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The Eligibility Criteria for Service Providers Under the Electronic Invoicing System

No company or electronic service provider may consider itself an accredited service provider. Based on Ministry of Finance Decision No. 64 of 2025 and the amended Ministry of Finance Decision No. 56 of 2026, several criteria must be met in order for a service provider to be accredited within the UAE e-invoicing system.

An Accredited Service Provider (ASP) is a company approved by the UAE Ministry of Finance to transmit, validate, and report electronic invoices on behalf of businesses, in accordance with the Five-Pillar Model based on the PEPPOL network. The invoice sender and receiver connect through accredited service providers, and tax-related data is automatically reported to the relevant authorities.

Can Companies Connect to the System Directly Without an Accredited Service Provider (ASP)?

Companies cannot connect to the system directly. They may only connect through an Accredited Service Provider (ASP) via the PEPPOL network, which is responsible for validating electronic invoices and converting data into XML format.

Purpose of Eligibility Criteria and Accreditation Procedures for Service Providers

The e-invoicing system is implemented as part of the UAE’s comprehensive digital transformation, enhancing the efficiency of the financial ecosystem and ensuring accurate exchange of electronic invoices and tax data with the Federal Tax Authority (FTA). Therefore, all concerned companies and government entities must ensure compliance with the eligibility criteria for e-invoicing service providers as stated in Article (2) of Decision No. 56 of 2026.

Also check: UAE E-Invoicing Advisory & Compliance Support

Need Expert Advice?

Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.

What Are the Eligibility and Qualification Criteria Required for a Service Provider to Obtain Accreditation?

Service providers seeking accreditation must meet the following conditions according to Article (5) of Decision No. 56 of 2026.

First: Active and Accredited Service Provider

The service provider must be active and accredited by PEPPOL and must have completed the Open PEPPOL tests.

Second: Experience Requirements

The PEPPOL service provider product used for e-invoicing must have been operational for at least two years. The provider or a third party must have experience in operating and managing the product. The service provider may use a third-party payment service provider, provided that the accredited service provider remains responsible for meeting all requirements. Experience must be proven through supporting documents.

Third: Company Registration Requirements

A service provider is considered compliant with company registration requirements if it is a legal entity established under UAE laws and licensed to operate within the UAE, and it has a paid-up capital of no less than AED 50,000.

Additional requirements include maintaining active and accredited PEPPOL status within the UAE, and ensuring the PEPPOL product meets international PEPPOL requirements and the UAE PINT-AE model.

Fourth: Tax Registration Obligations

A service provider is considered compliant with tax registration obligations if it is registered for Corporate Tax, and Value Added Tax (VAT) under Federal Decree-Law No. 8 of 2017 whenever registration is mandatory.

Fifth: Information Security Requirements for the PEPPOL Product

The PEPPOL product must meet information security requirements by maintaining multi-factor authentication mechanisms, encrypting all data, conducting regular security monitoring, and holding a valid ISO 27001 certification.

Sixth: Self-Declaration Requirements

The service provider must submit a self-declaration form according to the format specified in Annex (1) of the decision, declaring that:

  • It is not subject to liquidation, closure, or bankruptcy proceedings
  • It is not involved in any criminal, insolvency, or bankruptcy-related legal cases
  • It is not listed on any government blacklist
  • It commits to providing 100 free annual services related to e-invoice exchange and reporting
  • It maintains confidentiality of all data obtained during the provision of PEPPOL services

Seventh: Insurance Requirements

The following insurance coverage must be maintained:

  • Professional liability insurance of AED 2,500,000 at one of the working insurance companies in the UAE
  • Crime insurance coverage of AED 5,000,000 at one of the working insurance companies in the UAE
  • Cyber fraud insurance coverage of AED 5,000,000 at one of the working insurance companies in the UAE

Submitting the Accreditation Application to the Ministry of Finance

The service provider must submit an accreditation application according to the procedures set by the Ministry of Finance. The Ministry will review the application and may reject it if the provider does not meet the required criteria. Preliminary approval is granted once the required procedures are fulfilled.

When Is Final Accreditation Granted After Receiving Preliminary Approval?

Final accreditation is granted after completing and meeting the following:

  • Completing tax data reporting tests (electronic invoices and electronic credit notes) with the Federal Tax Authority
  • Completing the service tests required by Open PEPPOL
  • Coordinating with the Federal Tax Authority to conduct operational readiness tests
  • Undergoing continuous evaluation for accreditation

What Happens If the Accreditation of a Service Provider Expires?

According to Article (18) of Decision No. 56 of 2026, the service provider may submit a renewal request to the ministry at least 70 working days before the accreditation expiry date, provided that a valid insurance policy is submitted and information security requirements for the PEPPOL product are met.

Cases in Which the Ministry May Terminate a Service Provider’s Accreditation

The Ministry may terminate accreditation in the following cases:

  • If the accredited service provider wishes to stop offering e-invoicing services in the UAE
  • If the provider fails to comply with or no longer meets accreditation requirements
  • If the Ministry receives documented complaints from end-users regarding the provider’s conduct or obligations

The provider will be notified of the authority knowledge within five working days.

Consequences of Accreditation Termination

Termination results in removal from the central registry and any related databases, and the Ministry notifying Open PEPPOL to remove the provider from its official website and directory.

The terminated provider may appeal the decision within 40 working days from receiving the termination notice.

Related: VAT Consultants in UAE

Frequently Asked Questions (FAQs)

What is an Accredited Service Provider (ASP)?

An Accredited Service Provider is a company approved under the UAE Ministry of Finance accreditation framework. It is responsible for transmitting electronic invoices, validating them, and reporting them on behalf of businesses according to the Five-Pillar Model adopted on the Peppol network.

Can companies connect to the system directly?

No. Companies cannot connect to the system directly; they must use an Accredited Service Provider (ASP).

What is the Peppol PINT AE standard?

PINT AE is the UAE version of the international Peppol invoice format. It clearly defines the commercial data contained in an electronic invoice, such as VAT details and tax registration numbers. The service provider converts invoices from the accounting system into the PINT AE format and validates them before sending. Every Accredited Service Provider in the UAE must be a member of Open Peppol.

Can I rely on sending PDF invoices by email?

No. A compliant invoice under the new regulations must be a data file in PINT AE format. The UAE electronic invoice is an organized XML file in PINT AE format. From the mandatory implementation date applicable to your company’s segment, a PDF sent by email will no longer be considered an invoice for covered transactions.

What happens if the Accredited Service Provider rejects an invoice?

A confirmation or electronic rejection notice is sent to the sender’s service provider and to the Federal Tax Authority. The notice clearly states the reason for rejection. The invoice remains in “sent” status and does not move to “validated” status.

What are the eligibility and qualification criteria for service providers?

The service provider must be active and Peppol-certified, and must meet the requirements regarding experience, registration, and information security for the service product. Additionally, the provider must be registered for Value Added Tax (VAT) where mandatory, and for Corporate Tax, while also satisfying self-declaration and insurance requirements.

 

Need Expert Advice?

Contact the team at Farahat & Co. for professional support and expert insights for businesses operating in the UAE.

How Farahat & Co. Can Help

Farahat & Co. assists you in making the right choice before engaging with Accredited Service Providers (ASP) for e-invoicing, ensuring accurate exchange of electronic invoices. We support you in selecting an active and PEPPOL-accredited service provider, verifying experience requirements, ensuring the provider meets information security standards and holds a valid ISO certification, confirming the provider is not under liquidation, closure, bankruptcy, or listed on any government blacklist, and ensuring the provider has received final approval from the Ministry of Finance.

We also help ensure your financial system is compatible with issuing electronic invoices.

Contact Farahat & Co. today and ensure your readiness to appoint an Accredited Service Provider in full compliance with all regulations.

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