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E-Invoicing Penalties UAE: What the Rules Say | HelloBooks UAE e-invoicing penalties: the schedule in Cabinet Decision 106 of 2025, its replacement in 2026, and the controls that keep a business clear of them.

Tax guide · E-invoicing

E-invoicing penalties UAE: the schedule and how to stay clear

The e-invoicing rules carry administrative penalties for not implementing the system on time, for missing or late e-invoices and credit notes, and for failing to keep the ASP updated. Cabinet Decision No. 106 of 2025 set the first schedule. The Ministry's October 2026 programme update marks it as repealed and names Cabinet Decision No. 173 of 2026 as the current penalties decision. Check that decision for current amounts; the original schedule below shows how the regime is built.

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The original schedule in Cabinet Decision No. 106 of 2025

As published by the Ministry of Finance in December 2025:

  • Not implementing the system, including not appointing an ASP on time: AED 5,000 for each month or part of a month of delay.
  • Not issuing and transmitting an e-invoice to the recipient on time: AED 100 per e-invoice, capped at AED 5,000 per calendar month.
  • Not issuing and transmitting an e-credit note on time: AED 100 per e-credit note, capped at AED 5,000 per calendar month.
  • Not notifying the appointed ASP of changes to data registered with the FTA on time: AED 1,000 for each day or part of a day.
  • The schedule also had penalties for late system failure notices; Ministerial Decision No. 197 of 2026 has since repealed that notification duty.

Why the replacement matters

Penalty amounts are set by Cabinet decision and can change. The Ministry e-invoicing page still links the 2025 decision, while the October 2026 programme update lists it as repealed and refers to Cabinet Decision No. 173 of 2026. Before quoting a figure to a client or budgeting for risk, read the current decision on the Ministry of Finance or FTA site.

The structure is the useful part: a monthly charge for not being set up, per-document charges with a monthly cap for missing invoices, and daily charges for stale data. Each points to a control you can put in place.

Controls that prevent each penalty

Appoint your ASP before your deadline, 30 October 2026 for businesses with revenue of AED 50 million or more and 31 March 2027 for the rest. Review rejected or unsent invoices daily during the first months. Treat changes to your trade licence, address or TRN details as a trigger to update the ASP the same week.

Clean source data reduces rejections. HelloBooks keeps complete invoice records and links each credit note to its original invoice; the AI agent flags invoices with missing buyer details before they are finalised. HelloBooks does not send e-invoices, so monitoring transmission status happens in your ASP's system.

FAQ

Frequently asked questions

Is there a penalty for not appointing an ASP on time?
Under Cabinet Decision No. 106 of 2025 it was AED 5,000 for each month or part of a month of delay. Check Cabinet Decision No. 173 of 2026 for the current amount.
Are per-invoice penalties capped?
In the 2025 schedule, missing e-invoices and e-credit notes each cost AED 100 per document with a cap of AED 5,000 per calendar month.
Is there still a penalty for late system failure notices?
Ministerial Decision No. 197 of 2026 repealed the system failure rules in Ministerial Decision No. 243 of 2025, including the two business day notice.

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