. A registrant is safer staying on 14 calendar days until the FTA says otherwise. Details in our 14-business-day article.
Storage: servers outside the UAE are now allowed by the text
Guidelines v1.1 read "within the State" flexibly, but the decision itself still said it. Now the text asks for two things only: keep the invoices, credit notes and associated data for the period set by the Tax Procedures Law, and be able to produce them to the Authority on request. The periods are unchanged: 5 years after the tax period, and 7 for real-estate records. The obligation stays with you, not your provider.
System failures: no more notice to the Authority
Article 12 required issuers and recipients to tell the Authority within two business days about any failure that stopped them from complying. It is repealed in full. The 14-business-day window to issue still applies, though, so a long outage at your provider is still your problem. What to put in the contract is in our system-failure article.
Cabinet Decision 106 of 2025 sets AED 1,000 for each day of delay in "notifying the Authority or the provider of system failures or changes to registration data". The system-failure half no longer has an obligation behind it once Article 12 is gone. Telling your provider about changes to your registration data within 5 business days (Article 5) still applies.