Understanding Cabinet Decision No. 106 of 2025 on eInvoicing violations

Updated list of Pre-Approved ASPs

The decision forms part of the UAE’s broader digital tax transformation and affects all persons required to issue, transmit and receive structured electronic invoices and credit notes. The framework applies from the day following its publication and supports the transition towards real-time reporting, transparency and standardised tax documentation across sectors.

What the decision covers

The decision applies to violations of the legislation regulating the UAE electronic invoicing system, including the issuing, receiving and reporting of electronic invoices and credit notes. It also covers system failure notifications and changes to registered information.

The provisions apply only to those required to comply under federal decree-law no. 28 of 2022 and do not apply to voluntary users of the system.

Key violations and penalties

Delayed implementation

Failure to implement the electronic invoicing system or appoint an accredited service provider on time may lead to:

AED5,000 per month of delay or part thereof

Late electronic invoices

Failure to issue or transmit electronic invoices within the prescribed timeline results in:

AED100 per invoice
Capped at AED5,000 per calendar month

Late electronic credit notes

Failure to issue or transmit electronic credit notes results in:

AED100 per credit note
Capped at AED5,000 per calendar month

Failure to notify system failures

Issuers or recipients who fail to notify the authority of a system failure within the required timeframe may be penalised:

AED1,000 for each day of delay or part thereof

Failure to update registered details

Failure to notify the accredited service provider of changes to registered information results in:

AED1,000 per day of delay or part thereof

Why compliance matters

The penalties encourage early adoption and strict adherence to the UAE’s digital tax infrastructure. As the country moves towards mandatory phases of eInvoicing, accurate systems, trained staff and strong process controls will be essential.

Timely implementation also helps businesses enhance tax governance, reduce risks and avoid avoidable costs.

Guidance steps for businesses

Step 1

Assess your current position

Confirm whether you fall within the required categories for eInvoicing compliance
Review existing invoicing systems and identify gaps in structure, format or transmission capabilities

Step 2

Appoint an accredited service provider

Understand the technical requirements of the eInvoicing system
Select an accredited service provider that can support both issuing and receiving structured eInvoices

Step 3

Prepare internal teams

Train finance, accounting and IT staff on system use
Set controls for issuing invoices, managing credit notes and monitoring transmission timings

Step 4

Establish a process for system failures

Put in place a clear internal policy for detecting and reporting technical issues
Ensure notifications to the authority are made within the required timeframe

Step 5

Maintain updated registered information

Review registered data regularly
Notify your accredited service provider promptly when changes occur

Step 6

Run testing and readiness checks

Conduct dry runs to ensure invoices and credit notes are issued in the correct format
Validate transmission workflows and data accuracy

Step 7

Monitor ongoing compliance

Track invoicing timelines
Flag delays to avoid recurring penalties
Review reports from your accredited service provider

FAQ

Who must comply with the eInvoicing system?

Any person obligated under federal decree-law no. 28 of 2022 to issue, transmit and receive structured electronic invoices and credit notes.

Does this apply to voluntary users?

No. The penalties do not apply to persons issuing or sharing electronic invoices voluntarily.

When do the penalties take effect?

The decision comes into force the day after publication in the official gazette.

What counts as a system failure?

A system failure is any technical malfunction or disruption that prevents compliance with issuing or receiving electronic invoices or credit notes.

How will penalties be monitored?

Penalties will be applied based on delays, non-compliance and reporting failures, as outlined in the decision.

How can businesses reduce their exposure?

By implementing the system on time, setting internal controls and ensuring the timely reporting of system failures or data changes.

How we can support you

Forvis Mazars supports businesses in preparing for the UAE’s eInvoicing transition through readiness assessments, system selection support and compliance reviews. Our team helps organisations build robust and compliant invoicing processes that align with regulatory timelines and reduce exposure to penalties.

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Contact

Sabine Sleiman Partner - Tax advisory

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Partner - Risk consulting Akshat Prakash

Akshat Prakash Partner - Risk consulting