For UAE businesses with AED 50 million or more in annual revenue, the deadline to appoint an Accredited Service Provider (ASP) is 30 October 2026. Miss it, and the Cabinet has already set the price: AED 5,000 for each month or part of a month of delay. That is only one of six penalties in Cabinet Decision No. 106 of 2025, and the others work differently.
This short guide lays out all six, shows how they add up, separates the official figures from the inflated numbers circulating online, and explains how finance teams using an ERP in the UAE can avoid each one. For the full timeline and scope, see our UAE e-invoicing mandate guide.
- Cabinet Decision No. 106 of 2025 lists six violations with fixed administrative penalties.
- The largest recurring penalty is AED 5,000 per month for failing to implement the system or appoint an ASP on time.
- Late invoices and credit notes cost AED 100 each, capped at AED 5,000 per calendar month for each type.
- Penalties do not apply to businesses that use e-invoicing voluntarily.
The six e-invoicing penalties in the UAE
The annexed table of Cabinet Decision No. 106 of 2025 sets out the following. The timelines are those “prescribed by the Minister” in the Ministry of Finance (MoF) decisions.
| # | Violation | Penalty | Cap stated in the Decision |
|---|---|---|---|
| 1 | Issuer fails to implement the system, including failing to appoint an ASP on time | AED 5,000 for each month or part of a month of delay | None stated |
| 2 | Issuer fails to issue and transmit an e-invoice on time | AED 100 per e-invoice | AED 5,000 per calendar month |
| 3 | Issuer fails to issue and transmit an e-credit note on time | AED 100 per e-credit note | AED 5,000 per calendar month |
| 4 | Issuer fails to notify the FTA of a system failure on time | AED 1,000 for each day of delay or part of a day | None stated |
| 5 | Recipient fails to notify the FTA of a system failure on time | AED 1,000 for each day of delay or part of a day | None stated |
| 6 | Issuer or recipient fails to notify the ASP of changes to data registered with the FTA on time | AED 1,000 for each day of delay or part of a day | None stated |
Two reading notes. First, the monthly caps apply only to late invoices and late credit notes, and each has its own cap. Second, the Decision itself states no warning period or first-offence exemption. The only carve-out in the text is for voluntary users: Article 2 says the Decision does not apply to anyone who issues, transmits or reports e-invoices voluntarily.
How the fines add up: three hypothetical examples
These examples are illustrative arithmetic, not predictions of how the FTA will apply the rules.
- Late ASP appointment. A business in the AED 50M+ group that has not appointed an ASP three months after its deadline faces three months of delay, or AED 15,000 in total. Penalty 1 keeps accruing for each month or part of a month until the business is compliant.
- Late invoices and credit notes. A business issues 120 invoices and 70 credit notes outside the timeline in a single month. The invoice penalty would be AED 12,000 but is capped at AED 5,000. The credit note penalty would be AED 7,000 but is capped at AED 5,000. The maximum for the month is AED 10,000.
- Unreported outage. An issuer misses the notification deadline for a system failure by four days, which is AED 4,000. If its customer, as recipient, also fails to notify, that is a separate penalty for the recipient.
Numbers you may see online that are not in the Decision
Some commercial guides quote far higher figures, including per-invoice fines in the tens of thousands of dirhams. The official text of Cabinet Decision No. 106 of 2025 contains the six amounts above and nothing else. If you see another figure, ask for the article and table row it comes from. Because the Decision is short and public, it takes five minutes to check.
The same applies to reports of a general grace period. The Decision contains none. Two real timeline changes exist, and neither is a penalty waiver:
- Ministerial Decision No. 66 of 2026 moved the large-business ASP appointment deadline to 30 October 2026, but kept the 1 January 2027 go-live date.
- MoF’s Guidelines give VAT group members a 24-month grace period for transactions between themselves, from 1 January 2027 to 31 December 2028, as summarised by Baker McKenzie. Those transactions stay in scope; only the timing is deferred. Other transactions of the group follow the normal phases.
What the fines do not capture
The amounts are modest for a mid-sized or large company. The larger cost is operational. An invoice that fails validation is not delivered, so the customer cannot book it, and your collection date slips. A team that fixes rejections by hand spends hours it did not budget. A late appointment also means a late start on integration and testing, which is where most of the delivery risk sits.
Penalties under this Decision are also separate from other tax penalties, such as those for VAT filing errors. Ask your tax adviser how they may interact in your situation.
How to avoid each penalty
- Penalty 1: appoint on time. Check your phase and deadline: 30 October 2026 for AED 50M+ revenue, 31 March 2027 for others. Verify the provider on MoF’s register. Our guide to choosing an Accredited Service Provider explains how.
- Penalties 2 and 3: watch the clock. Under Ministerial Decision 243 of 2025, e-invoices and credit notes must be issued and transmitted within 14 days of the transaction. Set up alerts for documents approaching the limit, and a daily check for any stuck in rejection.
- Penalties 4 and 5: have an outage routine. The notification window is two business days. Decide in advance who tells the FTA, using what evidence, and how your ASP will alert you.
- Penalty 6: control master data. Changes to registered details must be notified to your ASP within five business days of the FTA confirming them. Give one person responsibility for company registration data.
Your ERP matters here because deadline alerts, rejection queues and clean customer records are things you configure and monitor in it. FACTS ERP’s e-invoicing page describes an invoice store with audit trail, VAT reporting and API integrations with other business systems. Whatever system you use, ask your vendor how it flags late and rejected documents.
Can you challenge a penalty?
The FTA’s general reconsideration process applies to its decisions. According to the FTA’s reconsideration service page, a request must be raised within 40 business days from the date of the original decision, and the FTA may take up to 45 business days to respond. Because e-invoicing penalties are new, confirm with your tax adviser how this applies to your case and keep records of when your documents were issued.
Frequently asked questions
What is the penalty for not appointing an ASP?
AED 5,000 for each month or part of a month of delay, under Cabinet Decision No. 106 of 2025, for businesses that are mandatorily subject to the system.
Do penalties apply during the voluntary phase?
No. Article 2 of the Decision says it does not apply to persons who issue, transmit, share, exchange or report e-invoices and credit notes voluntarily. Voluntary adoption has been open since 1 July 2026.
Is there a total limit on fines?
The Decision states monthly caps only for late invoices and late credit notes. The other penalties accrue for each month or day of delay, and the Decision states no cap for them.
Do buyers get fined for not processing e-invoices?
The annexed table lists no per-invoice penalty for recipients. Recipients can be penalised for failing to notify the FTA of a system failure and for failing to notify their ASP of changes to registered data. Recipients still have obligations under Ministerial Decision 243, so check your position with your adviser.
Is there a grace period before fines start?
The Decision text contains no general grace period. The reported relief is the 24-month intra-VAT-group grace period in MoF’s Guidelines and the extension of the ASP appointment deadline to 30 October 2026.
Where can I find the official penalty table?
On the Ministry of Finance’s e-invoicing portal, in the English text of Cabinet Decision No. 106 of 2025.
Conclusion
The penalty schedule is short, specific and public: six violations, mostly measured in AED 100 invoices, AED 1,000 days and AED 5,000 months. For businesses in the first wave, the one to avoid is the first, because it starts accruing as soon as the deadline passes. The best protection is not paying attention to fines but building routines: appoint early, test with real invoices, watch the 14-day clock and keep registration data current.
Want to check how ready your invoicing process is?
Talk to the FACTS ERP team or explore the FACTS ERP e-invoicing solution. Regulations can change, so confirm current requirements on the MoF portal before acting. You may also like our explainer on PINT AE and Peppol.
Sources
- Cabinet Decision No. 106 of 2025 on Violations and Administrative Penalties (English text)
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System
- Ministerial Resolution No. 66 of 2026 (amending Decision 244 of 2025)
- UAE Ministry of Finance: eInvoicing portal
- Baker McKenzie: summary of MoF’s Electronic Invoicing Guidelines (Feb 2026)
- UAE Federal Tax Authority: Reconsideration Request
This article is general information, not legal or tax advice.
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