The UAE Cabinet has issued Cabinet Decision No. 173 of 2026 to replace its 2025 fine table for electronic invoicing. Not implementing the system will cost AED 5,000 plus AED 5,000 a month, capped at AED 50,000 in 12 months. A missed e-invoice stays at AED 100. It starts the day after Official Gazette publication (date to confirm).
Dune Trading LLC has revenue of AED 80 million and both sends and receives invoices. Suppose it has no e-invoicing provider for 2 months and 10 days. Later, once live, it fails to send 80 e-invoices in one calendar month.
| Not implementing the system | AED 5,000 for the first instance, plus AED 5,000 for each month or part: 3 units, AED 15,000 (our reading of how months are counted). Total AED 20,000, under the AED 50,000 ceiling |
|---|---|
| Same failure, as both sender and receiver | One penalty only. Dune is both Issuer (sender) and Recipient (receiver), but Article 3(2) allows one penalty per violation |
| 80 e-invoices not sent in one month | 80 x AED 100 = AED 8,000, held to the monthly maximum of AED 5,000 |
How does UAE e-invoicing work, and where do fines come from?
E-invoicing means invoices and credit notes in a structured electronic format a computer can process, sent through a designated system. The Issuer sends them; the Recipient receives them through the same system. Both act through an Accredited Service Provider, a provider with accreditation to offer e-invoicing services, on a list the Ministry of Finance publishes (Ministerial Decision 243 of 2025, Articles 5 and 6).
Ministerial Decision 243 applies to any Person conducting Business in the UAE, except excluded transactions (Articles 3 and 4). The fines sit in a Cabinet Decision issued with reference to the VAT Law (Federal Decree-Law No. 8 of 2017) and Tax Procedures Law (Federal Decree-Law No. 28 of 2022).
From 1 October 2026, Ministerial Decision 197 of 2026 sets the issuing window at 14 Business Days from the transaction date (earlier text: 14 days) and removes the system-failure notification duty.
Who must be ready, and by when?
Revenue means gross income in the latest accounting period. Ministerial Decision 244, as amended by Decision 66 of 2026, sets three phases.
- 30 October 2026Revenue of AED 50 million or more: appoint a service provider.The original 2025 text said 31 July 2026; Ministerial Decision 66 of 2026 replaced it.
- 4 November 2026: todayFirst appointment date now passed.
- 1 January 2027Revenue of AED 50 million or more: implement.
- 31 March 2027Revenue below AED 50 million, and Government Entities: appoint a service provider.
- 1 July 2027Revenue below AED 50 million: implement.
- 1 October 2027Government Entities: implement.
Consumer sales, and businesses selling only to consumers, are not yet subject to the system (Article 5(2)).
What changed in the fine table?
The old table (Decision 106 of 2025) had six lines; the new one has four, and Article 4 repeals the old Decision.
| Violation | Before: Decision 106 of 2025 | Now: Decision 173 of 2026 |
|---|---|---|
| 1. Not implementing the system | Issuer only. AED 5,000 for each month or part of a month of delay. | CHANGED Issuer or Recipient, including not appointing a provider (Ministerial Decision 244). AED 5,000 first instance plus AED 5,000 each month or part while it continues. Cap AED 50,000 in any 12 consecutive months. NEW LIMB (b) A Recipient that implemented but later fails its duties under Ministerial Decision 243. Same amount. |
| 2. E-invoice not issued and sent | AED 100 each, up to AED 5,000 per calendar month. | SAME AMOUNT AED 100 each, up to AED 5,000 per calendar month. |
| 3. E-credit note not issued and sent | AED 100 each, up to AED 5,000 per calendar month. | SAME AMOUNT AED 100 each, up to AED 5,000 per calendar month. |
| Late system-failure notice (old lines 4 and 5) | AED 1,000 each day or part, for Issuer and Recipient. | REMOVED No line in the new table. |
| 4. Late notice of changed registered data to the provider | AED 1,000 each day or part (old line 6). | LOWER AED 250 for each day or part, up to AED 5,000 per calendar month. |
One rule is new. Article 3(2): one penalty only where the same Person is Issuer, Recipient or both for the same violation. (Article 2(2), excluding voluntary users, carries over from the 2025 Decision.) The old lines carried the words “within the timeline prescribed by the Minister”; the new ones do not. Our reading: timing now comes from Ministerial Decision 243, such as five Business Days to tell the provider of a data change (Article 5(3)).
Which line applies to me?
When does it start, and what about 30 October 2026?
In force from the day after publication in the Official Gazette. The Gazette date is to confirm; the signature date is blank on the Ministry copy.
Our reading: line 1(a) points to Ministerial Decision 244 “and its amendments” and names failure to appoint a provider, so 30 October 2026 is the date it follows for revenue of AED 50 million or more. A separate start date for fines, and the treatment of a missed 30 October date before 1 January 2027, are to confirm with the Federal Tax Authority. Appoint now.
Legal basis
- Fines
- Cabinet Decision No. 173 of 2026, Articles 2 to 5 and annexed table
- Repeals
- Cabinet Decision No. 106 of 2025 (Article 4)
- Duties and phases
- Ministerial Decisions 243 and 197; 244 and 66
Key facts
| Instrument | Cabinet Decision No. 173 of 2026 on Violations and Administrative Penalties for the Electronic Invoicing System |
|---|---|
| Announced | 30 October 2026 (Ministry of Finance) |
| In force | Day after Official Gazette publication |
| Main amounts | AED 5,000 plus AED 5,000 a month (cap AED 50,000); AED 100 each (cap AED 5,000 a month); AED 250 a day (cap AED 5,000 a month) |
| Last verified | 4 November 2026 (all six official PDFs below) |
Frequently asked questions
Do the fines apply to voluntary users?
No. Article 2(2) excepts a Person who uses e-invoices and e-credit notes on a voluntary basis. Ministerial Decision 243, as amended, says the same for the penalty decisions.
What is the most I can be fined for not implementing?
For line 1, AED 5,000 plus AED 5,000 for each month or part it continues, capped at AED 50,000 in any 12 consecutive months. Lines 2 to 4 have their own ceiling of AED 5,000 per calendar month.
Are the old system-failure fines still there?
No. They are not in the new table, and Ministerial Decision 197 repeals the system-failure article of Decision 243 from 1 October 2026. Past periods are to confirm with the Federal Tax Authority.
My revenue is under AED 50 million. When must I be ready?
Appoint a provider by 31 March 2027 and implement by 1 July 2027 (Ministerial Decision 244). When fines begin is to confirm.
Sources (official, Ministry of Finance)
- Cabinet Decision No. 173 of 2026 https://mof.gov.ae/wp-content/uploads/2026/10/Cabinet-Decision-No.-173-of-2026-On-the-Violations-and-Administrative-Penalties-Resulting-from-Violation-of-the-Legislation-Regulating-the-Electronic-Invoicing-System_En.pdf
- Cabinet Decision No. 106 of 2025 (repealed) https://mof.gov.ae/wp-content/uploads/2025/12/Cabinet-Decision-Violations-and-Penalties-eInvoicing-final-version-en-8.12.25.pdf
- Ministerial Decision No. 243 of 2025 https://mof.gov.ae/wp-content/uploads/2025/10/Ministerial-Decision-no.-243-of-2025-on-the-Electronic-Invoicing-System.pdf
- Ministerial Decision No. 197 of 2026 https://mof.gov.ae/wp-content/uploads/2026/10/Ministerial-Decision-No.-197-of-2026-%E2%80%93-Amending-Certain-Provisions-of-Ministerial-Decision-No.-243-of-2025-on-the-Electronic-Invoicing-System_En.pdf
- Ministerial Decision No. 244 of 2025 (original text) https://mof.gov.ae/wp-content/uploads/2025/10/Ministerial-Decision-No.-244-of-2025-on-the-Implementation-of-the-Electronic-Invoicing-System.pdf
- Ministerial Decision No. 66 of 2026 https://mof.gov.ae/wp-content/uploads/2026/05/Ministerial-Resolution-No.-66-of-2026-Amending-Certain-Provisions-of-Ministerial-Resolution-No.-244-of-2025-Regarding-the-Implementation-of-the-Electronic-Invoicing-System-En-20260514.pdf
- UAE
- Indirect Taxation
- E-invoicing
- Penalties
- Ministry of Finance
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