UAE e-invoicing fines: what Cabinet Decision 106 of 2025 actually says

Many summaries of UAE e-invoicing quote penalty figures without a source. We went to the Ministry of Finance's English text of Cabinet Decision 106 of 2025, announced on 8 December 2025. The annexed table lists six violations.

The table

• Not implementing the e-invoicing system, including not appointing an accredited service provider on time: AED 5,000 for each month or part of a month of delay.
• Not issuing and sending an e-invoice to the recipient through the system on time: AED 100 per e-invoice, capped at AED 5,000 per calendar month.
• Not issuing and sending an electronic credit note through the system on time: AED 100 per credit note, capped at AED 5,000 per calendar month.
• The issuer not notifying the FTA of a system failure on time: AED 1,000 for each day or part of a day.
• The recipient not notifying the FTA of a system failure on time: AED 1,000 for each day or part of a day.
• The issuer or recipient not notifying their accredited provider of changes to data registered with the FTA on time: AED 1,000 for each day or part of a day.

The deadlines each fine refers to

• Provider appointment and go-live: 30 October 2026 and 1 January 2027 for revenue of AED 50 million or more, 31 March 2027 and 1 July 2027 for other businesses, 31 March and 1 October 2027 for government entities.
• E-invoices: within the VAT invoice timeline for registered businesses, and within 14 days of the transaction for others.
• Credit notes: within 14 days of the event that triggers them.
• System failures: reported to the FTA within two business days.
• Changes to registered details: passed to your provider within five business days of the FTA confirming them.

Reading it correctly

• Repeat offences are not escalated. The invoice and credit note fines each have a monthly cap, and the text is silent on whether the caps combine.
• Voluntary users are outside the penalties, and the guidelines say they only apply from a business's mandatory date.
• The final line concerns your provider, while the two system failure lines concern the FTA.
• References to a fine for using the wrong format do not match the decision, which is about issuing and sending on time.
• Ordinary VAT penalties under Cabinet Decision 40 of 2017 can still apply to the same invoice.

When the fines start

The decision takes effect the day after publication in the Official Gazette, a date we could not confirm. Because each fine is tied to a business's own deadlines, the earliest realistic exposure is for businesses at AED 50 million or more that have not appointed a provider by 30 October 2026.

Sizing it for a smaller business

For a business in the second phase, missing the 31 March 2027 appointment means AED 5,000 for each month or part month. From 1 July 2027, every late or off-system invoice or credit note costs AED 100, up to AED 5,000 a month for each type. The amounts are modest one by one, but they recur every month until the system is in place.

If you would rather not discover these deadlines the hard way, ALXO can help you plan your e-invoicing timetable.