What changed?
Cabinet Decision No. 106 of 2025 governed administrative penalties for the UAE e-invoicing framework. The Ministry's announcement describes implementation penalties without the newly announced twelve-month aggregate cap and included a penalty for an Issuer or Recipient failing to notify the Authority of a system failure.
The announced replacement Decision sets AED 5,000 for an initial specified implementation violation, then AED 5,000 for each month or part thereof while it continues, capped at AED 50,000 in any twelve consecutive months. It removes the system-failure notification penalty and prevents duplicate penalties for the same violation where the same Person acts as Issuer, Recipient or both.
Practical consequence: In-scope businesses should update penalty matrices and compliance controls, but should not treat AED 50,000 as a universal cap for every e-invoicing violation. The Decision number and commencement date were not stated in the Ministry announcement and remain to be verified from the legal text.
What happened?
On 30 October 2026, the UAE Ministry of Finance announced a new Cabinet Decision replacing Cabinet Decision No. 106 of 2025 on administrative penalties related to the Electronic Invoicing System.
The announcement confirms changes to specified implementation penalties and related safeguards. It does not identify the replacement Decision by number or state its commencement date.
Key details
For the implementation violations described by the Ministry, the initial penalty is AED 5,000. A further AED 5,000 applies for every month or part thereof during which non-compliance continues. The aggregate for those violations is capped at AED 50,000 in any twelve consecutive months.
The replacement Decision removes the former penalty for an Issuer or Recipient failing to notify the Authority of a system failure. It also provides that only one administrative penalty applies to the same violation when the same Person acts as Issuer, Recipient or both.