On 30 October 2026, the UAE Ministry of Finance announced Cabinet Decision No. 173 of 2026 — a new administrative-penalties framework for the e-invoicing system that repeals Cabinet Decision No. 106 of 2025 entirely.
This is not a minor edit. The headline penalty structure is now capped, one penalty was removed outright, a new daily penalty appeared, and a double-counting loophole was closed. If you read penalty figures anywhere else — including older articles on this site — check them against the table below.
The four penalties under Cabinet Decision 173
| Violation | Penalty | Cap |
|---|---|---|
| Not implementing the system / not appointing an ASP | AED 5,000 first violation + AED 5,000 per month of continued non-compliance | AED 50,000 per rolling 12 months |
| Not issuing and transmitting an e-invoice | AED 100 per invoice | AED 5,000 per calendar month |
| Not issuing and transmitting an e-credit note | AED 100 per credit note | AED 5,000 per calendar month |
| Not notifying your ASP of changes to registered data | AED 250 per day | AED 5,000 per calendar month |
What actually changed vs Cabinet Decision 106
Three substantive shifts, all directions businesses wanted:
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The implementation penalty is now capped. Under the old framework, missing your appointment or go-live could compound month after month without limit — a year of non-compliance reached AED 60,000+ before per-invoice fines. The new cap of AED 50,000 per rolling 12 months makes the worst case predictable.
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The system-failure penalty is gone. The old decision penalised issuers and recipients for not reporting system failures to the FTA. The duty itself was already repealed by Ministerial Decision 197 of 2026; the penalty reference is now removed to match. One less thing to track.
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No double-fining. If the same person violates the same rule as both Issuer and Recipient, only one penalty applies. And the Decision is explicit that voluntary adopters are out of scope — if you're ahead of your mandate phase, these fines don't apply to you yet.
New on the other side of the ledger: the AED 250/day penalty for failing to notify your ASP of changes to the data registered with the Authority — capped at AED 5,000/month. Keep your TRN and contact details current with your provider.
Deadlines did not move
The penalties changed; the calendar didn't:
- Phase 1 (revenue ≥ AED 50m): ASP appointment was due 30 October 2026 — passed — go-live 1 January 2027
- Phase 2 (revenue < AED 50m): ASP appointment by 31 March 2027, go-live 1 July 2027
- Phase 3 (government entities): appointment by 31 March 2027, go-live 1 October 2027
Full dates in our UAE e-invoicing deadlines table. For the earlier framework's history, the Cabinet Decision 106 analysis remains as context — but treat CD 173 as the law now.
How to stay on the right side of it
The exposure concentrates in two places: appointing an accredited provider before your deadline and transmitting every invoice through the network once live. Both are operational, not legal, problems.
TrustBill submits through Microvista Technologies — an FTA-accredited service provider — so the transmission path is built into the platform: every invoice and credit note you issue travels the compliant route by default, and your registered data stays current through your provider. See pricing, or verify what "accredited" means before appointing anyone.
If you're still mapping obligations, start with the UAE e-invoicing guide and the penalties overview.
