UAE eInvoicing penalties: what Cabinet Decision 173 of 2026 changed
The UAE's new eInvoicing penalties under Cabinet Decision 173 of 2026: the AED 50,000 cap, a new penalty for recipients, what was removed and how to avoid each.
On 30 October 2026, the last day for the largest UAE businesses to appoint an eInvoicing provider, the Ministry of Finance announced new penalties for the eInvoicing system. Cabinet Decision No. 173 of 2026 replaces Cabinet Decision No. 106 of 2025, the penalty table most eInvoicing guides have quoted since December, ours included.
Some fines are now lower and capped, one has gone, and one is new: a business that receives eInvoices can now be penalised in its own right. Here is the new table, what changed, and what it means for businesses going live on 1 January 2027.
The new penalty table
| Violation | Under Decision 173 of 2026 | Before, under Decision 106 of 2025 |
|---|---|---|
| Not implementing eInvoicing by your date, including not appointing an ASP | AED 5,000 for the first violation, then AED 5,000 for each month or part of a month it continues, up to AED 50,000 in any 12 consecutive months | AED 5,000 for each month or part of a month of delay, with no cap |
| A recipient that stops meeting its obligations after implementing | The same penalty and cap as above | Not covered |
| Not issuing and transmitting an eInvoice through the system | AED 100 per eInvoice, up to AED 5,000 a calendar month | The same |
| Not issuing and transmitting an electronic credit note | AED 100 per credit note, up to AED 5,000 a calendar month | The same |
| Not telling your ASP about a change to your FTA-registered details | AED 250 for each day or part of a day, up to AED 5,000 a calendar month | AED 1,000 a day, with no cap |
| Not telling the FTA about a system failure | Removed | AED 1,000 a day |
The decision takes effect the day after it is published in the Official Gazette, and the Ministry's eInvoicing programme overview now lists Decision 106 as repealed. The phase dates have not moved, and the penalty for not implementing applies only once your own date has passed.
Five changes worth knowing
1. The implementation penalty now has a ceiling
Under Decision 106, a business that had not implemented eInvoicing paid AED 5,000 for every month or part of a month of delay, with no limit. Twelve months late would have cost AED 60,000, and the total kept growing.
Decision 173 keeps the AED 5,000 but caps the total for this violation at AED 50,000 in any 12 consecutive months: the first AED 5,000 plus nine more months.
The cap limits the damage. It does not make waiting cheap. From 1 January, a business in the first phase without an ASP cannot send eInvoices at all, and every invoice to a business customer has to be one.
2. Recipients are covered, not just issuers
Decision 106 penalised only the Issuer, the business sending the invoice, for failing to implement eInvoicing. The new row covers the Issuer or the Recipient, so a business is caught for the invoices it receives as well as the ones it sends.
It also adds a second case: a Recipient that implemented eInvoicing but then stops meeting its obligations as a recipient. Those obligations are in Ministerial Decision No. 243 of 2025: keep an ASP appointed, process the eInvoices and credit notes you receive through the eInvoicing system, and report them to the FTA through your ASP.
So appointing an ASP is not a one-off task. If the contract lapses, or nobody handles supplier eInvoices, the same AED 5,000 a month can apply.
3. One penalty, not two
Most businesses are both: they send invoices to customers and receive them from suppliers. Article 3 of the new decision says that where the same person acts as Issuer, Recipient or both for the same violation, only one penalty is imposed. A business that has not implemented eInvoicing at all is not fined twice for the same failure.
4. Late notice to your ASP costs less
When the FTA confirms a change to your registered details, you must tell your ASP in writing within five business days (Decision 243, Article 5). That deadline has not changed. The penalty has: AED 250 a day instead of AED 1,000, and no more than AED 5,000 in a calendar month.
At the old rate, a 20-day delay cost AED 20,000. Now it costs AED 5,000.
5. The system failure penalty is gone
Decision 106 charged AED 1,000 a day to an issuer or recipient that did not report a system failure to the FTA within two business days. Ministerial Decision No. 197 of 2026 removed that obligation from 1 October 2026, and the new decision removes the penalty to match.
What did not change
- The per-document penalties. AED 100 for each eInvoice or electronic credit note not issued and transmitted through the system, up to AED 5,000 a calendar month. At that rate, 50 documents reach the monthly maximum.
- The time limits. The new penalty descriptions no longer mention a timeline, but the limits are still in Decision 243: VAT-registered businesses issue eInvoices within the VAT timeline for tax invoices, and everyone else within 14 business days of the transaction.
- Voluntary adoption. The decision does not apply to anyone who issues, exchanges or reports eInvoices voluntarily. A business below AED 50 million revenue can start early, and penalties apply only from its own mandatory date.
- The dates. Ministerial Decision No. 244 of 2025, as amended by Decision No. 66 of 2026, still sets them:
| Who | Appoint an ASP by | eInvoicing mandatory from |
|---|---|---|
| Revenue of AED 50 million or more | 30 October 2026 | 1 January 2027 |
| Revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities | 31 March 2027 | 1 October 2027 |
Where penalties will come from after 1 January
For a business in the first phase that has appointed its ASP, the risk moves from the appointment to daily invoicing. Four places to watch:
- Failed eInvoices. Your ASP validates every eInvoice before it sends it on. One that fails, for a missing buyer TRN or a wrong tax category, has not reached your customer until it is fixed and sent again. Clear failures every day, not at month-end.
- Credit notes. Cancellations, price reductions, returns and corrections each need an electronic credit note (Decision 243, Article 6), with the same AED 100 penalty as an invoice. Raise every credit note in the system that sends your eInvoices, not outside it.
- Supplier eInvoices. As a recipient, you now have obligations of your own. Decide who in accounts payable reviews incoming eInvoices and how they reach your books.
- Changes at the FTA. A change to your registered details starts the five-business-day clock to tell your ASP. Make the notice part of the same process that updates your EmaraTax profile.
In Zoho Books
Zoho is on the Ministry's list of Accredited Service Providers (no. 121988), so for businesses on Zoho Books the ASP is part of the accounting system. Each of the risks above has a feature behind it:
- Every invoice shows its eInvoicing status, Yet To Be Pushed, Pushed or Failed, and a failed one shows the validation error on the transaction.
- Credit notes for cancellations, returns, discounts and corrections go out as electronic credit notes through the same network.
- Supplier eInvoices arrive in Zoho Books, ready to review and record.
- Approvals can hold an eInvoice until the right person has checked it.
We cover setup and pricing in UAE eInvoicing in Zoho Books. If you have not appointed a provider yet, start with what to do after the 30 October deadline.
Getting ready before your date
Lower penalties do not change the work. Your data still has to pass validation on every invoice, and your team still has to send, correct and receive eInvoices every day. Our eInvoicing page has the full timeline and obligations.
If your go-live is 1 January, or you want to start early, book a free consultation. We will check your Zoho Books data and setup against what the eInvoicing system rejects, before your customers' providers do.
Official sources
- Cabinet Decision No. 173 of 2026 on the Violations and Administrative Penalties of the Electronic Invoicing System (Ministry of Finance)
- Cabinet Decision No. 106 of 2025, now repealed (Ministry of Finance)
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (Ministry of Finance)
- Ministerial Decision No. 197 of 2026, amending Decision No. 243 of 2025 (Ministry of Finance)
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System (Ministry of Finance)
- Ministerial Decision No. 66 of 2026, amending Decision No. 244 of 2025 (Ministry of Finance)
- UAE eInvoicing Programme, October 2026 (Ministry of Finance)
- eInvoicing Accredited Service Providers (Ministry of Finance)
- Zoho Books UAE eInvoicing (Zoho)
- E-Invoicing in UAE, overview (Zoho Books help)
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