Dhruva urges UAE firms to focus on data sovereignty in e-Invoicing transition

The 2026 mandate is an opportunity for businesses to align compliance with stronger data governance standards

With the UAE’s mandatory eInvoicing framework set to launch in 2026, Dhruva urges taxpayers to move beyond data residency considerations and focus on the critical issue of data sovereignty when selecting accredited service providers (ASPs). When adopting any cloud solution, it’s crucial to take the UAE National Cloud Security Policy into consideration, which provides a comprehensive checklist for cloud customers. This policy details necessary arrangements with cloud service providers, outlines contract requirements and sets cloud security requirements and enforcement measures.Dhruva is a leading tax advisory firm specializing in VAT, corporate tax, transfer pricing, and international taxation in the Middle East.

The eInvoicing rollout, based on the OpenPeppol five-corner model, will route all business-to-business (B2B) and business-to-government (B2G) invoices through ASPs that validate, exchange, and report tax-relevant data directly to the Federal Tax Authority (FTA). This shift makes the question of where data lives and who ultimately controls it – a matter of legal, operational, and financial consequence.

Commenting on the development, Nimish Goel, Partner and Head of GCC, Dhruva Consultants, said: “Businesses cannot afford to mix data residency with sovereignty. Hosting tax data within UAE data centres is necessary, but it does not, by itself, guarantee compliance or protection. True sovereignty means that encryption keys, administrative controls, and audit logs remain fully under UAE jurisdiction and cannot be accessed by foreign authorities. For taxpayers, this distinction is not technical—it is a fundamental risk-management decision.”

Dhruva highlights that this distinction is becoming urgent for three reasons. First, the UAE has enacted a robust Federal Data Protection Law (PDPL) and sector-specific rules that demand explicit safeguards on cross-border data flows. Second, with eInvoicing deadlines approaching, taxpayers must evaluate how each provider’s hosting model aligns with UAE data hosting requirements, sovereignty and National Cloud Security Policy laws. Finally, the operational reality is that migrating data and applications between clouds is not seamless. Factors such as data gravity, proprietary platforms, and audit trail integrity make switching providers slow, risky, and expensive.

“E-invoicing will not only redefine how businesses transact with government authorities, but also how they safeguard their most sensitive tax and financial records,” Goel added. “Companies need to recognise that the choice of ASP is a long-term strategic decision. The location of the cloud operator, the jurisdiction under which they fall, and the location of their control plane and encryption keys all impact compliance and data security far more than the physical location of the server rack.”

Dhruva advises taxpayers to approach ASP selection with a structured due-diligence process aligned with the policy for cloud customers in the UAE. This policy covers key domains such as governance, data location and sovereignty, interoperability, security incident and access management, data confidentiality, architecture and infrastructure companies should ensure that all storage, backups, and logs are held within UAE borders, that operational control and key management remain in UAE jurisdiction, and that providers comply with the UAE’s Peppol interoperability standard. Audit logs should be immutable, recovery sites must be located in the country, and exit strategies need to be documented and tested, with transparency on egress costs.

“Taxpayers cannot treat this as a simple IT procurement,” Goel emphasized. “It is a compliance and sovereignty choice that will determine their risk exposure for years to come. The time to ask these questions is now—before companies find themselves locked into providers that may not meet their future regulatory and operational needs.”