Ministerial Decision 66 of 2026 — exactly what changed
The decision amends paragraph (a) of clause (1) of Article 5 of Decision 244 of 2025. The new text:
"A Person subject to the Electronic Invoicing System and whose Revenue is equal to or exceeds AED 50,000,000 shall appoint an Accredited Service Provider by 30 October 2026 and shall implement the Electronic Invoicing System by 1 January 2027."
Three things to notice:
- Only the appointment moved. The go-live date did not. The gap between appointment and go-live shrank from five months to two — whoever appoints on the last day has 62 days for integration, testing and training.
- The second tier is untouched. Businesses under AED 50 million still appoint by 31 March 2027 and go live on 1 July 2027; government entities appoint by 31 March 2027 and go live on 1 October 2027.
- The official reason, per the Ministry's announcement of 10 May 2026: a review of market readiness and business feedback on the need for wider technical options and more competitive pricing. 32 providers were accredited that day; today there are 54.
Ministerial Decision 56 of 2026 — a higher bar for providers
The decision replaced Article 5 of Decision 64 of 2025 in full and added an Article 5(bis). The new conditions for accreditation:
- An active Peppol-certified service provider that has passed the OpenPeppol conformance tests. Implicit before; now the first condition in the text.
- The experience requirement (Article 5(bis)): the product through which the service is delivered must have been in operation for at least two years, with the experience of operating or managing it held by the provider itself or by the third party that owns the product. Evidence is whatever documents the Ministry requires.
- The remaining conditions stand: company registration, provider requirements, tax registration, product information security, self-declaration and insurance.
The clause that matters most for this market is Article 5(2): a provider may use a product owned by a third party, and may outsource its development, operation or management, provided the provider retains full responsibility for meeting the conditions and for oversight of the service. This is what the Ministry's announcement described as enabling national companies to partner with international providers to transfer technical know-how — in other words the white-label model: a UAE company carries the accreditation and the responsibility, with an international engine behind it.
What it means for you as a customer
- Ask your provider: is your product two years old, and who runs it? Running on a third party's product is allowed — but know who the third party is, where your data is hosted, and what happens if the partnership ends. Have the product owner's name written into the contract.
- The Peppol condition means portability. Your invoices travel over an open network under a Peppol participant identifier that belongs to your business. Switching providers is technically possible; make it contractually possible with an exit clause and no exit fees.
- Providers accredited before the amendment remain accredited; the decision does not order a reassessment. But any provider accredited after May 2026 passed the harder test.
- Do not spend the extension hesitating. The two integration months between 30 October and 1 January fall in most businesses' year-end close and audit. Appoint in September, test in October, run in November, and arrive in January comfortable.