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UAE eInvoicing penalties under Cabinet Decision 106/2025: the six violations, penalty amounts and how they are counted, including late ASP appointment

Published 24 October 2026 · Cabinet Decision 106/2025 read in the official English text on 24 October 2026; other official sources last reviewed 22 October 2026 · 10 min read

Until now, most explanations of UAE eInvoicing have focused on the ministerial decisions that set the scope, the obligations and the timetable. The penalties sit in a separate instrument: Cabinet Decision No. 106 of 2025 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System. It appears on the Ministry of Finance (MoF) eInvoicing legislation list, and we have now read the official English text published there.

This guide explains what the decision says and nothing more. It covers the definitions, the scope rule, the exclusion of voluntary participants, all six violations in the annexed table with their penalty amounts and how each amount is counted, and the entry-into-force rule. Where the text leaves a question open, we say so rather than fill the gap. It matters most right now for businesses with Revenue of AED 50 million or more, whose ASP appointment deadline is 30 October 2026; see our roadmap for that category.

The decision at a glance

Who issued it: the UAE Cabinet, on the proposal of the Minister of Finance.
Legal basis named in the preamble: among others, Federal Decree-Law No. 8 of 2017 on Value Added Tax, Federal Decree-Law No. 28 of 2022 on Tax Procedures, and Cabinet Decision No. 40 of 2017 on administrative penalties for violation of tax laws.
Structure: four articles (definitions, scope, violations and penalties, publication and entry into force) and an annexed table of six violations.
Penalty units: per month of delay, per document with a monthly cap, and per day of delay.
Voluntary participants: outside the decision under Article 2(2).

Article 1: the definitions it uses

Article 1 says that the definitions in the Tax Procedures Law (Federal Decree-Law No. 28 of 2022) apply, and adds five of its own. In short:

Electronic Invoice and Electronic Credit Note — an invoice or credit note issued, transmitted and received in a structured electronic format that allows automatic and electronic processing, in line with the Electronic Invoicing System.
Issuer — any Person obliged to issue, transmit, share and exchange Electronic Invoices and Electronic Credit Notes through the system.
Recipient — any Person who must receive Electronic Invoices and Electronic Credit Notes through the system.
System Failure — a technical malfunction, disruption or unavailability of the system that prevents the Issuer or Recipient from meeting their obligations under the legislation in force.

The table also refers to “the Authority”. The decision does not define that word itself; it relies on the Tax Procedures Law definitions, where the Authority is the Federal Tax Authority (FTA). These definitions line up closely with those in Ministerial Decision 243/2025, which we explain in our Article 6 obligations guide.

Article 2: scope and the voluntary participant exclusion

Article 2(1): what the decision covers

The decision applies to violations of the legislation regulating the Electronic Invoicing System, in accordance with the Tax Procedures Law. In practice, that legislation is the set of ministerial decisions on the MoF list: Decision 243/2025 (scope, exclusions and obligations), Decision 244/2025 (the timetable) and their amendments. Our legislation map explains how they fit together.

Article 2(2): voluntary participants are not penalised under it

Article 2(2) says the decision does not apply to a Person who issues, transmits, shares, exchanges or reports Electronic Invoices and Electronic Credit Notes on a voluntary basis under the decisions issued under the Tax Procedures Law. This matches Article 4(3) of Decision 243/2025 (as replaced by Decision 197/2026), which allows a Person to take part voluntarily for what the exclusions would otherwise leave outside the system; the decisions then apply to it on a mandatory basis, except for the provisions on violations and penalties. The two texts point the same way: joining voluntarily does not bring a business within these penalties. See our voluntary participation guide for who can opt in.

Note the limits of this exclusion. It covers participation on a voluntary basis. It does not, on its own wording, cover a business that is in scope and has simply not yet implemented the system.

Article 3 and the annexed table: the six violations

Article 3 says the administrative penalties in the annexed table are imposed for the violations related to the Electronic Invoicing System. The table has six rows. We set them out below in our own words, with the penalty as stated in the table.

No.	Violation (paraphrased)	Who	Administrative penalty
1	Failing to implement the Electronic Invoicing System, including failing to appoint an Accredited Service Provider within the timeline prescribed by the Minister	Issuer	AED 5,000 for each month of delay or part of a month
2	Failing to issue and transmit an Electronic Invoice to the Recipient through the system within the prescribed timeline	Issuer	AED 100 per Electronic Invoice, up to a maximum of AED 5,000 per calendar month
3	Failing to issue and transmit an Electronic Credit Note to the Recipient through the system within the prescribed timeline	Issuer	AED 100 per Electronic Credit Note, up to a maximum of AED 5,000 per calendar month
4	Failing to notify the Authority of a System Failure within the prescribed timeline	Issuer	AED 1,000 for each day of delay or part of a day
5	Failing to notify the Authority of a System Failure within the prescribed timeline	Recipient	AED 1,000 for each day of delay or part of a day
6	Failing to notify the appointed Accredited Service Provider of changes to the data registered with the Authority within the prescribed timeline	Issuer or Recipient	AED 1,000 for each day of delay or part of a day

How each penalty is counted

Per month of delay (row 1)

Row 1 is the one most relevant to the coming deadline. It treats failing to appoint an ASP within the ministerial timeline as part of failing to implement the system, and charges AED 5,000 for each month of delay “or part thereof”. Read literally, a delay that runs into a new month counts that month in full. As an editorial illustration only: a delay of one month and a few days would, on that wording, be counted as two months. The decision does not say from which day the FTA starts counting or how it treats a delay that is later cured; we have not confirmed that.

Per document with a monthly cap (rows 2 and 3)

Rows 2 and 3 charge AED 100 for each Electronic Invoice or Electronic Credit Note not issued and transmitted through the system within the timeline, up to AED 5,000 per calendar month. As an editorial illustration: thirty late invoices in one calendar month would come to AED 3,000 on that wording, while eighty would reach the AED 5,000 monthly cap. Invoices and credit notes are listed in separate rows, each stating its own cap. The timelines themselves come from the ministerial decisions; for Registrants the Article 6(4) VAT Law timeline applies, otherwise fourteen Business Days under Article 6(5) as replaced. Our credit notes guide covers the four cases that call for a credit note.

Per day of delay (rows 4 to 6)

Rows 4, 5 and 6 charge AED 1,000 for each day of delay “or part thereof”. Rows 4 and 5 concern notifying the Authority of a System Failure. Row 6 concerns telling your appointed ASP when data registered with the Authority changes, which makes it worth tying your internal change process for registration data to your ASP relationship; see our master data readiness guide.

What the decision leaves to other instruments

Every row refers to a timeline “prescribed by the Minister”. The decision does not set those timelines itself. The ones we have traced are:

ASP appointment and implementation: Decision 244/2025, Article 5(1), with Article 5(1)(a) replaced by Decision 66/2026. Revenue of AED 50 million or more: ASP by 30 October 2026, implementation by 1 January 2027. Below AED 50 million: ASP by 31 March 2027, implementation by 1 July 2027. Government Entities: ASP by 31 March 2027, implementation by 1 October 2027. See our deadlines guide.
Issuing Electronic Invoices and Credit Notes: Decision 243/2025, Article 6(4) and 6(5) as replaced by Decision 197/2026.
System Failure notification: Article 12 of Decision 243/2025, which dealt with System Failure, was repealed by Decision 197/2026 with effect from 1 October 2026. We have not confirmed which ministerial provision now sets the notification timeline that rows 4 and 5 refer to. See our guide to Decision 197/2026.
Notifying the ASP of data changes: we have not identified the ministerial provision that sets this timeline.

The table has no separate row naming reporting to the Authority under Article 6(6) of Decision 243/2025, or record retention under Article 11 as replaced. Whether other penalty legislation, such as Cabinet Decision No. 40 of 2017 named in the preamble, applies to those points is outside what this decision states, and we do not draw a conclusion on it. Our record keeping guide covers retention.

Article 4: publication and entry into force

Article 4 says the decision is published in the Official Gazette and comes into force on the day after the date of its publication. The English text we read does not state the date of issue or of Gazette publication, and we have not confirmed either date. If the exact start date matters to you, check the Official Gazette or ask the FTA.

What this means before 30 October 2026

For a business with Revenue of AED 50 million or more (including exactly AED 50,000,000), the appointment deadline in Decision 244/2025 as amended is 30 October 2026. Row 1 is the penalty that names a late ASP appointment. The practical steps below are editorial, not official:

Confirm your category against the Revenue definition; see our revenue threshold guide.
Confirm that your chosen provider is accredited under Decision 168/2026, not only pre-approved; see our ASP accreditation guide.
Record the date and evidence of your appointment.
Plan go-live by 1 January 2027, because row 1 covers failing to implement the system, not only the appointment.
Set up an internal process to tell your ASP when registration data changes (row 6).
Decide who in finance will notify the Authority of a System Failure once the applicable timeline is confirmed (rows 4 and 5).
Use our readiness check and readiness project plan to track the work.

If the appointment date is close or has already passed, our guide to missing the 30 October 2026 ASP deadline sets out what to check and an editorial recovery order.

Businesses below AED 50 million have more time; see our roadmap for that category. The penalty table is the same for all categories; only the ministerial timelines differ.

What we have not confirmed

The date of issue and the date of Official Gazette publication, and therefore the exact date of entry into force.
How the FTA counts the first month of delay under row 1, and how it treats a delay that is later cured.
Which current ministerial provision sets the System Failure notification timeline after the repeal of Article 12 of Decision 243/2025, and which sets the timeline for notifying the ASP of data changes.
Whether any FTA guidance on applying these penalties, waivers or reconsideration has been published; we have not reviewed any.
How Cabinet Decision No. 40 of 2017 interacts with this decision.

Frequently asked questions

Is there a penalty for missing the ASP appointment deadline?

Yes. Row 1 of the table covers failing to implement the system, including failing to appoint an Accredited Service Provider within the ministerial timeline: AED 5,000 for each month of delay or part of a month.

Are penalties charged per invoice?

For late or missing Electronic Invoices and Credit Notes, yes: AED 100 each, capped at AED 5,000 per calendar month per row.

Do the penalties apply if I join voluntarily?

No. Article 2(2) excludes voluntary participation, consistent with Article 4(3) of Decision 243/2025.

When did the decision come into force?

On the day after its publication in the Official Gazette. We have not confirmed the publication date.

Where can I read the decision?

The official English PDF is linked from the MoF eInvoicing programme page. Short answers on other topics are in our eInvoicing FAQ, and all guides are on the guides page. Key dates are summarised on the home page.

Official sources used in this guide

Important notice

This guide is general information prepared by MINSEONG.COM, an independent website. It is not legal or tax advice, it is not an official government publication, and it does not determine whether any penalty applies to any business. Penalty amounts are paraphrased from the official English text read on 24 October 2026; the illustrations are editorial. Rules may change after that date. Always check the current Ministry of Finance and Federal Tax Authority publications and consult a qualified UAE tax adviser before making decisions.