UAE Sets Penalties for Mandatory E-Invoicing Non-Compliance

After publishing two key Ministerial Decisions at the end of September that finalize and clarify the UAE’s national e-invoicing framework, and confirming the gradual introduction through a phased rollout, on November 24, 2025, the UAE Ministry of Finance published a Cabinet Decision that defines penalties for non-compliance with mandatory e-invoicing and reporting obligations. The Decision includes a list of violations together with defined penalties.

Main E-Invoicing Violations and Penalties

As previously noted, the UAE plans a phased rollout, beginning on July 1, 2026, when the pilot program for selected taxable persons will commence. The rollout is set to be completed in October 2027, when government bodies will be included in the system. To ensure compliance and effective implementation, the Ministry set out a series of financial penalties.

Those who fail to implement the system and appoint an Accredited Service Provider on time will be fined AED 5,000 (around USD 1.360) per month, or a pro rata amount for each day of delay. Taxable persons who do not receive or exchange e-invoices or e-credit notes within the required timeframe will incur a penalty of AED 100 (around USD 27) per document, capped at AED 5,000 per calendar month.

Furthermore, both the e-invoice and e-credit note issuers and the recipients must report any system failures to the Federal Tax Authority on time. Those who fail to fulfill this obligation will be penalized with AED 1,000 (around USD 272) for any delays. The same penalty applies in cases when the issuer or recipient fails to notify the appointed Accredited Service Provider of changes to the registered data with the Tax Authority on time.

Conclusion

It is essential to note that defined penalties apply only to those who are subject to mandatory e-invoicing, whereas those who voluntarily issue, transmit, share, or report e-invoices and e-credit notes are exempt from them. Therefore, the penalty system has two functions. On one hand, to ensure those required to comply with rules, and on the other hand, to encourage voluntary compliance without the risk of penalties during the transition period. 

Source: UAE Ministry of Finance, VATabout