FTA Urges E-Invoicing Compliance: Service Provider Appointment Due 30 October 2026, AED 5,000 Monthly Penalty
Asif Rashid Abdul 
The Federal Tax Authority (FTA) has called on persons subject to the UAE’s Electronic Invoicing System to meet the legal deadlines for the phased rollout and avoid administrative penalties. For businesses with annual revenues of AED 50 million or more, the first deadline falls on 30 October 2026, when an Accredited Service Provider (ASP) must be appointed.
The reminder follows an expanded joint meeting held in Dubai on 29 September 2026, attended by more than 700 participants from accredited providers, businesses and FTA officials. This article sets out the deadlines, the penalty framework and the recent amendments businesses should note.
Deadlines
| Category | Appoint an ASP by | Implement the system by |
| Revenues equal to or exceeding AED 50 million | 30 October 2026 | 1 January 2027 |
| Revenues below AED 50 million | 31 March 2027 | 1 July 2027 |
The 30 October date was originally 31 July 2026. Ministerial Decision No. 66 of 2026 amended Ministerial Decision No. 244 of 2025 to move it, and left the 1 January 2027 implementation date unchanged. Commentary indicates that government entities follow a separate timetable, with appointment by 31 March 2027 and implementation by 1 October 2027.
Penalties
Cabinet Decision No. 106 of 2025 sets the administrative penalties for violations of the e-invoicing legislation.
| Violation | Penalty |
| Failure to implement the system, including failure to appoint an ASP within the prescribed timeline | AED 5,000 for each month, or part of a month, of delay |
| Failure to issue and send an electronic invoice within the prescribed timeline | AED 100 per invoice, up to AED 5,000 per calendar month |
| Failure to issue and send an electronic credit note within the prescribed timeline | AED 100 per credit note, up to AED 5,000 per calendar month |
Because the first penalty accrues for each month or part of a month, missing an appointment deadline by even a short period engages a full month’s penalty.
Recent amendments: Ministerial Decision No. 197 of 2026
The Ministry of Finance announced Ministerial Decision No. 197 of 2026 on 19 October 2026. It amends Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System and took effect on 1 October 2026.
- Tax groups. Business transactions between members of the same tax group are excluded for 24 months from 1 January 2027.
- Storage. Persons subject to the system must retain electronic invoices, credit notes and associated data for the period under the Tax Procedures Law and be able to produce them to the FTA on request. The requirement to store the data within the UAE has been removed.
- System failure. The definition of “system failure” and the related notification requirement are removed, through the repeal of Article 12.
- Issuance deadline. Invoices and credit notes must be issued and transmitted within 14 Business Days from the date of the transaction.
Steps the FTA outlines
The FTA urges businesses to avoid leaving preparations to the last minute. The sequence it describes is to select an appropriate ASP, contract and integrate with that provider, and then complete the required procedures on the EmaraTax platform.
Practical Takeaways
- Confirm which revenue category applies to the business.
- Businesses at or above AED 50 million should complete the ASP appointment by 30 October 2026, and then finish contracting, integration and EmaraTax steps before 1 January 2027.
- Businesses below AED 50 million can use the period to 31 March 2027 to select a provider and test their systems.
- Tax group members should review how the 24-month exclusion from 1 January 2027 applies to their intra-group transactions.
- Review record-retention and storage arrangements against the amended Article 11, including any offshore storage.
- Check that invoicing workflows reflect the 14-Business-Day issuance period.
- Keep a record of the appointment date, the provider contract and the EmaraTax steps completed.