UAE Announces Official Penalty Table for E-Invoicing Non-Compliance
On Monday, November 24, 2025, the UAE Ministry of Finance moved the country’s digital transformation agenda forward by publishing Cabinet Decision No. 106 of 2025. This decision introduces a definitive table of administrative penalties for violations related to the mandatory Electronic Invoicing System and signals that the government is ready to enforce the mandate strictly once it goes live.
The "Soft Launch" Prediction
Despite the publication of these fines, immediate punitive action may not be the government's first step.
The initial months following the obligation's effective date may serve as an unofficial, de facto grace period. During this transitional window, non-compliant entities are more likely to receive warnings and guidance rather than immediate financial penalties, allowing businesses to iron out technical teething issues.
However, businesses should not mistake this potential leniency for a permanent waiver. The penalties are codified and will be enforceable.
The Official Penalty Table
The new decision outlines specific fines for varying degrees of non-compliance. Notably, the penalties address both the failure to implement the system and the failure to maintain operational continuity (e.g., reporting system failures).
Below is a summary of the key penalties introduced:
| Violation | Penalty Amount |
| Failure to implement the E-Invoicing System (including failure to appoint an Accredited Service Provider by the deadline) | AED 5,000 per month of delay (or part thereof) |
| Failure to issue & transmit an E-Invoice to the Recipient through the system | AED 100 per invoice (Capped at AED 5,000 per calendar month) |
| Failure to issue & transmit an E-Credit Note to the Recipient through the system | AED 100 per credit note (Capped at AED 5,000 per calendar month) |
| Failure to notify the Authority of a System Failure (Applicable to both Issuer and Recipient) | AED 1,000 per day of delay (or part thereof) |
| Failure to notify the Accredited Service Provider of changes to registered data | AED 1,000 per day of delay (or part thereof) |
Next Steps
With the penalty structure now public, the cost of non-compliance is calculable. We recommend reviewing your implementation roadmap against the official deadlines to ensure your ERP integration and ASP selection are finalized well before the grace period expires.
As a Ministry of Finance Pre-Approved E-Invoicing Service Provider, Comarch is here to help. Schedule a consultation to assess your current status and ensure your implementation roadmap is robust enough to avoid these penalties.
There’s more to know about e-invoicing in the United Arab Emirates - explore the new and upcoming regulations.
