UAE E-Invoicing Mandate 2026: Timeline & Compliance Guide

The UAE's e-invoicing mandate requires any person doing business in the country, whether or not it is registered for VAT, to issue and receive its B2B and B2G invoices as structured PINT AE XML, carrying the 51 fields the Ministry of Finance's Electronic Invoice Mandatory Fields specification lists for a tax invoice. Invoices are exchanged through a Ministry-accredited service provider (ASP), and the tax data is reported to the Federal Tax Authority (FTA). Who and what is in scope is set by Ministerial Decision No. 243 of 2025, as amended by Ministerial Decision No. 197 of 2026. The phased dates are set by Ministerial Decision No. 244 of 2025, as amended by Ministerial Decision No. 66 of 2026.

Businesses with revenue of AED 50 million or more must appoint an ASP by 30 October 2026 and must go live by 1 January 2027. All other businesses go live by 1 July 2027 and government entities by 1 October 2027, both appointing an ASP by 31 March 2027.

The system is already running. A pilot with an invited group of taxpayers and voluntary adoption by any business both opened on 1 July 2026, and the five-corner exchange is operating. The Ministry's implementation guidance is the UAE Electronic Invoicing Guidelines (version 1.1, 1 June 2026). Its e-invoicing portal describes itself as the only official source of information on the programme, and the decisions behind it were amended several times during 2026, so dates and rules in older guidance are worth checking against it.

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UAE E-Invoicing Timeline: Which Phase Applies to Your Business

The rollout is phased by size, and each category has two dates: one to appoint an ASP and a later one to go live. Both come from Article 5 of MD 244 as amended by MD 66 of 2026, which moved the first appointment deadline from 31 July to 30 October 2026 and left the go-live dates where they were.

Some published guidance, including version 1.1 of the Ministry's own Guidelines, still gives 31 July 2026 as the first appointment deadline. It predates MD 66.

The AED 50 million threshold is measured on revenue, which MD 244 defines as the gross income earned in the most recent accounting period, based on the financial statements (or other documentation the FTA accepts where there are none). A newly established company uses its projected revenue for the current financial year, according to the Ministry's October 2026 programme presentation. It is not profit or taxable supplies. If your business sits near the threshold and you are uncertain which category applies, prepare for January 2027. Missing the earlier date carries greater risk than being ready ahead of schedule.

"Mandatory" means operational readiness, not just a signed contract. By your go-live date, your business must be issuing and receiving invoices in PINT AE through its ASP.

The pilot and voluntary adoption are two different things. The pilot, which started on 1 July 2026, runs with a Taxpayer Working Group: the Ministry notifies the businesses it wants to include, and they join only with their written agreement (MD 244, Article 3). Voluntary adoption is open to anyone: under Article 4, any person may implement the system voluntarily from 1 July 2026. The Ministry's October 2026 presentation reports the five-corner model live for the pilot phase, with businesses able to choose and onboard with an ASP through EmaraTax and start exchanging e-invoices straight away.

Starting voluntarily carries no penalty risk: penalties apply only from the date a business is required to implement, so an early adopter is not fined while it irons out problems (Guidelines, section 8.2). There is a VAT point to check first. Once a registrant is required to issue its tax invoices as e-invoices, Article 59(16) of the VAT Executive Regulation disapplies several tax invoice provisions, including those that allow simplified tax invoices. Whether an early adopter already counts as required in that sense is worth confirming with your tax adviser before you switch.

For financial controllers planning resource allocation: work backward from your go-live date. ASP onboarding, internal system adjustments, and staff training typically require three to six months, which is longer than the gap between some appointment deadlines and go-live, so preparation that waits for a signed ASP contract may not fit. For teams comparing phased mandates across regions, Nigeria's 2026 Electronic Fiscal System rollout shows a different control design, with B2B and B2G invoice clearance before buyer delivery and 24-hour reporting for B2C transactions.

Who Is in Scope, and What Is Excluded

The mandate is not tied to VAT registration. MD 243 applies to any person conducting business in the UAE, in respect of every business transaction, unless the person or the transaction is excluded (Article 3). The Guidelines add that this holds whether or not the person is established in the UAE, and a business that is not registered for VAT obtains a tax identification number (TIN) from the FTA in order to take part.

• B2B and B2G transactions are in scope, and so are government-to-government ones.
• B2C transactions are out, and so is a business that sells only to consumers, until the Minister issues a decision bringing them in (MD 244, Article 5(2)). No B2C date has been published.
• Receiving is an obligation, not just sending. The recipient must process the e-invoices it receives through the system, and supplier and recipient both report to the FTA (MD 243, Articles 6(3) and 6(6)).

From 1 October 2026, MD 243 Article 4(1), as replaced by MD 197, excludes these transactions:

• Sovereign activities of government entities that do not compete with the private sector
• International passenger air transport where an electronic ticket is issued, and airline ancillary services where an Electronic Miscellaneous Document is issued
• International air cargo where an Airway Bill is issued, for 24 months from the date the system becomes effective
• Financial services that are exempt from VAT or zero-rated under Article 42 of the VAT Executive Regulation
• Transactions between members of the same VAT tax group, for 24 months starting 1 January 2027

The VAT-group exclusion is the one most often misread. It was added by MD 197 and covers only persons registered with the FTA as a single taxable person under the VAT law. Companies in the same corporate group that are not in one VAT group get no relief, so their intercompany charges, management fees and cost recharges follow the normal rules. Within a VAT group, the exclusion removes the exchange and reporting requirement for transactions between members for two years from 1 January 2027; it does not take the group's dealings with outside customers and suppliers out of scope.

The Guidelines (section 6.3.1) also treat an investment holding company that earns only passive income as outside scope, unless it recharges costs to other entities. An excluded transaction can still be e-invoiced voluntarily, in which case every rule applies except the penalties (MD 243, Article 4(3)).

PINT AE Format: From PDF Invoices to Structured XML

If your business currently sends invoices as PDF attachments or delivers paper copies, the UAE's e-invoicing mandate introduces a fundamentally different approach to how invoice data moves between parties. At the centre of this change is the PINT AE format, the UAE's standard for electronic invoices.

PINT AE is the UAE specialisation of Peppol International (PINT), a family of Peppol e-invoice specifications. The Ministry of Finance maintains it as the UAE Peppol Authority, and the current release is PINT AE Billing 1.0.4, released on 2 June 2026. It is an XML format built on Universal Business Language (UBL), with UAE-specific elements for VAT treatment, tax registration numbers and transaction types. Rather than a document you read visually, a PINT AE invoice is a file where every data element (seller name, invoice number, line items, tax amounts, currency codes) occupies a precisely defined position in a standardised schema. For a broader look at how electronic invoicing works globally, the UAE's adoption of Peppol places it within an international framework already used across Europe, Singapore, and Australia, with South Africa's planned e-invoicing mandate set to extend this structured invoicing trend into the African continent.

Two details differ from what many teams expect. A UAE e-invoice carries no QR code or barcode (Guidelines, section 5.3). And each participant's Peppol identifier is the scheme code 0235 followed by its 10-digit TIN.

Why structured XML replaces PDF

The distinction between a PDF invoice and a PINT AE XML invoice is not cosmetic. A PDF is a visual representation of an invoice designed for human reading. When a finance team receives a PDF, someone (or some software using OCR) must interpret its layout, locate the relevant fields, and re-enter that data into an accounting system. Different vendors format their PDFs differently, which makes automated interpretation unreliable and manual entry error-prone.

A PINT AE XML file eliminates this ambiguity entirely. Every field is machine-readable from the moment it is created. The seller's tax registration number, each line item's unit price, the applicable VAT rate: all sit in defined data elements that any compliant system can read without interpretation. This enables automated validation at the point of transmission, not days or weeks later during reconciliation.

The five-corner model: how an invoice moves

The Ministry calls the system a Decentralized Continuous Transaction Control and Exchange (DCTCE) model, with five corners (Guidelines, section 3):

1. Corner 1, the supplier, sends its invoice data to its ASP in a format they agree.
2. Corner 2, the supplier's ASP, validates the data, converts it to PINT AE XML and sends it over Peppol to the buyer's ASP. In parallel, it reports a Tax Data Document to the FTA.
3. Corner 3, the buyer's ASP, validates the invoice and sends a status response back to the supplier's ASP. If validation succeeds, it delivers the invoice and reports its own Tax Data Document to the FTA.
4. Corner 4, the buyer, receives the invoice as structured data.
5. Corner 5, the FTA, receives the tax data on its central data platform and sends status responses back through the ASPs.

Two consequences follow. This is reporting, not clearance: the FTA does not approve an invoice before the buyer receives it, which is the main difference from Saudi Arabia's model (see the GCC notes below). And what reaches the FTA is tax data from both sides of the transaction, in near real time, rather than a copy of the invoice document. If the buyer's ASP fails an invoice in validation, it sends a negative status to the supplier's ASP and to the FTA, and no buyer-side tax data is reported.

The supplier must issue and transmit each e-invoice within 14 business days of the transaction (MD 243, Article 6(5), as amended by MD 197), and a VAT registrant must also meet the tax invoice deadline in the VAT law.

What changes in daily operations

For finance teams, the more pressing question is what actually changes in daily operations. The shift affects both sending and receiving invoices.

Outbound invoices can no longer be sent as email attachments or printed and mailed as the method of regulatory compliance. Invoice data must be transmitted through your ASP in PINT AE format. Your accounting software still generates the invoice, but instead of exporting a PDF and emailing it, the data flows to your ASP for validation, conversion, and delivery through the Peppol network.

Inbound invoices arrive as structured data through your ASP rather than as email attachments or postal deliveries. This means your accounts payable workflow shifts from opening PDFs and keying in data to receiving pre-structured records that can feed directly into your ERP or accounting system.

The important nuance: this transition does not necessarily mean replacing your existing accounting software. ERP and accounting platforms connect to accredited service providers through integrations, or the ASP offers connectors for common systems. The change sits in the transmission layer, not in how your team creates or records invoices internally. Your staff will still draft invoices in the same interface they use today. The difference is what happens after that invoice is finalised: instead of a PDF leaving your outbox, structured data leaves through your ASP.

Mandatory Data Fields in a UAE E-Invoice

The shift from paper or PDF invoices to structured e-invoicing under the UAE's mandate is a data standardisation exercise at its core. The question for most finance teams is not whether they capture the right information, but whether their systems can output that information in the precise machine-readable structure PINT AE requires.

The Ministry's Mandatory Fields document (version 1.0, 23 February 2026) lists 51 mandatory fields for an electronic tax invoice and 49 for a commercial invoice, the electronic invoice used for supplies that are not taxable and by suppliers that are not VAT-registered. For accountants and financial controllers already familiar with UAE VAT invoice mandatory fields, most of these data points are not new. The change is in how they must be delivered: as discrete, machine-readable XML elements rather than free-text entries on a PDF, plus a few items a PDF never needed.

Below is a practical breakdown of the 51 tax invoice fields, grouped by business function rather than schema order.

Invoice Details

Every e-invoice carries an invoice number, issue date, invoice type code, and currency code, plus items many current invoices lack: an invoice transaction type code, a payment due date, a payment means code, and the business process and specification identifiers that tell the network which PINT AE profile applies. The transaction type code is a string of eight flags marking whether the invoice involves a free zone, a deemed supply, the margin scheme, a summary invoice, a continuous supply, disclosed agent billing, an e-commerce supply, or an export. Those flags are part of the invoice's VAT treatment and need the same care as the tax category.

Seller Information

The seller block holds the legal name, the seller's Peppol electronic address (its TIN) with the fixed scheme identifier 0235, a legal registration identifier and its type (such as a trade licence, Emirates ID, or passport), the TRN with its tax scheme code, and a structured address: street line, city, emirate, and the country code AE. Contact details are not among the mandatory fields.

Buyer Information

Buyer details mirror the seller's: name, Peppol electronic address and identifier, TRN with tax scheme code, and a structured address. The buyer's TRN is not mandatory on commercial invoices or for out-of-scope and exempt transactions.

Document Totals

Five summary amounts are mandatory at the document level:

• Sum of invoice line net amounts
• Invoice total amount without tax
• Invoice total tax amount
• Invoice total amount with tax
• Amount due for payment, after any prepayments or rounding

These figures must reconcile precisely. The ASPs validate every invoice against the PINT AE business rules before delivery, so an invoice whose arithmetic does not hold fails at the network rather than surfacing later in a VAT audit.

Tax Breakdown

For each VAT category on the invoice, the tax breakdown gives the taxable amount, tax amount, category code, and rate. The Guidelines (section 10.5) list six tax categories:

• Standard rate (5%) for most domestic supplies of goods and services
• Zero rated, for example qualifying exports of goods and services and certain healthcare, education and real estate supplies
• Exempt, for example certain financial services, residential property, and bare land
• Outside the scope of VAT
• Reverse charge, for domestic supplies between registrants of electronic devices, precious metals and stones, crude and refined oil, natural gas, pure hydrocarbons and metal scrap; the invoice shows no VAT and must state the reason and the type of goods
• Margin scheme, for eligible second-hand goods, antiques, and collectables, where the VAT amount shown is zero and the margin scheme flag is set

Imports of goods and services under the reverse charge are not subject to e-invoicing requirements (Guidelines, section 10.5.1). Applying the wrong category is more than a formatting error: the tax data the FTA receives carries that treatment, so a wrong code puts a wrong VAT position on record.

Line-Level Data

Each invoice line carries 13 fields: a line identifier, quantity and unit of measure, the line net amount, the item net price, gross price and price base quantity, the item's tax category and rate, the item name and description, and two amounts in AED, the line VAT amount and the line amount, which are required in dirhams whatever currency the invoice is issued in. Item classification (HSN) codes are optional for now; the Ministry says the timeline for making them mandatory will be announced later.

Document Types and References

The Guidelines (section 10.1) recognise six document categories: the electronic tax invoice, electronic tax credit note, commercial invoice, electronic credit note, and self-billed versions of the tax invoice and tax credit note. There is no debit note category. An electronic credit note is mandatory in four cases: a cancelled supply, a reduction in the consideration, consideration returned, and an administrative or numerical error (MD 243, Article 6(2)). It carries a reference to the invoice it corrects. A purchase order number is optional.

The practical takeaway is straightforward: if your current invoicing system already captures the data required under UAE VAT rules, much of the underlying information is the same. What changes is the packaging. Each field must be mapped to its corresponding PINT AE XML element, validated against the PINT AE business rules, and transmitted through an accredited service provider. A useful first step is exporting a sample invoice from your current system and comparing each field against the 51 required elements. This mapping exercise reveals what your system already captures and where gaps need to be closed before your compliance date.

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How to Appoint an Accredited Service Provider

Under the five-corner model, every business in scope reaches the network through an Accredited Service Provider (ASP), which validates and converts its invoices, exchanges them over Peppol, and reports the tax data to the FTA. You appoint exactly one ASP, for both sending and receiving (Guidelines, section 6.1). Each member of a VAT group onboards under its own TIN and may use a different ASP from the other members.

What the Ministry Requires of an ASP

Accreditation is granted by the Ministry of Finance under Ministerial Decision No. 168 of 2026, in force from 1 October 2026, which replaced the earlier rules in MD 64 of 2025. Among its conditions, a provider must:

• Be an active Peppol-certified service provider that has passed the OpenPeppol conformance tests
• Be a company incorporated in the UAE, or a foreign entity licensed to do business here, with paid-up capital of at least AED 50,000 and audited financial statements
• Deliver the service through a product that has been in operation for at least two years
• Be registered for corporate tax and VAT
• Hold ISO/IEC 27001 certification for the product and ISO 22301 for business continuity
• Carry professional indemnity insurance of at least AED 2.5 million, and crime and cyber fraud cover of at least AED 5 million each
• Pass Peppol interoperability testing and FTA tax data reporting tests before going live

Accreditation lasts two years and must then be renewed. MD 168 also abolished the separate pre-approval stage: providers pre-approved under the old rules had 30 days from 1 October 2026 to complete full accreditation. A provider may offer e-invoicing services in the UAE only once accredited, so using an unaccredited one would leave your business non-compliant.

The Accredited Provider List and Onboarding

The Ministry publishes the list of accredited ASPs with their accreditation numbers and contact details. On 20 October 2026 it named 69 accredited providers, plus three pre-approved providers then in final assessment. Before signing any agreement with a provider, verify that it appears on that list.

Onboarding starts on the FTA's side: in EmaraTax, the business opens the e-invoicing tile, chooses its ASP, and proceeds to that provider to complete the connection. Keep your EmaraTax registration data current, because when it changes you must tell your ASP in writing within five business days of the FTA confirming the change (MD 243, Article 5(3)). Teams comparing Gulf provider structures should also review Oman's Fawtara rollout and service-provider rules, where VAT groups must align on one provider and some businesses may be able to pursue self-provider accreditation.

Evaluating an ASP Beyond the Minimum Requirements

Meeting the Ministry's accreditation criteria is necessary but not sufficient for choosing the right provider. When comparing accredited ASPs, assess them against your specific operational needs:

• ERP and accounting software integration. The ASP should connect with your existing systems (SAP, Oracle, Tally, QuickBooks, Xero, or whichever platform you use) without requiring a full technology overhaul. Ask for documentation on supported integrations and implementation timelines.
• Invoice volume capacity. If your business processes thousands of invoices monthly, confirm the ASP can handle that throughput without degradation during peak periods such as month-end or VAT filing windows.
• Data hosting and security terms. There is no general rule that e-invoice data must be held in the UAE, but the Ministry's checklist asks whether you have agreed data hosting and security requirements with your ASP, and an accredited product must meet any hosting or residency rules that apply to you as a customer, such as those of a regulated sector. Agree these in the contract.
• B2B and B2G support. If your business invoices government entities, confirm the ASP supports business-to-government (B2G) flows in addition to standard B2B ones.
• Pricing transparency. Every accredited ASP must give each customer 100 free e-invoice exchange and reporting services a year (MD 168, Article 9(4)). Beyond that, fee structures vary. Some charge per transaction, others use monthly tiers, and some bundle onboarding costs into the contract. Request a detailed pricing breakdown before committing, and watch for hidden fees around support, upgrades, or exceeding volume thresholds.

Start the Process Early

Do not leave ASP selection until your appointment deadline. Integration between your financial systems and the ASP's platform requires configuration, testing, and staff training, and for large businesses the gap between the 30 October 2026 appointment date and go-live on 1 January 2027 is about two months. Businesses below the threshold and government entities have until 31 March 2027 to appoint. Choosing and contracting several months ahead of that date allows for test transmissions, compatibility checks, and the inevitable back-and-forth on integration details that cannot be compressed into the final weeks before go-live.

Free Zones, Exports and Cross-Border Invoicing

Two scenarios consistently trip up finance teams preparing for UAE e-invoicing compliance: free zone obligations and invoices that cross the border. Each carries specific rules that generic compliance summaries tend to gloss over.

Free Zone and Designated Zone Entities

A common misconception is that free zone businesses operate on a separate compliance timeline. They do not. The mandate applies to any person doing business in the UAE, whether on the mainland, in a free zone, or in a designated zone, on the same revenue-based schedule. The PINT AE format requirements, ASP obligations, and mandatory data fields apply identically regardless of where the business is established.

What a free zone changes is the content of the invoice. Where a free zone entity is the supplier, buyer, or beneficiary, or the supply takes place in or from a free zone, the e-invoice sets the free zone flag in its transaction type code and carries the beneficiary's details in addition to the customer's (Guidelines, section 10.4).

For businesses in designated zones (which are treated as outside the UAE for VAT purposes in certain transaction categories), the e-invoice must carry the VAT treatment the transaction actually has, so your ASP configuration needs to handle designated zone scenarios such as zero-rated supplies. If your business operates across both designated zones and the mainland, a deeper understanding of free zone invoicing and VAT treatment in the UAE is essential for getting your e-invoicing setup right.

Cross-Border Invoice Treatment

The mandate reaches persons whether or not they are established in the UAE: a non-resident that has to issue UAE tax invoices issues them as e-invoices (Guidelines, section 6.3.3). The cross-border cases work as follows.

• Exports: The tax invoice for an export is issued as an e-invoice with the export flag set, and the same invoice may be provided to Customs. If the foreign buyer has no Peppol ID, the supplier must address the invoice to the predefined endpoint 0235:9900000099 (Guidelines, section 10.4).
• Foreign buyers on Peppol: Because the UAE network is Peppol, a foreign buyer with a Peppol ID can be reached over the same network; the Ministry describes Peppol as connecting UAE businesses with businesses outside the country.
• Imports: Imports of goods and services accounted for under the reverse charge are not subject to e-invoicing requirements (Guidelines, section 10.5.1).
• Domestic buyers not yet onboarded: While the phases roll out, a supplier on the system may invoice a UAE buyer who is not. The supplier then addresses the e-invoice to the predefined endpoint 0235:9900000098 and also gives the buyer a regular tax invoice, such as a PDF (Guidelines, section 10.2.2).
• GCC counterparts: Saudi Arabia's ZATCA e-invoicing clearance model and FATOORAH requirements are already fully operational, with their own VAT invoice mandatory field requirements that differ from the UAE's PINT AE schema. Saudi B2B invoices are cleared by the tax authority before the buyer receives them, where UAE invoices are reported in parallel with delivery; a side-by-side breakdown of the Saudi and UAE e-invoicing systems covers the key technical and regulatory divergences. UAE contractors billing into Saudi giga projects, for instance, need to reconcile PINT AE obligations on the UAE side with Saudi Arabia's construction invoicing and FATOORAH requirements on the recipient side. Other GCC states are at varying stages of their own mandates, so treat each GCC counterpart on a case-by-case basis depending on their system readiness.

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Archiving, Retention, and What Happens When Systems Fail

Issuing e-invoices is only half the compliance equation. The other half is keeping them, with their associated data, retrievable for years after transmission.

Retention Periods

The retention period comes from the Tax Procedures rules, which the Guidelines (section 5.4) set out as:

• 5 years after the end of the tax period the records relate to, for a taxable person
• 5 years from the end of the calendar year in which the document was created, for any other person
• 7 years from the end of the calendar year of creation for real estate records
• An additional 4 years where a dispute, an audit, or a notified audit is under way

The obligation covers the e-invoices, electronic credit notes, and the associated data that supports each invoice's integrity, authenticity, and auditability. Corporate tax has its own record-keeping rules, covered in UAE corporate tax record-keeping; set one retention policy for the e-invoice archive that satisfies whichever period is longer for your records.

Where and How Records Are Kept

There is no requirement to store e-invoice data in the UAE. The original MD 243 said records should be kept "within the State", but the Ministry's Guidelines already read that as a duty to retrieve and provide the records when the FTA asks, wherever the servers sit, and MD 197 deleted the words from 1 October 2026. The rule now is to retain the e-invoices, credit notes, and associated data for the Tax Procedures period and to be able to produce them to the FTA on request.

If your ASP stores invoices for you under contract, the legal obligation stays with your business (Guidelines, Appendix 4). Keep your own retrievable archive, or set out in the contract how you get the data back, including if you change provider.

The Guidelines ask for records held in an electronic system that preserves their integrity and ensures secure retention, retrievable in a complete and readable form. They do not prescribe a technology. A document management or archiving system with access controls and write-once storage is one practical way to meet that standard; a shared folder of XML files makes it harder to show.

When Systems Fail

Until 30 September 2026, MD 243 required both the issuer and the recipient to notify the FTA of a system failure within two business days. MD 197 repealed that article, and the definition of system failure, from 1 October 2026, so there is no longer a statutory notification duty. The Guidelines' operating expectation remains: if service is disrupted, your ASP tells the FTA, and once service resumes it exchanges and reports all pending e-invoices.

Nothing in the decisions suspends the 14-business-day window for issuing and transmitting each e-invoice during an outage. Your contract with the ASP should say how it will tell you about a disruption and how the backlog is cleared, and your own process should make sure invoices raised while the connection is down are queued, not lost.

Penalties for Non-Compliance with UAE E-Invoicing

The Ministry's October 2026 programme presentation lists Cabinet Decision No. 173 of 2026 as the decision on e-invoicing penalties, replacing Cabinet Decision No. 106 of 2025. As of 21 October 2026 the text of No. 173 had not been posted on the Ministry's e-invoicing portal, which still links only No. 106, so the amounts in the new decision cannot yet be confirmed. Check the portal before relying on any figure, including those below.

The schedule in No. 106, which the new decision replaces, shows the shape of the regime:

The caps matter more than the per-document rate. Under the three capped rows of this schedule, a business that had not implemented the system at all faced at most AED 5,000 a month for non-implementation, AED 5,000 for its untransmitted invoices, and AED 5,000 for its untransmitted credit notes: AED 15,000 a month, a figure that did not grow with invoice volume.

Two points come from the Ministry's Guidelines rather than the penalty decision. Penalties apply only from each business's mandatory date, so voluntary early adopters are not fined (section 8.2). And the ordinary VAT penalties under Cabinet Decision No. 40 of 2017 continue to apply to failures in the tax invoice itself (Guidelines, section 11.1).