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14 business days to issue an e-invoice: who gets them, and who stays on 14 days

Decision 197 changed the window to issue and transmit an e-invoice to 14 business days. But the clause opens with "Subject to Clause 4", and Clause 4 keeps VAT registrants on the VAT Law timeline. Here is the arithmetic, with dates.

Last updated: 24 October 20264 min read

The short version. If you are not VAT-registered, you have 14 business days from the transaction to issue and transmit the e-invoice. If you are registered, Article 6 itself sends you to the VAT Law, which gives you 14 days from the date of supply. The clock starts on the date of the transaction or the date payment is received, whichever is earlier.

The text

Article 6 of Decision 243 of 2025, as amended by Decision 197 of 2026:

  • Clause 4: where the issuer is VAT-registered, it issues and transmits the e-invoice and the e-credit note to the recipient within the timeline prescribed by the VAT Law.
  • Clause 5 (amended): subject to Clause 4, the issuer must issue and transmit the e-invoice or e-credit note through the e-invoicing system within 14 business days from the date of the business transaction. Before the amendment it said "14 days".

The VAT Law (Federal Decree-Law 8 of 2017, Article 67) requires a registrant to issue a tax invoice within 14 days of the date of supply. Since 2023 the tax credit note has a 14-day limit as well.

Who is on which clock

IssuerWindowReference
VAT-registered business14 days from the date of supply, under the VAT LawArticle 6(4), and VAT Law Article 67
In scope for e-invoicing but not VAT-registered14 business days from the transactionArticle 6(5) (amended)
Transaction between members of the same tax group, 1 January 2027 to 31 December 2028Excluded; e-invoicing is voluntaryArticle 4(1)(f)

This reading comes from the text itself. The FTA has not yet published guidance on how the two windows combine, so if you are registered, set your system to 14 calendar days and you lose nothing.

When the clock starts

Article 1 defines the "Date of Business Transaction" as the earlier of the date the transaction occurred and the date payment for it was received. If you take an advance payment before delivery, the clock started on the payment date, not the delivery date.

Worked dates

A business day is any day except weekends and official federal government holidays. The federal government weekend is Saturday and Sunday, so Friday counts.

Transaction date14 days (registrant)14 business days (non-registrant)
Thursday 5 November 2026Thursday 19 NovemberWednesday 25 November
Thursday 26 November 2026, no public holidaysThursday 10 DecemberWednesday 16 December
Thursday 26 November 2026, if 1, 2 and 3 December are public holidaysThursday 10 DecemberMonday 21 December

The government announces Commemoration Day and National Day holidays each year and sometimes moves them. Count on that year's official announcement.

What to do

  1. Know your VAT status first. If you are registered, do not build your billing cycle on 14 business days.
  2. Advance payments start the clock. Tie invoice issue to payment receipt, not only to delivery.
  3. Ask your provider whether its system warns you before the window closes, and which timestamp it records as the transmission date.
  4. Credit notes too. The same window applies to the e-credit note, so returns and discounts run on a clock like invoices.
The penalty. Cabinet Decision 106 of 2025 sets AED 100 for each invoice or credit note not issued or transmitted on time, capped at AED 5,000 a month. The Ministry's October presentation names a new penalties decision (173 of 2026), but its text had not been published as of 24 October.

Read also

Sources: Ministerial Decision No. 197 of 2026 (mof.gov.ae); Ministerial Decision No. 243 of 2025, Articles 1 and 6; Federal Decree-Law No. 8 of 2017 on VAT, Articles 62 and 67 as amended by Decree-Law No. 18 of 2022; Cabinet Decision No. 106 of 2025.
This content is general information, not tax or legal advice. The official text prevails.