1What is a Peppol Access Point?
The UAE Federal Tax Authority (FTA) is moving all B2B and B2G invoicing onto Peppol — an international network for exchanging structured electronic documents. Businesses do not connect to Peppol directly; they connect through an Accredited Service Provider (ASP) that operates a certified Access Point (AP).
A certified gateway that sends and receives Peppol documents on your behalf, guaranteeing format, routing, and delivery.
The Accredited Service Provider that runs the AP. In the UAE, ASPs are accredited by the Ministry of Finance under
Ministerial Decision No. 64 of 2025.The Service Metadata Publisher — a registry that maps a company's Peppol ID (its TRN-based participant ID) to the AP that serves it.
FinSanad's role is Corner 1 (the supplier's software): it produces a compliant structured invoice, hands it to an ASP's Access Point over an API, and stores the returned identifiers and status. The ASP handles the network transport and the real-time tax report to the FTA.
2The UAE 5-Corner (CTC) Model
Classic Peppol is a 4-corner exchange (supplier → supplier's AP → buyer's AP → buyer). The UAE adds a 5th corner: the invoice's tax data is reported to the FTA at the same time it is delivered to the buyer — a Continuous Transaction Control (CTC) model.
3FinSanad → ASP Integration Architecture
FinSanad already generates signed UBL 2.1 XML per invoice (see the E-Invoicing guide). Peppol readiness adds a thin outbound integration layer to an ASP:
| Step | What happens | Where in FinSanad |
|---|---|---|
| 1. Generate | Produce the structured invoice in UBL 2.1, aligned to the PINT AE data dictionary (mandatory fields, TRN, tax categories). | /api/v1/einvoice/{id}/generate (implemented) |
| 2. Validate | Schematron / PINT AE validation of every mandatory field before transmission. | Validation service (to add) |
| 3. Transmit | POST the document to the ASP's Access Point API (REST) or SFTP; receive a Peppol message ID. | ASP connector (to add — per chosen ASP) |
| 4. Acknowledge | Store the ASP's delivery status + the FTA Tax Data Submission (TDS) reference against the invoice. | Extend e_invoices table |
| 5. Archive | Retain the XML, signature, hash and acknowledgements for 7 years. | e_invoices retention (implemented) |
4FinSanad Readiness Map
How FinSanad's current capabilities map to the UAE e-invoicing / Peppol requirements:
| Requirement | Status | Detail |
|---|---|---|
| Structured invoice generation (UBL 2.1 XML) | Implemented | Per-invoice UBL 2.1 with type codes 380/381/383, TRN party IDs, per-line tax categories. |
| Supplier TRN & VAT registration capture | Implemented | 15-digit TRN validated; company settings on the tenant. |
| VAT calculation (standard / zero-rated / exempt) | Implemented | 5% engine + VAT201 return generation. |
| Digital signature & QR code | Implemented | RSA-2048 / SHA-256 signature over the XML; QR payload. (Self-signed cert — swap for CA cert for production.) |
| Sequential, unique invoice numbering | Implemented | Per-tenant sequential numbers (INV-YYYY-#####). |
| 7-year electronic archival | Implemented | e_invoices stores XML + hash + signature + fingerprint. |
| REST API for integration | Implemented | /api/v1/… tenant-scoped API. |
| Data security & encryption | Implemented | TLS 1.3, Argon2 password hashing, RBAC, tenant isolation. |
| PINT AE data-dictionary alignment | Partial | UBL 2.1 base present; PINT AE mandatory-field profile + Schematron validation to be finalised. |
| Peppol participant registration (TRN-based ID) | Needs ASP | Registered through the chosen ASP / SMP. |
| Access Point connectivity | Needs ASP | Outbound connector to the ASP AP (REST/SFTP). |
| Tax Data Submission (TDS) to FTA | Needs ASP | Delivered via the 5-corner model by the supplier's ASP. |
| CA-issued signing certificate | Config | Replace the self-signed cert with an accredited CA certificate. |
5UAE E-Invoicing Compliance Checklist
A 25-point readiness assessment across five categories (adapted from the UAE InvoiceNow compliance checklist). Tick items as you complete them — your progress is saved in this browser.
6UAE Rollout Timeline
7References
- UAE InvoiceNow compliance checklist — invoicenow.biz/ae/en/compliance-checklist
- Ministry of Finance — ASP accreditation,
Ministerial Decision No. 64 of 2025 - Federal Tax Authority (FTA) — e-invoicing programme & VAT — tax.gov.ae
- Peppol — International (PINT) & PINT AE billing specifications; UBL 2.1 (ISO/IEC 19845)
- FinSanad — E-Invoicing implementation guide · UAE development plan