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. 87,900 EUR) in annual supplies, confirmation of a bank account
• Document the performed verification and retain the supporting evidence

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

The amendment affects large businesses with annual revenues exceeding 50 million AED (ca. 11.56 million EUR). Previously, large businesses were required to appoint an Accredited Service Provider (ASP) by July 31, 2026, but may now do so no later than October 30, 2026.

The timeline for required e-invoicing system implementation, however, remains unchanged. Full implementation for large businesses is required no later than January 1, 2027.