The UAE’s e-invoicing penalties are set in Cabinet Decision No. 106 of 2025, announced by the Ministry of Finance on 8 December 2025. This guide lists every fine, explains when each one starts for your phase, and shows how to avoid it. If you are preparing your ERP now, our UAE e-invoicing integration service covers the technical side: PINT AE mapping, ASP connection and monitoring.
What are the fines under Cabinet Decision No. 106 of 2025?
The decision lists five violations. The amounts below are as published by the Ministry of Finance.
| Violation | Penalty | Cap | Legal obligation behind it |
|---|---|---|---|
| Not implementing the e-invoicing system, or not appointing an Accredited Service Provider, within the timeframe | AED 5,000 per month | None stated | MD 244/2025, Art. 5 (as amended by MR 66/2026) |
| Not issuing or sending an electronic invoice within the timeframe | AED 100 per e-invoice | AED 5,000 per month | MD 243/2025, Art. 6 |
| Not issuing or sending an electronic credit note within the timeframe | AED 100 per e-credit note | AED 5,000 per month | MD 243/2025, Art. 6(2) |
| Not notifying the Federal Tax Authority (FTA) of a system malfunction within the timeframe | AED 1,000 per day of delay (or part of a day) | None stated | MD 243/2025, Art. 12, repealed by MD 197/2026 from 1 October 2026 |
| Not notifying your Accredited Service Provider of changes to data registered with the FTA within the timeframe | AED 1,000 per day of delay (or part of a day) | None stated | MD 243/2025, Art. 5(3): within five business days |
Who do the penalties apply to?
The penalties apply to every person required to implement the e-invoicing system under Ministerial Decision No. 243 of 2025. That covers any person conducting business in the UAE for its business transactions, except the exclusions in Article 4 of that decision, such as sovereign government transactions, international passenger air tickets and certain exempt or zero-rated financial services.
Two groups are outside the penalty regime for now:
- Voluntary adopters. The Ministry of Finance states that persons applying the system voluntarily are exempt from the decision until they become mandatorily subject to it. Voluntary adoption has been possible since 1 July 2026.
- Business-to-consumer (B2C) transactions. Under Ministerial Decision No. 244 of 2025, B2C transactions, and persons engaged exclusively in them, are not subject to the system until the Minister decides otherwise.
When do the penalties start for my business?
Each fine starts from the deadline that applies to your phase. The two headline dates are the ASP appointment date and the implementation date.
| Phase | Who | Appoint ASP by | Implement by |
|---|---|---|---|
| Phase 1 | Revenue ≥ AED 50 million | 30 October 2026 | 1 January 2027 |
| Phase 2 | Revenue < AED 50 million | 31 March 2027 | 1 July 2027 |
| Government | Government entities | 31 March 2027 | 1 October 2027 |
“Revenue” means gross income in the most recent accounting period, based on your financial statements. The Phase 1 ASP deadline was originally 31 July 2026; Ministerial Resolution No. 66 of 2026 moved it to 30 October 2026 and kept the go-live date. Every 2026 change is in UAE e-invoicing amendments in 2026.
In practice:
- The AED 5,000 monthly fine can apply from the day after your ASP appointment deadline if no ASP is appointed, and from your implementation date if you are not live.
- The per-document fines apply once you must issue e-invoices, from your implementation date onwards.
- The notification fines apply whenever the relevant change or event happens after you are in scope.
How is the AED 5,000 monthly fine calculated?
The fine is AED 5,000 per month for a business that has not implemented the system, or not appointed an ASP, within the deadline in Ministerial Decision No. 244 of 2025. The Ministry’s summary of the decision does not state a cap, so expect the fine to keep accruing monthly until the business complies. For how partial months are counted, rely on the full decision text or your tax adviser.
How do the per-invoice fines work?
Each e-invoice that is not issued or sent within the timeframe costs AED 100, and each late or missing electronic credit note costs AED 100. Each category is capped at AED 5,000 per month.
The timeframe comes from Ministerial Decision No. 243 of 2025:
- VAT registrants issue and transmit e-invoices and e-credit notes within the timeline set by the VAT Law.
- Other persons issue and transmit them within 14 days of the date of the business transaction.
Credit notes are easy to miss. They must be issued electronically when a transaction is cancelled, when the agreed price is reduced, when consideration is returned in full or in part, or when there is an administrative or numerical error.
What changed with the system failure notification?
Cabinet Decision No. 106 of 2025 lists a fine of AED 1,000 per day for not notifying the FTA of a system malfunction on time. The obligation behind it was Article 12 of Ministerial Decision No. 243 of 2025, which required notification within two business days.
Ministerial Decision No. 197 of 2026 removed the system failure provisions, including that notification requirement, with effect from 1 October 2026. The fine still appears in the Cabinet Decision, so confirm with your tax adviser how the FTA treats it now. Even without a legal duty, keeping a log of outages is good practice, because it explains any late invoices.
How do I avoid each penalty?
Each fine maps to a specific weak point. Use this checklist to close them before your deadline.
- ASP appointed early. Sign with an Accredited Service Provider from the Ministry’s published list well before your phase deadline, not on the last day.
- Connector tested end to end. Your ERP data mapped to PINT AE, sandbox tests passed for every invoice type, and production onboarding complete before go-live.
- Invoices issued from the system, not around it. Every sales channel that issues invoices (ERP, POS, branch tools) feeds the e-invoicing flow, so no invoice is missed.
- Credit notes automated. Cancellations, discounts, returns and corrections create electronic credit notes linked to the original invoice.
- Rejections monitored daily. A queue shows rejected or unsent documents, with an owner who fixes and resubmits them within the timeframe.
- Registration changes routed to the ASP. When your trade name, address or other FTA-registered data changes, someone notifies the ASP in writing within five business days.
- Outages logged. Even after MD 197/2026, record any system failure and how invoices were handled, to support your position if asked.
What does a realistic risk look like?
The per-document caps limit the damage from occasional late invoices, but the monthly AED 5,000 fine for not being live has no stated cap. A business that misses its implementation date by three months faces at least AED 15,000 from that fine alone, before any per-invoice fines once it is in scope. The cost of being late is predictable, which makes the case for starting the integration early.
For businesses below AED 50 million, the deadlines are 31 March 2027 for the ASP and 1 July 2027 for go-live. Our month-by-month plan is in UAE e-invoicing under AED 50 million. If you are still deciding who does what, read ASP vs integrator vs ERP vendor.
How Co-Mate helps
Co-Mate is an integration engineering company, not an Accredited Service Provider. We connect your ERP to the ASP you choose, map your invoices to PINT AE, automate credit notes and give your finance team a rejection queue, so the fines above do not become a monthly cost. Start with the free e-invoicing readiness check or see our UAE e-invoicing integration service.