The Ministry of Finance has published Ministerial Decision No. 197 of 2026, which amends certain provisions of Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System.
In force from: 1 October 2026
Official text (MoF): Ministerial Decision No. 197 of 2026 (PDF)
Summary of changes
1. Definitions (Article 1)
- Accredited Service Provider is redefined as a Service Provider granted Accreditation to provide Electronic Invoicing Services in the State, in accordance with the legislation regulating the Electronic Invoicing System.
- New definitions are added for Tax Group and Taxable Person. Both follow the VAT Law.
- The definition of System Failure is deleted.
2. Excluded transactions (Article 4 replaced)
The following are Excluded Transactions:
- a) Government Entities acting in a sovereign capacity, not in competition with the private sector
- b) International passenger air transport where an Electronic Ticket is issued
- c) Airline services ancillary to (b), where an Electronic Miscellaneous Document is issued
- d) International air cargo where an Airway Bill is issued. This applies for 24 months only, from the date the eInvoicing System becomes effective.
- e) Financial services that are exempt or zero-rated under Article 42 of the VAT Executive Regulation
- f) New: transactions between members of the same Tax Group, for 24 months starting 1 January 2027
- g) Any other transaction the Minister determines
Excluded Persons will be set by a separate Minister’s decision. Excluded persons and transactions may opt in voluntarily. If they do, the full eInvoicing rules apply to them, except the violations and penalties decisions.
3. Issuance deadline (Article 6, Clause 5 replaced)
Electronic Invoices and Electronic Credit Notes must be issued and transmitted through the system within 14 Business Days from the Date of Business Transaction (subject to Clause 4 of Article 6).
4. Storage (Article 11 replaced)
Anyone subject to the system must keep all Electronic Invoices, Electronic Credit Notes and associated data for the period set by the Tax Procedures Law, and must be able to produce them to the Authority on request.
5. Article 12 repealed
Article 12 is repealed. Together with the deletion of the “System Failure” definition, this removes the previous system-failure notification obligation.
Points worth discussing for ASPs
- How you will identify and handle intra-Tax Group transactions during the 24-month window
- Customer onboarding for airline cargo clients, whose exclusion is time-limited
- Monitoring the 14 business day issuance window on your platforms
This post is a summary for discussion and is not legal or tax advice. Please refer to the official decision text above. Questions or interpretation points are welcome below.