UAE Mandate
UAE eInvoicing Penalties: Cabinet Decision No. 106 of 2025 Explained
Administrative penalties for failing to implement UAE eInvoicing, missing invoice timelines, or delayed System Failure notices, from the Cabinet Decision annex.
Updated 2026-08-02 · 6 min read
What this decision covers
Cabinet Decision No. 106 of 2025 sets administrative penalties for violations of the legislation regulating the Electronic Invoicing System, under Federal Decree-Law No. 28 of 2022 on Tax Procedures.
It does not apply to Persons who issue/transmit/report Electronic Invoices voluntarily (Article 2(2)), those voluntary implementers still follow technical rules under MD 243 / MD 244, but the penalty schedule in Decision 106 is carved out for them.
Penalty table (annex)
- Amounts below are taken from the table annexed to Cabinet Decision No. 106 of 2025. Always read the official PDF for the binding wording.
| # | Violation | Penalty |
|---|---|---|
| 1 | Issuer fails to implement the Electronic Invoicing System, including failure to appoint an ASP within the Minister’s timeline | AED 5,000 for each month of delay (or part thereof) |
| 2 | Issuer fails to issue and transmit an Electronic Invoice to the Recipient through the system within the prescribed timeline | AED 100 per Electronic Invoice, max AED 5,000 per calendar month |
| 3 | Issuer fails to issue and transmit an Electronic Credit Note within the prescribed timeline | AED 100 per Electronic Credit Note, max AED 5,000 per calendar month |
| 4 | Issuer fails to notify the Authority of a System Failure within the prescribed timeline | AED 1,000 for each day of delay (or part thereof) |
| 5 | Recipient fails to notify the Authority of a System Failure within the prescribed timeline | AED 1,000 for each day of delay (or part thereof) |
| 6 | Issuer or Recipient fails to notify the appointed ASP of changes to data registered with the Authority within the prescribed timeline | AED 1,000 for each day of delay (or part thereof) |
How this ties to day-to-day obligations
From MD 243 of 2025:
- Appoint an Accredited Service Provider (Article 5).
- Issue/transmit invoices and credit notes through the system; generally within 14 days from the Date of Business Transaction (Article 6(5)), subject to VAT Law timelines for Registrants.
- Notify the Authority of a System Failure within 2 Business Days (Article 12).
- Notify the ASP of Authority-registered data changes within 5 Business Days of confirmation (Article 5(3)).
Implementation phases that trigger “failure to implement / appoint ASP” are in MD 244 as amended by MD 66 of 2026 (e.g. large taxpayers: ASP by 30 October 2026, go-live 1 January 2027).
Practical takeaway
The highest recurring exposure for many businesses is row 1, missing the ASP appointment or go-live window at AED 5,000 per month. Invoice-level failures are capped monthly, but System Failure and data-change notification delays accrue per day.