UAE caps eInvoicing penalties at AED 50,000 a year in a new decision

UAE caps eInvoicing penalties at AED 50,000 a year in a new decision

30 October 2026: The UAE Ministry of Finance has replaced Cabinet Decision No. 106 of 2025, the penalty schedule for the national eInvoicing system, with a new Cabinet Decision that fines an issuer or recipient who fails to meet its implementation obligations AED 5,000 for the first violation and AED 5,000 for each further month, up to AED 50,000 in any twelve consecutive months. The Ministry says the changes follow feedback from businesses preparing for mandatory eInvoicing.

Not yet independently verified. This rests on the Ministry of Finance announcement. The Ministry gives neither the number nor the effective date of the new decision, and we have not read its text or its full penalty table. We will update this when it can be confirmed, and remove this note.

A monthly fine with a ceiling

The core change is to the penalty for not complying with the "eInvoicing implementation obligations". Under the new decision, the Ministry says, "a penalty of AED 5,000 applies for the initial violation, followed by AED 5,000 for each month or part thereof during which the non-compliance continues, subject to a maximum aggregate penalty of AED 50,000 for these violations in any twelve consecutive months."

Two details in that wording matter for a finance team planning its go-live. A part month counts as a whole month, so a business that misses its date by a few days pays the second AED 5,000. And the cap runs over any rolling twelve months rather than a calendar year, so a long delay that spans January is still capped at AED 50,000 in total.

The Ministry describes the new schedule as "more proportionate" and says it revises a number of the penalties in the old decision. It does not publish the revised table, so the amounts for other breaches, such as late issue of an individual eInvoice, cannot yet be compared with the 2025 schedule.

The system failure fine is gone

The new decision removes the penalty for an issuer or recipient that fails to notify the Federal Tax Authority of a system failure. That follows Ministerial Decision No. 197 of 2026, which repealed the duty to report a failure within two business days and dropped the rule that eInvoice data be stored in the UAE. With the obligation gone, the fine attached to it had nothing left to punish.

The decision also settles a question that worried groups that trade with themselves. Where the same person acts as issuer, recipient or both in relation to the same violation, the Ministry says, only one administrative penalty will be imposed.

Where this leaves the first wave

The penalties apply as the first wave of mandatory eInvoicing approaches. Businesses in that wave had until 30 October to appoint an accredited service provider ahead of a go-live on 1 January 2027, and invoices between members of the same VAT tax group are excluded for 24 months from that date.

A business that has not yet signed with a provider now knows the most it can be fined in a year for a late start, though not when the new decision takes effect. Our accounting software category lists nine products and our ERP category two; none of them yet records UAE accreditation.

Related on TrustList:

• mika raises €6 million seed for AI bookkeeping and tax returns for small German companies
• FBR: moving stock to your own warehouse needs no e-invoice, but must travel with a Stock Transfer Note
• Saudi Arabia: ZATCA’s e-invoicing Wave 25 covers VAT revenue over SAR 187,500, with Fatoora integration due by 1 February 2027

Sources

• UAE Ministry of Finance: MoF announces updated administrative penalties related to the UAE eInvoicing system, 30 October 2026