Cabinet Decision No. 106 of 2025 · UAE Federal
Fixes the penalties for e-invoicing breaches: AED 5,000 for each month of delay in implementing the system, including failing to appoint an Accredited Service Provider on time, and AED 100 per electronic invoice or credit note not issued and transmitted on time, capped at AED 5,000 per calendar month.
Cabinet Decision No. 106 of 2025 fixes the administrative penalties for breaches of the UAE electronic invoicing legislation issued under the Tax Procedures Law, Federal Decree-Law No. 28 of 2022. It was issued on 9 October 2025 and, under Article 4, came into force on the day after its publication in the Official Gazette; the Federal Tax Authority records the effective date as 15 October 2025. It is in force and is the penalty companion to the Ministry of Finance decisions that create the e-invoicing system and set its implementation timeline.
Article 1 adopts the definitions of the Tax Procedures Law and adds the terms the penalties turn on. An Electronic Invoice or Electronic Credit Note is one issued, transmitted and received in a structured electronic format that allows automatic processing through the Electronic Invoicing System. The Issuer is the person required to issue, transmit, share and exchange those documents through the system, the Recipient the person who receives them through it, and a System Failure a technical malfunction, disruption or unavailability that prevents either from meeting its obligations.
Article 2 confines the Decision to violations of the e-invoicing legislation and excludes anyone who issues, transmits or reports electronic invoices voluntarily under decisions made pursuant to the Tax Procedures Law. Article 3 applies the penalties in the annexed table.
The table has six entries. An Issuer that fails to implement the system within the Minister's timeline, including by failing to appoint an Accredited Service Provider in time, pays AED 5,000 for each month or part of a month of delay. An Issuer that fails to issue and transmit an Electronic Invoice to the Recipient through the system within the Minister's timeline pays AED 100 per invoice, capped at AED 5,000 per calendar month, and the same applies per Electronic Credit Note with the same monthly cap. An Issuer or a Recipient that fails to notify the Authority of a System Failure within the timeline pays AED 1,000 for each day or part of a day of delay, and an Issuer or Recipient that fails to notify its Accredited Service Provider of changes to the data registered with the Authority within the timeline pays AED 1,000 per day of delay.
The Decision sets no procedure of its own for assessment, objection or collection; those follow the Tax Procedures Law and its Executive Regulation, which govern administrative penalty assessments generally. The timelines that trigger each penalty are not in this Decision but in the Minister of Finance's implementation decisions, so the phased go-live dates for different taxpayer groups determine from when each amount can be charged.
Issuers, meaning persons required to issue, transmit, share and exchange electronic invoices and credit notes through the UAE Electronic Invoicing System, and Recipients who receive them through it, within the phases set by the Minister of Finance. Persons who join the system voluntarily under the Tax Procedures Law decisions are outside the Decision.
English official text in 3 articles. Open the full text or jump to a provision:
| Article 1 | Adopts the Tax Procedures Law definitions and defines Electronic Invoice and Electronic Credit Note as structured electronic documents processed automatically through the Electronic Invoicing System, the Issuer and Recipient of such documents, and System Failure as a malfunction, disruption or unavailability that prevents compliance. |
| Article 2 | The Decision applies to violations of the electronic invoicing legislation under Federal Decree-Law No. 28 of 2022 and does not apply to persons who issue, transmit, share, exchange or report electronic invoices and credit notes voluntarily. |
| Article 3 | The administrative penalties in the annexed table apply to the violations it lists. |
| Article 4 | The Decision is published in the Official Gazette and comes into force on the day following publication, recorded by the FTA as 15 October 2025. |
| Table, item 1 | An Issuer that fails to implement the Electronic Invoicing System within the Minister's timeline, including by failing to appoint an Accredited Service Provider in time, pays AED 5,000 for each month or part of a month of delay. |
| Table, items 2–3 | An Issuer that fails to issue and transmit an Electronic Invoice or Electronic Credit Note to the Recipient through the system within the Minister's timeline pays AED 100 per document, capped at AED 5,000 per calendar month for each category. |
| Table, items 4–5 | An Issuer or a Recipient that fails to notify the Authority of a System Failure within the Minister's timeline pays AED 1,000 for each day or part of a day of delay. |
| Table, item 6 | An Issuer or Recipient that fails to notify its appointed Accredited Service Provider of changes to the data registered with the Authority within the Minister's timeline pays AED 1,000 for each day or part of a day of delay. |
AED 5,000 for each month or part of a month of delay in implementing the system or appointing an Accredited Service Provider; AED 100 per electronic invoice and AED 100 per electronic credit note not issued and transmitted on time, each capped at AED 5,000 per calendar month; AED 1,000 per day or part of a day for failing to notify the Authority of a System Failure, by an Issuer or a Recipient; and AED 1,000 per day for failing to notify the Accredited Service Provider of changes to registered data.
These are the figures we quote when a client asks whether the e-invoicing provider appointment can wait. The AED 5,000 monthly charge for late implementation runs from the phase deadline set by the Ministry of Finance, and the per-document charge of AED 100 bites on every invoice a client's system fails to transmit, so a business issuing hundreds of invoices hits the AED 5,000 monthly cap almost immediately. In our bookkeeping and VAT engagements we map each client to its implementation phase, help select and contract with an Accredited Service Provider, and build the System Failure and data-change notifications into the month-end checklist, because the daily AED 1,000 penalties for silence accumulate faster than the invoice penalties themselves. We also remind clients that voluntary early adopters are outside this Decision, which makes an early, controlled go-live the lower-risk path.
| Cites | Tax Penalties Decision (VAT, Excise, Procedures) · Tax Procedures Law · VAT Law |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
E-Invoicing System Decision
Defines the scope of the Electronic Invoicing System: every person conducting business in the UAE must issue and transmit electronic invoices and credit notes through an …
E-Invoicing Implementation Timeline Decision
Sets the e-invoicing roll-out: pilot from 1 July 2026; businesses with revenue of AED 50 million or more appoint an Accredited Service Provider (by 30 October 2026 under …
E-Invoicing Timeline Amendment (May 2026)
Replaces paragraph (a) of Article 5(1) of the implementation decision: businesses with annual revenue of AED 50 million or more now have until 30 October 2026 to appoint …
E-Invoicing System Amendment (October 2026)
From 1 October 2026 revises the e-invoicing system decision: replaces the Accredited Service Provider definition, adds Tax Group and Taxable Person definitions, deletes t…
Tax Procedures Law
The common procedural code for all federal taxes: registration, record keeping, returns, voluntary disclosures, FTA audits and assessments, tax agents, administrative pen…
VAT Law Amendment (E-Invoicing, 2024)
Inserts the legal basis for e-invoicing into the VAT Law: new definitions of the Electronic Invoicing System, electronic invoice and electronic credit note, revised defin…
Tax Procedures Executive Regulation
Implements the Tax Procedures Law: which accounting records must be kept and for how long (generally five years, seven for real estate records), form and language of docu…
Tax Penalties Decision (VAT, Excise, Procedures)
Sets in three tables the fixed and percentage-based administrative penalties the FTA imposes for breaches of the Tax Procedures Law, the Excise Tax Law and the VAT Law, s…
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