UAE replaces its e-invoicing penalty regime: Cabinet Decision No. 173 of 2026 repeals Decision No. 106 of 2025

What changed in detail

UAE Cabinet Decision No. 173 of 2026 on the Violations and Administrative Penalties Resulting from Violation of the Legislation Regulating the Electronic Invoicing System sets the penalty regime for the Electronic Invoicing System. Under its Article 4, it repeals Cabinet Decision No. 106 of 2025 on the same subject, together with any provision that contradicts or conflicts with it.

The penalties are set out in the table annexed to the decision. They include:

• AED 100 for each electronic invoice not issued and transmitted to the recipient through the Electronic Invoicing System, up to AED 5,000 per calendar month;
• AED 100 for each electronic credit note not issued and transmitted, up to AED 5,000 per calendar month; and
• AED 250 for each day of delay in notifying the appointed Accredited Service Provider of changes to the data registered with the Authority.

Under Article 5, the decision is to be published in the Official Gazette and enters into force on the day following its publication. The Ministry of Finance copy does not state the publication date.

What it means

The per-document penalties make transmission failures a volume risk: a business whose integration silently drops invoices or credit notes can reach the AED 5,000 monthly cap on each type quickly. Controls that confirm each document actually reached the recipient through the system matter as much as the ability to generate it.

The ASP notification penalty runs per day, so a change of registered data (address, legal details, contacts) needs a routine for telling the Accredited Service Provider promptly. Because the in-force date depends on Official Gazette publication, which the Ministry’s copy does not show, check the gazette date before relying on the old Decision No. 106 rules for any period.