Cabinet Decision No. 173 of 2026 replaces the UAE’s original e-invoicing penalty regime under Cabinet Decision No. 106 of 2025. It caps the implementation penalty at AED 50,000 in any 12 consecutive months, removes the system-failure notification fine and cuts the data-change notification fine by 75%.
The Ministry of Finance announced the revised framework on 30 October 2026, marking another important development in the UAE’s transition towards mandatory electronic invoicing.
What has changed?
The per-invoice fines stay the same. The changes are in the implementation fine, the notification fines and how the caps work.
| Violation | Decision 106 of 2025 | Decision 173 of 2026 |
|---|---|---|
| Failure to implement e-invoicing or appoint an ASP on time | AED 5,000 per month or part month, no cap | AED 5,000 initially, plus AED 5,000 per month or part month; capped at AED 50,000 in any 12 consecutive months |
| Recipient fails to keep complying after implementation | Not separately listed | Same as above |
| Failure to issue and transmit an e-invoice | AED 100 per invoice, capped at AED 5,000 per month | Unchanged |
| Failure to issue and transmit an e-credit note | AED 100 per credit note, capped at AED 5,000 per month | Unchanged |
| Failure to notify the FTA of a system failure | AED 1,000 per day or part day | Removed |
| Failure to notify the ASP of changes to registered data | AED 1,000 per day or part day, no cap | AED 250 per day or part day, capped at AED 5,000 per month |
The system-failure fine went because Ministerial Decision No. 197 of 2026 had already repealed the underlying notification requirement with effect from 1 October 2026. Decision 173 brings the penalty regime into line with that change.
Key Aspects of the Decisions
- New annual cap on the implementation penalty: E-Invoicing implementation and ASP-appointment penalty, previously uncapped, now tops out at AED 50,000 in any 12 consecutive months.
- The system-failure notification penalty has been removed: the AED 1,000 per day penalty for not notifying the FTA of a system failure.
- The data-change notification penalty is 75% lower and now capped: the penalty for not notifying the ASP of data changes falls from AED 1,000 to AED 250 per day, now capped at AED 5,000 a month.
- Per-document penalties are unchanged: AED 100 per e-invoice or e-credit note not issued, capped at AED 5,000 a month.
- Recipients face a new continuing violation: stopping compliance after implementation is penalised on the same basis as failing to implement.
- One violation, one penalty: applies where the same person is both Issuer and Recipient.
- Voluntary adopters are still excluded.
RVG Insight
E-invoicing compliance does not end with appointing an Accredited Service Provider or implementing the system. Businesses must ensure that their invoicing processes, systems and internal controls remain compliant on an ongoing basis. The real test of e-invoicing readiness is not whether the system goes live, but whether it continues to operate compliantly
