The new Cabinet Decision replaces Cabinet Decision No. 106 of 2025. The deadlines for appointing an accredited provider are unchanged. The official text, with its number and effective date, has not yet been reviewed: the amounts come from press reports.
What happened
On 30 October 2026 the Ministry of Finance (MoF) announced on its website a new Cabinet Decision updating the administrative penalties linked to the e-invoicing system, replacing Cabinet Decision No. 106 of 2025. That much is confirmed by the official source. The amounts below come from Gulf News, which cites the Emirates News Agency (WAM): the MoF detail page has not been read in full, and the number of the new decision and its effective date do not yet appear in the sources consulted.
What changes in practice
According to the press, the regime becomes lighter and more predictable. First violation: AED 5,000 (about USD 1,360). A further AED 5,000 for each month, or part of a month, in which the violation continues. The total is capped at AED 50,000 (about USD 13,600) over 12 consecutive months. The penalty for failing to report a fault in the issuer's own system is removed. Where the same person is both the issuer and the recipient of an invoice, a single penalty applies. All of this should be treated as provisional until the official text has been read.
Who it applies to
All UAE businesses that will be required to issue electronic invoices. Businesses with annual revenue of AED 50 million or more (about USD 13.6 million) were already required to appoint an Accredited Service Provider (ASP), the provider accredited to transmit e-invoices, by 30 October 2026, and go live on 1 January 2027. Other VAT-registered businesses must appoint an ASP by 31 March 2027 and go live on 1 July 2027.
The exposure
A cap makes the penalty calculable; it does not make the underlying problem smaller. The dates have not been changed, and a PDF or Word invoice sent by email is not a valid electronic invoice: a structured format transmitted through an ASP is required. A business with revenue of AED 50 million or more, including the revenue of its group entities, that did not appoint an ASP by 30 October is already late. The operational risk, being unable to invoice customers, outweighs the financial penalty.
What to do now
1) Obtain the text of the decision from the MoF website, with its number and effective date, before treating the amounts as final. 2) Check revenue, including group entities: if it is AED 50 million or more, confirm whether an ASP has been appointed. 3) For all other VAT-registered businesses, diary 31 March 2027 for the ASP appointment and 1 July 2027 for go-live. 4) Confirm that the accounting system can produce invoices in the required structured format.
Sources
- https://mof.gov.ae/en/news/
- https://gulfnews.com/business/tax-news/uae-revises-einvoicing-fines-after-business-feedback-1.500729799
Published 31 October 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.
