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Guide

UAE e-invoicing penalties: what the Cabinet Decision says

Last verified 14 October 2026 against the linked decisions.

The penalties are set by Cabinet Decision No. 106 of 2025, published on the Ministry of Finance site. There are three that matter to a small business:

Source: Cabinet Decision No. 106 of 2025, annexed table. Verified 14 October 2026.

Who they apply to

Any person who must use the system and does not, from their mandatory dates. For a business under AED 50 million that means from 31 March 2027 for the provider appointment, and from the go-live date for invoices. Does not apply to persons who use the system voluntarily, per Article 2(2) of the same decision.

The first penalty is the one to avoid

Failing to appoint a provider on time is charged by the month, or any part of a month, for as long as the failure lasts. It does not depend on how many invoices you issue. A freelancer with three invoices a month and a trading company with three thousand face the same monthly amount for the same delay. Appointing a provider is a form and an agreement; it is the cheapest penalty to avoid.

Late invoices and the monthly cap

Once you are live, each e-invoice or e-credit note not issued and transmitted on time carries a per-document amount, up to a monthly cap. "On time" is defined elsewhere:

Issuance window
Within 14 days of the date of the business transaction, or within the VAT law timeline for VAT registrants Source: Ministerial Decision No. 243 of 2025, Article 6(4) and 6(5). Verified 14 October 2026.

The cap is per calendar month. A backlog cleared in one month is capped once; a backlog that drifts across month ends is capped in each.

Notifications

Two smaller duties carry a daily amount: telling the Federal Tax Authority about a system failure within the set time, and telling your provider when your registered details change. Both are easy to miss because nothing visible happens when you forget. Put them in whoever handles your tax registration's checklist.

If you have already missed the appointment date

  1. Appoint a provider now. Every month, or part of one, adds to the amount, so the delay itself is the cost.
  2. Keep the agreement date. It is the evidence that the failure ended.
  3. Ask a registered tax agent about the penalty position before paying or disputing anything. The decision sets amounts; it does not describe reductions or waivers.

Read the decision

The whole decision is three pages, and the penalties are in a table on the last one: Cabinet Decision No. 106 of 2025 (PDF). The scope and obligations it enforces are in Ministerial Decision No. 243 of 2025.

Common questions

Is there a penalty for not being registered for VAT?

Not under this decision. Scope does not depend on VAT registration. The scope article applies to any person conducting business in the UAE and sets no VAT registration condition. VAT registration has its own rules and penalties under the VAT law, which are separate from e-invoicing.

Do penalties apply during the pilot or to voluntary users?

Does not apply to persons who use the system voluntarily, per Article 2(2) of the same decision. If you adopt early by choice before your mandatory date, the penalties decision does not apply to you for that period.

Can a penalty be appealed?

The penalties decision we cite sets the amounts and does not describe an appeal route. Objections to administrative penalties generally follow the Tax Procedures Law. Ask a registered tax agent before relying on any route.

How is the monthly cap on late invoices applied?

The per-invoice amount is charged for each late e-invoice or e-credit note, and the total for a calendar month is capped at the stated maximum. The cap is per month, so a backlog that runs across two months is capped twice.

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This is general information, not tax or legal advice. Sources are linked next to each fact. Methodology.