NaqoodCabinet Decision 173 of 2026 Rewrites the UAE E-Invoicing Penalty Table
On 30 October 2026, the Ministry of Finance announced a new Cabinet Decision on administrative penalties for the UAE Electronic Invoicing System, reported by WAM the same day. The full text, Cabinet Decision No. 173 of 2026, is now on the MoF eInvoicing page. It repeals Cabinet Decision No. 106 of 2025 in full and replaces its penalty table.
The headline: the AED 5,000 monthly fine for not implementing e-invoicing (including not appointing an Accredited Service Provider) now has a ceiling of AED 50,000 in any 12 consecutive months. The fine for not notifying the FTA of a system failure is gone, and the fine for not updating your provider on changed FTA data drops from AED 1,000 to AED 250 a day.
The deadlines do not move. If you are new to the programme, our UAE e-invoicing guide explains who is in scope, the phase dates and how the five-corner model works.
What changed under Cabinet Decision No. 173 of 2026?
| Violation | Cabinet Decision 106 of 2025 | Cabinet Decision 173 of 2026 |
|---|---|---|
| Not implementing e-invoicing, including not appointing an ASP on time | AED 5,000 per month, no stated cap | AED 5,000 for the first instance, then AED 5,000 per month or part of a month, capped at AED 50,000 in any 12 consecutive months |
| Not notifying the FTA of a system failure | AED 1,000 per day of delay | Removed |
| Not notifying your ASP of changes to data registered with the FTA | AED 1,000 per day of delay | AED 250 per day of delay, up to AED 5,000 per calendar month |
The fines for not issuing and transmitting an e-invoice or an electronic credit note through the system are unchanged: AED 100 per document, up to AED 5,000 per calendar month for each type.
The decision also names the Recipient directly. Item 1 covers a failure by the Issuer or the Recipient to implement the system, and a new item covers a Recipient that implemented the system but then fails to keep meeting its obligations as a Recipient. Both items share the same AED 50,000 cap. So a business that mostly receives invoices from suppliers should not assume e-invoicing is only the seller’s problem.
How does the AED 50,000 cap work in practice?
Under the old table, a business that stayed non-compliant for a full year could face AED 5,000 for each month, or AED 60,000. Under Decision 173, the total for the implementation items cannot exceed AED 50,000 within any period of 12 consecutive months.
The cap limits how far the fine can build up. It does not reduce the AED 5,000 starting amount, and it does not remove the obligation to implement. A business that is late still pays from the first month and still has to get connected.
Can I be fined twice as both issuer and recipient?
No, not for the same violation. Article 3 says that where the same person acts as an Issuer, a Recipient, or both in respect of the same violation, only one administrative penalty is imposed for it. Most SMBs both send and receive invoices, so this matters. Different violations can still each attract their own fine.
As before, the decision does not apply to businesses that issue, transmit or report e-invoices on a voluntary basis. Penalties only bite once you are required to implement under your phase.
When does Decision 173 apply?
Article 5 says the decision comes into force on the day after its publication in the Official Gazette. The MoF announcement does not give a separate start date, so check the Gazette date with your adviser if you need the exact day for a specific breach.
The phase dates are unchanged. Businesses with revenue of AED 50 million or more had to appoint an Accredited Service Provider by 30 October 2026 and must implement by 1 January 2027. Businesses below AED 50 million must appoint an ASP by 31 March 2027 and implement by 1 July 2027.
What should SMB owners and accountants check now?
If your revenue is AED 50 million or more and you have not appointed an ASP, the implementation fine can already apply. Appoint one now: the cap limits the total, but every month of delay still costs AED 5,000 until you hit it.
If you are below AED 50 million, use the time before 31 March 2027 to pick a provider and make sure your accounting system can send and receive structured invoices over Peppol. Remember the Recipient items: your suppliers will start sending you e-invoices, and you need to be able to receive them.
Finally, put a simple process in place for telling your ASP when your FTA registration details change, such as your trade name, address or TRN details. The daily fine is lower now, but it still runs up to AED 5,000 a month. Our earlier post on MoF Decision 197 of 2026 explains why the system failure notice, and now its fine, no longer apply.
Naqood is FTA-accredited accounting software for UAE businesses. Keeping invoices, credit notes and supplier bills in one ledger makes it easier to see what you issue and receive when e-invoicing goes live.
FAQ
What is the maximum e-invoicing implementation penalty in the UAE now?
Under Cabinet Decision No. 173 of 2026, the fines for failing to implement e-invoicing (including failing to appoint an Accredited Service Provider) and for a Recipient failing to stay compliant are capped at AED 50,000 in any 12 consecutive months.
Is there still a fine for not reporting an e-invoicing system failure?
No. Decision 173 removes the AED 1,000 per day fine that applied under Cabinet Decision No. 106 of 2025. The duty to notify the FTA within 2 Business Days was already repealed by Ministerial Decision No. 197 of 2026.
Did Cabinet Decision 173 of 2026 extend the e-invoicing deadlines?
No. Businesses with revenue of AED 50 million or more had to appoint an ASP by 30 October 2026 and must implement by 1 January 2027. Smaller businesses have until 31 March 2027 to appoint and 1 July 2027 to implement.
Sources
- Ministry of Finance, Cabinet Decision No. 173 of 2026 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System (English PDF)
- Emirates News Agency (WAM), “MoF announces updated administrative penalties related to UAE eInvoicing system”, 30 October 2026
- Ministry of Finance, announcement of Cabinet Decision No. 106 of 2025, 8 December 2025
- Federal Tax Authority, e-invoicing deadlines reminder, 25 October 2026
This post is for general information and does not constitute tax or legal advice. For how the rules apply to your specific situation, consult a qualified UAE tax adviser. Naqood is an FTA-accredited accounting platform for UAE businesses.