E-invoicing for freelancers: are you in scope?

The basic rule: no exemption by "size", but there is one by "client type"

The Ministerial Decision defining the mandate's scope does not exempt freelancers as a category. The real rule is simpler and more precise: the mandate covers B2B (business-to-business) and B2G (business-to-government) transactions only — B2C (invoicing an end consumer) is currently excluded.

So the right question isn't "I'm a freelancer, am I exempt?" — it's "are my clients businesses or individuals?"

When are you actually in scope?

• You're VAT-registered (you have a TRN) — registration is typically mandatory above AED 375,000 in annual revenue, and voluntary between AED 187,500 and 375,000.
• And your primary clients are businesses or government entities — contracts, hourly projects, consulting, technical, or creative services for other organizations.

If both apply to you, you're in scope on the same timeline as any other business — most likely under the "rest of businesses" tier (revenue under AED 50 million), meaning: appoint an accredited provider by 31 March 2027, and go live from 1 July 2027.

Your specific right: 100 free transactions a year

Under Ministerial Decision 64 of 2025, very small businesses with limited transaction volume — which describes most freelancers — are entitled to 100 free e-invoicing transactions per year. This means you don't pay a per-invoice fee for your first 100 invoices each year, depending on how your provider implements it.

What if my clients are a mix (businesses and individuals)?

This is actually the most common situation. In this case, you're in scope only for the portion of your clients that are businesses — your invoices to individuals remain currently excluded under the existing arrangement. In practice, this means you need an invoicing system that can distinguish between the two, or at minimum a clear manual tracking of which invoices are in scope.

Practical steps for a freelancer right now

1. Confirm your tax status: Are you VAT-registered? If not and your revenue is close to AED 375,000, review registration first.
2. Review your client list: What percentage of your revenue comes from businesses vs individuals? This determines the actual size of your obligation.
3. Choose a provider matched to your size: Since your invoice volume is likely small, a boutique provider with simple pricing is a better fit than a large enterprise-scale provider — see our cost article and filter by category in the ASP directory.
4. Ask about the 100-free-transaction exemption explicitly before signing, not after.

Read next