UAE E-Invoicing Penalties and Fines (Cabinet Decision No. 106 of 2025)

The UAE e-invoicing penalties are set by Cabinet Decision No. 106 of 2025: AED 5,000 for each month, or part of a month, without a working e-invoicing system or accredited service provider (ASP); AED 100 for each late e-invoice or electronic credit note, capped at AED 5,000 per calendar month; and AED 1,000 per day for late notifications. They only apply once your business's mandatory phase has started.

The same text is often called "Cabinet Resolution No. 106 of 2025". Below you will find the full table, what "or part thereof" means, three worked examples in AED, who is exposed and when, and a calculator for your own figures. For the wider picture, start with our UAE e-invoicing guide.

Key facts

• 6 violations are listed in Cabinet Decision No. 106 of 2025, each with a fixed fine.
• AED 5,000 per month or part thereof for not implementing the system, which includes not appointing an ASP on time.
• AED 100 per late e-invoice or e-credit note, capped at AED 5,000 per calendar month for each.
• AED 1,000 per day for late notifications: a system failure to the FTA (issuer or recipient), or a data change to your ASP.
• No fines for voluntary adopters: penalties only apply once you are legally required to comply.

What are the UAE e-invoicing penalties?

Three details in this table matter more than they look:

• The ASP deadline is part of the first line. "Failing to implement" includes failing to appoint an accredited ASP on time. Your appointment date (30 October 2026 or 31 March 2027) therefore counts, not only your go-live date.
• Caps are per calendar month and per line. Late e-invoices and late e-credit notes each have their own AED 5,000 cap. The daily fines have no monthly cap in the published table.
• Buyers are covered too. Not reporting a system failure is a separate violation for the issuer and for the recipient, and the data-change notice applies to both.

The decision enters into force the day after its publication in the Official Gazette. We could not confirm that publication date from an official source, so we don't give one. In practice, what matters is your own mandatory date, covered below.

What does "per month or part thereof" mean?

The wording comes straight from the decision: AED 5,000 "for each month or part thereof". One day into a new month of delay costs as much as the whole month, so a fix that is a few days earlier can save AED 5,000.

The decision does not say from which date the months are counted when a business has missed both its ASP appointment deadline and its go-live date. If your case depends on that, ask an FTA-registered tax agent.

How much could you be fined? Three worked examples

These examples apply the published amounts to simple situations. They are illustrations, not a forecast of what the FTA will decide in your case.

Example 1: an SME with no ASP on 1 July 2027

A trading company with revenue below AED 50 million had to appoint an ASP by 31 March 2027 and go live on 1 July 2027. It does neither. It signs with an ASP in August, and its first e-invoice goes out on 20 September 2027.

• Delay after the go-live date: 2 months and 19 days, which counts as 3 months.
• Fine: 3 × AED 5,000 = AED 15,000.

Treat AED 15,000 as a minimum. If the delay were counted from the missed appointment deadline of 31 March 2027, the same company would be 5 months and 20 days late, which counts as 6 months: AED 30,000. The invoices it sent as PDFs during those months were not e-invoices either; how the FTA treats them is a question for a tax agent.

Example 2: 30 e-invoices sent late in one month

A distributor issues its e-invoices on time for most of the year. One month, after a software update, 30 e-invoices are issued and transmitted after the legal deadline (the VAT law timeline, as the distributor is VAT-registered).

• 30 × AED 100 = AED 3,000 for that month.
• With 75 late e-invoices, the fine would stop at the cap: AED 5,000, not AED 7,500.
• If 10 e-credit notes were also late that month, add 10 × AED 100 = AED 1,000. Credit notes have their own line and their own cap.

The cap applies per calendar month. A problem that runs for three months can cost up to AED 15,000 for late e-invoices alone.

Example 3: a system failure reported 4 days late

An importer's ERP stops sending e-invoices to its ASP after a server crash. Ministerial Decision No. 243 of 2025 requires it to notify the FTA within 2 business days of the failure. Nobody is in charge of reporting it, and the finance manager only notifies the FTA 4 days after that deadline.

• 4 days × AED 1,000 = AED 4,000 for the issuer.
• The daily fine has no monthly cap. A week of silence (AED 7,000) costs more than a full month of late e-invoices at the cap.

The lesson: name the person who reports failures before you go live, not during the incident.

Estimate your own exposure

Enter your own figures below. The calculator applies the same table and caps. A full-page version, with a link you can share, is on the UAE e-invoicing penalty calculator page.

Who can be fined, and from when?

Who is exposed in practice:

• Suppliers (issuers) making B2B or B2G transactions in the UAE, whether or not they are VAT-registered, free zone companies included. Check the details on our page on who must comply with UAE e-invoicing.
• Buyers (recipients), who must also appoint an ASP. Two of the six violations apply to them: late failure notification and late data-change notification.
• New businesses set up after these phases, which must appoint an ASP and implement once they become subject to the system.

Not exposed under this decision:

• Voluntary adopters, for anything done before their mandatory date. The pilot and voluntary adoption have been open since 1 July 2026.
• Excluded transactions: sovereign government activities that do not compete with the private sector, international passenger flights with an e-ticket, airline ancillary services with an EMD, international air cargo with an airway bill (for 24 months), and VAT-exempt or zero-rated financial services. If you choose to e-invoice them voluntarily, the penalties don't apply.

The Ministry of Finance has described the move of the large-business ASP deadline to 30 October 2026 as a "targeted and final adjustment" and said no further extensions will be granted. Don't plan on a new delay.

Can VAT penalties apply on top?

How can you avoid e-invoicing penalties?

1. Check your phase and dates now. Revenue means gross income for your most recent accounting period, based on your financial statements. The e-invoicing readiness check gives you your personal deadlines in two minutes, and the UAE e-invoicing deadlines page explains every phase.
2. Appoint an accredited ASP early. Only providers on the official list of accredited service providers count. Signing in the last week leaves no time to connect and test.
3. Make sure your software issues on time. VAT-registered suppliers must issue within the VAT law timelines; other suppliers within 14 days of the transaction. Credit notes for cancellations, price reductions, refunds and errors must be electronic too. See the UAE e-invoicing requirements and compare e-invoicing software options.
4. Write a failure procedure. Name the person who notifies the FTA within 2 business days, and agree with your ASP how it will warn you when sending or receiving stops.
5. Keep FTA and ASP data in sync. When the FTA confirms a change to your registered details, such as your legal name or address, tell your ASP in writing within 5 business days.

Want the full project plan? Follow our 10-step e-invoicing implementation checklist.