Cabinet Decision No. 106 of 2025 sets six e-invoicing penalties. Missing your implementation or provider deadline costs AED 5,000 for each month or part month. Each invoice or credit note not sent through the system costs AED 100, capped at AED 5,000 a month. Unreported system failures cost AED 1,000 a day.
The six violations at a glance
| Who | Violation | Penalty |
|---|---|---|
| Issuer | Not implementing the system, including not appointing an accredited service provider, on time | AED 5,000 per month or part of a month |
| Issuer | Not issuing and sending an e-invoice through the system | AED 100 per invoice, max AED 5,000 a calendar month |
| Issuer | Not issuing and sending an e-credit note through the system | AED 100 per credit note, max AED 5,000 a calendar month |
| Issuer | Not telling the FTA about a system failure in time | AED 1,000 per day or part of a day |
| Recipient | Not telling the FTA about a system failure in time | AED 1,000 per day or part of a day |
| Issuer or recipient | Not telling your provider about changes to data registered with the FTA | AED 1,000 per day or part of a day |
All six come from the annex to Cabinet Decision No. 106 of 2025. Two details matter more than they look. A part month counts as a full month, so being one day late on the appointment deadline costs the same as being thirty days late. And buyers are not off the hook: two of the six penalties apply to recipients.
Worked example 1: appointing a provider late
A distributor with AED 80 million revenue has until 30 October 2026 to appoint an accredited service provider (Ministry of Finance). It signs on 5 January 2027. That is two months plus a few days late, which counts as three months: 3 × AED 5,000 = AED 15,000. If it is still not live when invoicing becomes mandatory on 1 January 2027, the monthly charge keeps running until it is.
“shall come into force from the day following the date of its publication”
Worked example 2: invoices sent the old way
After go-live, a branch keeps emailing PDF invoices for a month: 38 invoices and 4 credit notes. Invoices: 38 × AED 100 = AED 3,800. Credit notes: 4 × AED 100 = AED 400. Each category is capped at AED 5,000 a month, so the total is AED 4,200. Had the branch issued 120 PDF invoices, the invoice penalty would stop at the AED 5,000 cap. The cap is per category per calendar month, not per year.
Worked example 3: a system outage nobody reported
An ERP upgrade breaks the connection to the provider over a long weekend and nobody tells the FTA for four days. At AED 1,000 a day, that is AED 4,000 for the issuer. If the buyer also knew and stayed silent, it faces the same daily penalty. The fix is procedural, not technical: name the person who reports failures and write the steps down before go-live.
When did the penalties start?
The decision applies from the day after its publication in the Official Gazette. In practice, each penalty bites once the matching obligation applies to you, so the AED 5,000 monthly penalty for larger businesses is tied to the 30 October 2026 appointment deadline, and the per-invoice penalties to the 1 January 2027 go-live. The go-live dates were not moved when the appointment deadline was extended (Ministry of Finance).
How to keep the penalty bill at zero
- Sign with an accredited provider before your deadline, even if integration finishes later.
- Switch off any route that can still produce a PDF invoice for in-scope customers, including branch templates and manual Word invoices.
- Route credit notes through the same system as invoices.
- Write a one-page outage procedure: who notices, who tells the FTA, by when.
- Tell your provider the same day you change your trade name, address or TRN details with the FTA.
Our readiness check flags most of these in a minute.
Frequently asked questions
Is the AED 5,000 penalty a one-off?
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No. It applies for each month, or part of a month, that implementation or the provider appointment is late.
Is the AED 100 per invoice uncapped?
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No. It is capped at AED 5,000 per calendar month, separately for invoices and for credit notes.
Can a buyer be penalised?
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Yes. Recipients can be penalised for not reporting a system failure and for not telling their provider about changes to registered data.
Can penalties be challenged?
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Yes, through reconsideration with the FTA, the same route used for other tax penalties.
Sources
- Cabinet Decision No. 106 of 2025 on violations and administrative penalties for the Electronic Invoicing System — UAE Ministry of Finance. Checked 17 October 2026.
- Ministry of Finance announces targeted amendments to eInvoicing system decisions (ASP deadline moved to 30 October 2026) — UAE Ministry of Finance, 10 May 2026. Checked 17 October 2026.
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System — UAE Ministry of Finance. Checked 16 October 2026.