Understanding the role of an Accredited Service Provider for eInvoicing

An Accredited Service Provider (ASP) for eInvoicing is a third-party entity officially recognised by the relevant governmental authorities to offer electronic invoicing services in their jurisdiction. These providers are crucial for ensuring the smooth functioning of the eInvoicing process between businesses and the Tax Administration.

This approach was first implemented in Mexico and has been more recently adopted in other countries such as Peru, Colombia, Guatemala, and the UAE.

Using a third-party service provider for eInvoicing is cost-effective for Tax Administrations, as it eliminates the need for significant investment in developing and maintaining complex systems internally. However, this approach also presents potential reputational risks if the provider has deficiencies in their eInvoicing system.

The UAE Ministry of Finance (MoF) has recently released the Ministerial Decision No 64 of 2025, which outlines the accreditation process for service providers in the eInvoicing programme.  Before starting the accreditation process on the MoF portal, service Providers must first be certified by OpenPeppol. This process includes signing an agreement that defines roles and responsibilities, specifying that businesses, as “End Users”, are fully responsible for the data content exchange on the Peppol network (Art 9 of the Peppol Service Provider Agreement).

It is crucial for businesses to ensure that the data they provide to the ASP is accurate and error-free.  Consulting with tax advisors is essential to verify the data’s accuracy and integrity, as the ASP will not be liable for any inaccuracies.  If incorrect data is submitted to the Tax Administration, the business will be accountable and may face tax penalties.

The Role of the Accredited Service Provider in the UAE

An Accredited Service Providers are responsible for making transporting eInvoices between supplier and purchaser, along with sharing an extract of eInvoice data known as a tax data document, to MoF/FTA. Alongside the eInvoices, the ASP will also maintain a service to receive responses from various parties on the success/failure of transmissions.

In the UAE, only service providers listed on the Ministry of Finance (MoF) website are deemed compliant to operate as access points in the Peppol network.  These providers have successfully navigated rigorous testing and requirements, proving their capabilities in technical and information security standards.  This compliance ensures that businesses receive reliable and secure e-invoicing services, integral to efficient digital transaction.

Key advantages over Saudi Arabia’s approach

An important difference between the UAE and Saudi Arabia’s approach to eInvoicing Service Providers accreditation.  In Saudia Arabia, listed eInvoicing providers only show that they agree to follow the rules and be compliant, without needing official testing or certification.  On the other hand, the UAE requires strict testing and accreditation, ensuring businesses get high compliance and better security.  However, it is important to note that this accreditation in the UAE does not make the Accredited Service Provider responsible for the data processed within the Peppol network, the quality and accuracy of the data remain the responsibility of the business itself.

Considerations for selecting an E-invoicing Provider

When choosing an eInvoicing provider in the UAE, businesses should consider, at a minimum, several key factors beyond the mandatory requirements set by the MoF and Tax Administration for issuing compliant e-invoices. Below are some factors to consider when choosing the eInvoicing provider:

1. MoF listing: Ensure the provider is officially listed on the MoF website, verifying their compliance and capability to serve as a Peppol access point. Being listed on the MoF website ensures that ASP have undergone through testing and evaluation, confirming their ability to maintain the integrity and efficiency of electronic invoicing processes within the Peppol network.
2. Contingency plan: Discuss with the ASP contingency plans to manage potential service interruptions, ensuring continuous and reliable eInvoicing operations. The service must be operations 24 hours a day, 7 days a week. If the system of the ASP requires maintenance or upgrades, any interruptions must be communicated to businesses well in advance, along with an alternative plan to prevent any disruption of operations.
3. Proof of concept (POC): Requesting a POC can provide invaluable insights into the provider’s system, enabling businesses to evaluate how their data will be processed and ensuring alignment with operational needs.
4. Level of service (SLA):  Discuss with the service provider the level of service, understand the process for raising issues in the system, and determine how quickly these issues will be resolved.  This helps ensure that you have reliable support and service when needed.  Additionally, the SLA must explicitly detail the expected response and resolution times for any issues raised by businesses.  Knowing how quickly the ASP can address and resolve these concerns provides businesses with valuable confidence in their selection.

Who can become an Accredited Service Provider?

To become accredited, service providers must meet specific requirements:

• Business Documentation – Provide trade license, proof of capital and Power of Attorney.
• Certifications Needed:
  • Peppol Certification
  • ISO 22301 for business continuity
  • ISO/IEC 27001 for information security
• Insurance requirements – Maintain professional indemnity, crime and cyber fraud insurance. All insurance policies must be issued within the UAE.
• Tax compliance – Must be registered for taxes in the UAE.
• Service Commitment – Offer 100 free eInvoice exchanges each year.
• Experience in the operation of and Electronic Invoicing system – 2 years

Termination of the Accreditation by the Ministry of Finance

It is important to note that the Ministry of Finance is required to inform the accredited service provider of the termination decision within 5 days.  Subsequently, the accredited service provider must notify the associated end users of this termination within 5 days of receiving the notification.

This limited timeframe for communication poses a significant challenge, as businesses may not have sufficient time to prepare and execute the migration plan to a new provider.  The abrupt transition could create operational risks, potentially disrupting business operations during the onboarding process with a different accredited provider.  To mitigate these risks, the MoF should consider extending the notification period, allowing businesses adequate time to smooth transition and implement a comprehensive migration plan.

Summary

The UAE’s accreditation process for eInvoicing providers demonstrates commitment to high standards of operational efficiency and security.  By carefully selecting providers that meet these criteria, businesses can not only ensure compliance but also enhance their digital transformation processes.

While using Accredited Service Providers is mandatory for facilitating einvoicing and ensuring interoperability within the eInvoicing system, the ultimately responsibility for ensuring the accuracy and integrity of the data exchanged lies with the end users- the businesses themselves.

Engaging with a tax advisor at the outset of the project is essential to effectively navigate complexities the complexities of tax compliance, data dictionary requirements, and data management.  This proactive approach helps mitigate risks, ensures compliance with regulatory requirements, and supports a smooth and successful implementation of the eInvoicing process.