In November 2025 the UAE Cabinet issued Decision No. 106 of 2025, setting out the administrative penalties that will apply once e-invoicing becomes mandatory for a business. For anyone still treating their ASP appointment as a “next year” problem, the decision is a useful reminder of what’s actually at stake.
What triggers a penalty
- Not implementing e-invoicing or appointing an Accredited Service Provider on time – AED 5,000 per month until you’re compliant.
- Not issuing electronic invoices as required – AED 100 per invoice, capped at AED 5,000 a month.
- Not issuing electronic credit notes as required – AED 100 per credit note, capped at AED 5,000 a month.
- Not notifying the FTA of a system failure that prevents compliance, within two business days – AED 1,000 per day until you notify them.
- Not updating your ASP with company data changes in good time – AED 1,000 per day until it’s updated.
When the penalties start to bite
Enforcement is phased in alongside the go-live dates: penalties for large taxpayers (revenue ≥ AED 50 million) apply from 1 January 2027, for the rest of the VAT-registered population from 1 July 2027, and for B2G transactions from 1 October 2027. Businesses that adopt voluntarily ahead of their mandatory phase face no penalties during that voluntary window.
What this means for your ASP timeline
Because the penalty clock starts on your go-live date, the real deadline that matters is the one before it: large taxpayers need an Accredited Service Provider appointed by 30 October 2026, ahead of the 1 January 2027 go-live. Appointing a provider, mapping your invoice data and testing transmission all take longer than most teams expect – leaving it late narrows your runway considerably.
This post summarises publicly available guidance on Cabinet Decision No. 106 of 2025 as we understand it. Penalty amounts and phase dates can be updated by the Ministry of Finance and Federal Tax Authority, so always confirm the current position through official FTA/MoF channels before making compliance decisions. For where Fincore E-Invoicing fits into your rollout, see our FTA UAE Mandate guide or get in touch.