Cabinet Decision 106/2025: UAE E-Invoicing Fines from AED 100 to AED 5,000 — Full Breakdown
Cabinet Decision No. 106 of 2025 sets the penalty framework for UAE e-invoicing non-compliance. Fines range from AED 100 per invoice to AED 5,000 per month. Here is exactly what triggers each fine and how to avoid all of them.
What Is Cabinet Decision No. 106 of 2025?
Cabinet Decision No. 106 of 2025 was issued on 24 November 2025 by the UAE Council of Ministers. It establishes the administrative penalty framework for non-compliance with the UAE Electronic Invoicing System (EIS). The decision applies from the mandatory go-live dates for each business wave.
Penalties are enforced by the Federal Tax Authority (FTA). All official documentation is available at mof.gov.ae.
Full Penalty Schedule
1. Failure to Implement the E-Invoicing System or Appoint an ASP
Fine: AED 5,000 per month (or part thereof)
This is the largest and most common fine. If your business has not implemented e-invoicing or appointed an Accredited Service Provider by your mandatory deadline, you are fined AED 5,000 for every calendar month you remain non-compliant.
A business that misses its January 2027 deadline and only complies in April 2027 faces AED 15,000 in penalties (three months × AED 5,000).
2. Late Transmission of E-Invoices
Fine: AED 100 per invoice, capped at AED 5,000 per month
If your system is operational but invoices are transmitted late — outside the permitted window after issuance — you are fined AED 100 per late invoice. The monthly cap is AED 5,000, meaning the fine does not compound indefinitely. But persistent latency will still cost you every month.
3. Failure to Report an E-Invoicing System Malfunction
Fine: AED 1,000 per day
If your e-invoicing system or your ASP connection goes down and you fail to report the malfunction to the FTA within the required timeframe, you face AED 1,000 per day until the fault is reported.
4. Failure to Notify Your ASP of Data Changes
Fine: AED 1,000 per day
If you change registered data — business name, TRN, address — and fail to inform your ASP, AED 1,000 per day applies until notification is made.
Penalty Summary Table
| Violation | Fine | |---|---| | No EIS implementation / no ASP appointed | AED 5,000 per month | | Late invoice transmission | AED 100 per invoice (max AED 5,000/month) | | Failure to report system malfunction | AED 1,000 per day | | Failure to notify ASP of data changes | AED 1,000 per day |
Who Is Exempt from Penalties?
Businesses that voluntarily adopt e-invoicing before their mandatory wave date are not subject to penalties during the pilot phase (from 1 July 2026). This exemption only applies during the voluntary period — once your mandatory deadline passes, all penalties under Cabinet Decision 106/2025 apply in full.
How to Avoid All Four Fines
- Appoint an ASP before your deadline — Wave 1: 30 October 2026; Wave 2: 31 March 2027
- Ensure real-time transmission — Do not batch invoices; transmit at the point of issuance
- Set up system malfunction alerts — Your accounting software should notify you of ASP connection failures immediately
- Keep your ASP data current — Update TRN, address, and business name changes promptly
Pyalm Books Handles All Four Compliance Areas
Pyalm Books manages ASP connectivity, real-time invoice transmission, system status monitoring, and business data sync — so none of the four fine triggers apply to your business.
Start with Pyalm Books | Cabinet Decision 106/2025 — Official MoF Source