Ministerial Decision No. 168 of 2026 replaces pre-approval with direct accreditation

The Ministry of Finance has issued Ministerial Decision No. 168 of 2026, which sets the eligibility criteria and accreditation procedures for service providers under the UAE Electronic Invoicing System. The decision took effect on 1 October 2026.

It repeals Ministerial Decision No. 64 of 2025 and its amendments, including Ministerial Decision No. 56 of 2026. The Ministry says the earlier pre-approval stage helped onboard providers while the system was being built and tested, and that the programme is now operational.

The main changes are:

• Pre-approval is removed. Providers must complete the defined accreditation assessment and testing before accreditation is granted.
• Providers may still use third-party Peppol products and outsource parts of their service, but they remain fully responsible for compliance and service delivery.
• The decision sets out procedures for renewing accreditation, ongoing evaluation and termination, with a formal route to object to a termination.

There is a transitional rule for providers that received preliminary approval under the old decision. They have up to 30 days from 1 October 2026 to meet the new accreditation requirements, and do not need to apply again unless the Ministry decides otherwise. If they do not meet the requirements in that period, their preliminary approval is terminated.

The decision arrives just as the first appointment deadline falls. Businesses with annual revenue of AED 50 million or more must appoint an Accredited Service Provider by 30 October 2026 and go live by 1 January 2027; the rest appoint by 31 March 2027 and go live by 1 July 2027. Gulf News reported on 28 October that 65 businesses are currently listed by the Ministry as Accredited Service Providers.

For a UAE business, the practical point is to confirm that the provider you appoint, or have already appointed, holds full accreditation on the Ministry's list rather than a preliminary approval.