Regulatory updates - United Arab Emirates

Rules for maintaining accounting records and commercial books

FTA Decision No. 4 of 2026, which became effective July 30, 2026, requires records and commercial books retained as Electronic Copies or Photocopies to be:

• Complete and identical to the original: All pages must be retained in original order; partial scans are not accepted.

• Clear and legible: Readable on screen, with ink or paper that does not fade over the retention period, non-coloured copies of coloured originals are permitted provided all details remain legible.
• Accessible to the FTA on request: Including encryption keys or passwords where records are protected, and access to the physical storage location for paper copies.

Concerned Goods imported before 2026

VATP045 clarifies the treatment of Concerned Goods imported on or before 31 December 2025. For such historical imports, businesses may avoid issuing a self-invoice by either obtaining an administrative exception from the FTA, or where applicable, retaining the overseas supplier invoice and relevant customs declaration and correctly reflecting the VAT in the VAT return.

New requirement to verify supplies before recovering input tax

FTA Decision No. 13 of 2026 comes into effect October 1, 2026, and introduces verification requirements for taxable persons before deducting input tax. Businesses must:

• Verify the supplier when first dealing with them and at least every 12 months thereafter, including identity, place of business and relevant risk indicators
• Verify the commercial substance of taxable supplies, including transaction rationale, payment arrangements and pricing
• For suppliers exceeding AED 375,000 (ca. EUR 87,900 ) in annual supplies, confirmation of a bank account
• Document the performed verification and retain the supporting evidence

Supplies under AED 10,000 (ca. EUR 2,340) are exempt from these checks, unless total dealings with that supplier exceed AED 100,000 (ca. EUR 23,400) over 12 months.

Affected businesses should review the full text of Decision No. 4, Decision No. 13, and VATP045 for details relevant to their operations.

The official accreditation confirms that ONESOURCE Pagero has fulfilled the technical, organizational, and legislative requirements set out by the Ministry of Finance. As a fully accredited service provider, businesses can use ONESOURCE Pagero to exchange and report e-invoices in compliance with the UAE e-invoicing model.

The UAE e-invoicing obligations will apply broadly, encompassing not only businesses established in the UAE, but also UAE VAT-registrants. Businesses in scope should begin preparations now, as implementation deadlines are approaching.

Large businesses with annual revenues of 50 million AED or more are required to appoint a UAE-accredited service provider (ASP) no later than October 30, 2026. Mandatory e-invoicing and reporting will be introduced for large businesses on January 1, 2027. Following this, other businesses with annual revenues less than 50 million AED, as well as government entities, will be brought into scope in accordance with the Ministry of Finance's implementation timeline. Note: the ASP appointment deadline for large businesses was extended to October 30, 2026.

Businesses within scope should now evaluate service providers and may then select their preferred ASP in the EmaraTax portal to begin onboarding and prepare for compliance with UAE e-invoicing requirements.

The key update in this version is the addition of Appendix 5 – Advance Payments and Retention Clarification, which provides further guidance on the electronic invoicing treatment of advance payments and retention amounts.

All Accredited Service Providers are requested to review the updated guidelines and assess any implementation, operational, and compliance impacts arising from the new clarification and other updates included in Version 1.1.

The updated UAE Electronic Invoicing Guidelines are available on the Ministry of Finance e-invoicing website.