12 Questions to Ask an FTA Approved ASP Before You Sign
It’s 27 October. Your shortlist is down to two providers, and both say they’re ready. Only one may be on the Ministry of Finance (MoF) register.
That’s the real question behind every FTA approved ASP decision. The Federal Tax Authority (FTA) receives your tax data, but the MoF decides who is accredited. An ASP e-invoicing UAE contract is a long commitment, and you can appoint only one Accredited Service Provider (ASP) at a time.
ADEPTS doesn’t sell an ASP. We’re chartered accountants, so we ask the accountants questions. With our specifically tailored 12 questions, we simplify how to choose an ASP UAE ; one finance teams can defend at audit.
Key Takeaways
As of 30 September 2026
- Deadline: 30 October 2026 to appoint an ASP if revenue is AED 50 million or more; go-live is 1 January 2027.
- Two lists: the MoF publishes accredited and pre-approved providers separately, and only accredited providers carry an accreditation number.
- Provider count: 60 accredited and 6 pre-approved (as of 30 September 2026).
- Question groups: four, covering verification (1 to 3), technical fit (4 to 6), commercial terms (7 to 9) and compliance and audit (10 to 12).
- Biggest mistake: trusting a logo or press release instead of checking the accreditation number on the register.
Question 1 to 3: Is Your FTA Approved ASP Really Accredited?
Start here. Everything else is irrelevant if this fails. Would you rent an office without seeing the title deed?
An application is not an accreditation, just as booking a driving test isn’t holding a license. The MoF register has two lists: accredited providers, and pre-approved providers still in final assessment. A provider of neither may describe accreditation as “in progress.”
The register recognizes no such status! Searches for approved ASP in UAE or approved ASP in Dubai, and for FTA accredited service providers, tend to surface provider-written pages. Go to the register instead.
Accredited
- Full accreditation granted
- Accreditation number shown
- Valid for two years
Pre-approved
- Final production assessment under way
- No accreditation number yet
- Must reach accreditation within the Ministry’s timeline
1. Which MoF List Are You On, Accredited or Pre-Approved, and What Is Your Reference?
Ask for the accreditation number, then check it yourself. A good answer names the list and gives a number that matches the register. A weak answer says the application is “in progress,” waves a partnership announcement, or asks you to trust the logo.
2. If You Are Pre-Approved, What Is the Committed Date for Full Accreditation, in Writing?
A pre-approved provider may serve customers, but only until the timeline the Ministry sets expires. After that, Ministerial Decision No. 64 of 2025 (Article 4) bars it from continuing. Get the committed date in writing, plus a no-cost exit right if it slips. A weak answer sounds like “any day now.”
3. Are You an Active Peppol-Certified Access Point, and Tested Against PINT AE Specifically?
Global Peppol certification is not the same as UAE readiness. PINT AE, the Peppol International specification for the UAE, is the country’s own standard, and a provider can be a long-standing Peppol member elsewhere without being tested against it. Any Peppol service provider UAE businesses shortlist should show an active certificate, its duration, and evidence of PINT AE validation. A weak answer is “we’re Peppol compliant globally.”
Questions 4 to 6: Technical Fit With the Systems You Already Run
Lists of the best e-invoicing software UAE vendors publish about themselves are sales material. Fit with your own enterprise resource planning (ERP) system is the only test that counts.
4. Is the Platform Your Own Product or a Reselling Arrangement?
The e-invoicing software UAE clients log into may be the provider’s own product or a white-labeled one. Reselling is allowed: Ministerial Decision No. 56 of 2026 lets a provider use a third-party product, provided it stays fully responsible. So the question isn’t purity.
It’s accountability. A good answer names the product owner, makes the provider the accountable party in the contract, and offers direct support. A weak answer can’t name the vendor behind the platform, or points to “our partner” when something breaks.
5. Do You Have a Production-Ready Integration With Our ERP Today, and What Are the API Rate Limits?
Integration existing is not the same as integration coping. A connector that works on a quiet Tuesday can choke at month-end, when 10,000 invoices hit the queue and the provider throttles it. Think of a highway that drops to one lane at rush hour.
Ask for the application programming interface (API) rate limit, the throttling behavior and the peak-volume ceiling, then get all three written into the service level agreement (SLA), not described in a demo. A weak answer is “we can build that.” Check your own side first with our ERP readiness checklist.
6. Can We See a Live Sandbox Transmission, an FTA Acknowledgment and a Rejection?
Ask to see a rejected invoice on screen, not a description of one. In the UAE’s five-corner Decentralized Continuous Transaction Control and Exchange (DCTCE) model, the FTA is the fifth corner, receiving tax data from the providers.
A good answer walks you through three outcomes in a live sandbox: an accepted invoice, the FTA confirmation returning through your provider, and a rejection with a readable reason. Under the MoF Guidelines, the provider must also tell you promptly when tax data reaches the authority. A weak answer is a slide deck. The output must match the XML format the provider must produce.
Questions 7 to 9: Commercial Terms and Total Cost
Let’s take a look at some important questions regarding the commercial terms and the total cost of ASP appointment.
7. What Is the Full Fee Structure: Onboarding, Per-Invoice, Tier Thresholds and Overages?
Price is more than a per-invoice rate. Ask for onboarding fees, per-invoice charges, tier thresholds and overage rates in one schedule, priced at three volumes: your normal month, double that, and your month-end peak.
Every provider must commit to 100 free e-invoices a year under Ministerial Decision No. 64 of 2025 (Article 10), and the MoF’s selection guidance advises writing that into the contract. It’s a start, not a budget. A weak answer is “custom quote after onboarding.”
8. Who Pays When the FTA Changes the Specification, and Who Pays the Penalty When Transmission Fails?
Two costs in one question, and the second is the one that rarely gets asked. If a transmission fails because of the provider’s technical error and the FTA penalizes you, does the provider absorb it? Who carries that risk? Under Cabinet Decision No. 106 of 2025, the penalty lands on you as the issuer: AED 100 for each invoice not issued and transmitted on time, up to AED 5,000 per calendar month. Ask for a penalty pass-through clause in writing, and for proof of insurance. Ministerial Decision No. 64 requires at least AED 2,500,000 of professional indemnity cover. A provider that won’t take liability for its own failure is telling you something. On specification changes, a good answer is that updates sit inside your fee.
9. What Is the Uptime SLA, and What Are the Exit Terms and Data Portability Rights?
Ask for the actual SLA document, not a summary. E-invoicing downtime stops invoicing, and that stops cash collection. Get the committed uptime figure, the service credits, how you’ll be told about an outage, and what happens to your archive if the relationship ends. A good answer arrives as a signed document with an archive handover date. A weak answer is a percentage on a web page.
Questions 10 to 12: Compliance, Records and What Happens at Audit
These are the questions an accountant asks and a software reseller doesn’t.
10. Where Is Our Invoice Archive Physically Held, Who Owns It, and In What Format Can We Retrieve It?
You must keep invoice records for five years after the tax period, plus four more during a dispute or audit. You can delegate storage to your provider by contract, but the legal duty stays with you.
On location, be precise. Article 11 of Ministerial Decision No. 243 of 2025 says records are held “within the State,” yet the MoF Guidelines v1.1 treat that as a retrieval test: complete, readable records, produced promptly, wherever the servers sit. UAE hosting is the simplest answer to defend, but check your sector’s own residency rules too.
On format, the good answer is a bulk export in both raw PINT AE XML, which an audit of structured data needs, and readable PDF, which the commercial record needs. One format alone is a continuity risk.
11. What Do You Produce When the FTA Requests Records, How Fast, and Which ISO Certifications Do You Hold?
Never accept “our systems are secure.” Ask what the audit pack contains and how quickly it arrives. Providers must keep transaction logs with unique identifiers and transmission statuses, so a proper pack exists.
Then ask for certificates by number. Ministerial Decision No. 64 requires a valid International Organization for Standardization (ISO) ISO/IEC 27001 certificate for the provider’s product (Article 9) and ISO 22301 for business continuity (Article 6).
Ask for certificate numbers, expiry dates and scope. Ask, too, whether the ISO 22301 certificate is held today or pending, because the Decision allows three months after the financial year-end to obtain it. A provider without either is a finding waiting to happen. Defective invoices cost money as well.
12. If Your Accreditation Is Withdrawn, What Is the Migration Plan?
Accreditation lasts two years, and renewal must be filed at least 70 business days before expiry. Miss it, and the accreditation is cancelled and links to every business the provider represents are revoked (Article 18).
What happens to your invoicing the day that link is cut? The Ministry can also terminate for non-compliance or validated complaints, and the provider must tell you within five business days of its own notice (Article 19). Ask for the accreditation date, expiry date and renewal status. Then ask for a written migration plan covering data export, cut-over support and who pays.
A good answer puts the cost on the provider. A weak answer is “that won’t happen.”
What to Do in the Two Weeks After You Choose
Signing with an accredited service provider UAE regulators recognize isn’t the finish line, and the two dates do different jobs. 30 October 2026 is the appointment deadline only, set by Ministerial Decision No. 66 of 2026 for businesses with revenue of AED 50 million or more.
1 January 2027 is go-live. The nine weeks between them are for onboarding, integration, testing and training, so the system is running that morning rather than being configured that week. Below AED 50 million, the dates are 31 March 2027 and 1 July 2027.
In the first two weeks, name one owner for onboarding, start it through EmaraTax, the FTA’s portal, and agree how invoice data will reach the provider. Our registration steps guide covers the detail.
- By 30 October 2026: contract signed, appointment registered.
- November: onboarding and ERP integration.
- December: sandbox testing and a month-end dry run.
- 1 January 2027: live.
Sign on 29 October and you have barely nine weeks. Plan for it!
How ADEPTS Runs an Independent ASP Selection
Choosing a provider shouldn’t mean trusting the party selling it. With ADEPTS, you get:
- A shortlist verified against the MoF register
- The scorecard completed with your finance team
- SLA, penalty and exit clauses reviewed before you sign
- Sandbox testing and Value Added Tax (VAT) close checks
- Archive and audit-pack checks after go-live
The result is one accountant’s view of the whole decision, from the first register check to your first month-end close. See our e-invoicing services.
Conclusion
Twelve questions, four groups, one principle: verify before you trust. An FTA approved ASP earns the name on the MoF register, not in a brochure. Yes, the clock is tight, but a rushed signature costs more than a careful week. Any ASP e-invoicing UAE decision gets easier once answers are written down. You don’t need to be technical to run this test. You just need our 12 questions, a pen, and the discipline to record what each provider actually says. Take it into every vendor meeting. If you’d like a second pair of eyes, ADEPTS will score your shortlist with you.
Frequently Asked Questions
No. The MoF Guidelines route compliance through an ASP, and each business in scope must appoint exactly one for both sending and receiving. The Guidelines set out no direct route to the FTA, so appointment is your first step.
Each entity onboards separately, because each has its own Tax Identification Number (TIN) and Peppol identifier, including every VAT group member. Members may share an ASP or choose different ones. See why VAT group members need individual ASP connections.
Cabinet Decision No. 106 of 2025 imposes a penalty of AED 5,000 for each month or part of a month of delay. The deadline covers businesses with revenue of AED 50 million or more. Smaller businesses have until 31 March 2027.
Yes, but you can hold only one ASP at a time, so the cut-over needs planning. Disruption depends on the exit terms you agreed: archive export, handover dates and any parallel running. Settle these before signing, using Question 9 as your guide.
No. You may contract your ASP to store invoices, but the legal duty stays with you. Taxable Persons keep records for five years after the tax period, plus four more years during a dispute or audit.
There is no official price. Fees vary with volume, integration work and tier structure. The MoF only requires each provider to offer 100 free e-invoices a year. Get written quotes at your normal volume, double it, and your month-end peak.
Only if its vendor, or the partner delivering it, appears on the MoF accredited list. Otherwise the software connects to an ASP but can’t replace one. Check the accreditation number on the register, then confirm the integration is production-ready before relying on it.
No. An ASP exchanges e-invoices and reports tax data to the FTA. You still file your VAT return, though e-invoicing data is designed to pre-populate certain fields. Your tax agent or finance team remains responsible for filing.
The ASP must notify you and the FTA, then exchange and report all pending invoices once service resumes. You must also notify the FTA of a system failure on time, or face AED 1,000 for each day of delay.
No separate ASP setup applies. Everyone appoints from the same MoF list. What changes is invoice data: free zone transactions need beneficiary details. Check that your ERP captures them, and confirm zone-specific rules with your adviser.
References
- United Arab Emirates. Cabinet. Cabinet Decision No. 106 of 2025 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System. December 2025. PDF. https://mof.gov.ae/wp-content/uploads/2025/12/Cabinet-Decision-Violations-and-Penalties-eInvoicing-final-version-en-8.12.25.pdf.
- ———. “eInvoicing.” Accessed September 30, 2026. https://mof.gov.ae/en/about-us/initiatives/einvoicing/.
- ———. “eInvoicing Accredited Service Providers (ASPs).” Last updated September 30, 2026. https://mof.gov.ae/en/about-us/initiatives/einvoicing/einvoicing-accredited-service-providers-asps/.
- ———. Ministerial Decision No. 56 of 2026 Amending Certain Provisions of Ministerial Decision No. 64 of 2025. May 2026. PDF. Listed on the eInvoicing portal as Ministerial Resolution No. (56) of 2026. https://mof.gov.ae/wp-content/uploads/2026/05/Ministerial-Resolution-No.-56-of-2026-Amending-Certain-Provisions-of-Ministerial-Resolution-No.-64-of-2025-En-20260510.pdf.
- ———. Ministerial Decision No. 64 of 2025 on the Eligibility Criteria and Accreditation Procedure for Service Providers under the Electronic Invoicing System. 2025. PDF. https://mof.gov.ae/wp-content/uploads/2025/03/Ministerial_Decision_Eligibility_and_Accreditation_procedure_for_SPs_EN.pdf.
- ———. Ministerial Decision No. 66 of 2026 Amending Certain Provisions of Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System. May 2026. PDF. Listed on the eInvoicing portal as Ministerial Resolution No. (66) of 2026. https://mof.gov.ae/wp-content/uploads/2026/05/Ministerial-Resolution-No.-66-of-2026-Amending-Certain-Provisions-of-Ministerial-Resolution-No.-244-of-2025-Regarding-the-Implementation-of-the-Electronic-Invoicing-System-En-20260514.pdf.
- ———. UAE Electronic Invoicing Guidelines. Version 1.1. June 1, 2026. PDF. https://mof.gov.ae/wp-content/uploads/2026/06/UAE-Electronic-Invoicing-Guidelines_V-1.1-01June2026.pdf.
Related Articles
