Your right to 100 free e-invoicing transactions per year
Last updated: 2026-07-05 · Qayyid Editorial
UAE Ministerial Decision 64/2025 requires every Accredited Service Provider (ASP) to give each of its customers 100 free e-invoicing transactions per year, covering both invoice exchange and reporting to the Federal Tax Authority. This is not an optional marketing perk — it is a right for every customer that the provider is obliged to deliver.
What counts as a "transaction"?
The UAE uses the Peppol 5-corner Decentralised model (DCTCE): an invoice flows from the supplier (corner 1, C1) to its ASP (C2), on to the buyer's ASP (C3), then to the buyer (C4), with reporting to the FTA via the e-Billing system (corner 5). The free allowance covers this path: exchange + reporting. However, the counting method can differ from one provider to another (does one invoice count as one transaction? what about credit notes?) — so confirm with your provider, or check the MoF portal, before relying on a specific number.
Why this matters for a small business owner
There is a widespread fear that e-invoicing is "expensive" for small and freelance vendors. The reality is different: if you issue fewer than 100 B2B or B2G invoices a year, this free right can cover your entire year at no per-transaction cost. Many freelancers and micro-vendors issue only a limited number of invoices to companies and government bodies each year — and they may pay nothing for the transactions themselves.
| Item | Detail |
|---|---|
| Free allowance | 100 transactions/year per customer, per ASP (MD 64/2025) |
| What it covers | Invoice exchange + reporting to the FTA |
| Who benefits most | Low-volume freelancers and micro-vendors |
| Scope | B2B and B2G only (consumer B2C excluded for now) |
| Wave 2 (freelancers, non-VAT, other businesses) | Appoint ASP by 31 Mar 2027; go-live 1 Jul 2027 |
| No free government portal | Using an accredited provider is mandatory (unlike KSA's "Fatoora") |
Correcting common misinformation
- "Non-VAT-registered businesses are exempt" — false. VAT registration is irrelevant; if you issue B2B/B2G invoices you are in scope (Wave 2) and entitled to this free allowance.
- "E-invoicing is costly for small vendors" — overstated. The free right can cover a low-volume vendor's whole need.
- There is no free government issuance portal like Saudi Arabia's; using an ASP is mandatory — but every ASP must give you 100 free transactions.
How to claim your right
- Appoint an ASP through the EmaraTax platform; a provisional list of eligible providers exists (it is still moving, with final accreditation ongoing).
- Ask explicitly about the 100 free transactions and how they are counted before you sign.
- Note that the free allowance covers exchange and reporting; other charges (subscription, onboarding, platform) may apply — verify with the provider.
- Remember that failing to appoint an ASP risks an AED 5,000/month penalty (Cabinet Decision 106/2025), and keep your e-invoices for 5–7 years inside the UAE.
This explainer is for guidance only; the single authoritative, binding source is the Ministry of Finance e-invoicing portal: mof.gov.ae/en/about-us/initiatives/einvoicing. Check it and confirm with your provider before making any decision.