BLOGS

October 01, 2026

UAE Tax & Regulatory Update: September 2026

September was one of the busiest months for UAE regulatory output we’ve seen this year. Several updates came into effect immediately, others set deadlines that are now weeks away, and one piece of genuinely good news arrived for smaller businesses.

This is our monthly look back at what happened in September, what it means, and what you should be doing about it now.

The Big One: FTA Decision No. 13: Supplier Verification Before Input VAT

If there is one update from September that every VAT-registered business in the UAE needs to have properly absorbed, it is this one.

FTA Decision No. 13 of 2026 came into effect on 1 October. From this point forward, a valid tax invoice is no longer sufficient on its own to recover input VAT. Businesses must now verify the validity and integrity of their suppliers and their individual supplies before deducting input tax.

The UAE’s VAT system can be abused through false invoices, undeclared sales, and fictitious supplier relationships. Decision 13 is the FTA’s formal response, shifting some of the responsibility for supply chain integrity onto the buyer. It mirrors approaches already in place in other jurisdictions, but the UAE version is more detailed and more extensive than most.

The key thresholds:

Under AED 10,000 per supply: generally exempt from detailed verification, unless your total annual spend with that supplier exceeds AED 100,000. Once you cross that threshold with a supplier, the exemption disappears entirely for every invoice from them, however small.

Above AED 100,000 per supplier annually: full verification required. Identity documents. Place of business confirmation. Risk indicator assessment. And all of this must be refreshed every 12 months.

Above AED 375,000 per supplier annually: everything above, plus a written confirmation from a UAE bank that the supplier holds an account, and a documented review of their publicly available reputation.

Beyond the supplier checks, there are supply-level checks too, commercial rationale, pricing, licensed activity, and payment method, that apply to every individual invoice above the applicable threshold.

And one non-negotiable that applied from day one: every business must have a written policy in place, under Article 5(4) of the Decision, naming who implements, reviews, and supervises the verification process. It doesn’t get filed with the FTA. But if it doesn’t exist, that is itself a compliance failure.

We ran a webinar on this in September, the recording is on our YouTube channel and walks through exactly what you need to have in place: run your 12-month purchase report by supplier, identify who sits above AED 100,000 and AED 375,000, build the verification files, and make sure your policy document exists.

E-Invoicing: The Clock Is Now Running

The e-invoicing ASP appointment deadline, 30 October 2026,  is 29 days away as we write this.

For businesses above AED 50 million in annual revenue, that is the confirmed deadline to appoint an Accredited Service Provider through the MRI tax portal. The go-live date of 1 January 2027 has not changed and will not change.

Appointing your ASP is not the hard part. Everything that needs to happen between appointment and go-live: data remediation, system integration, workflow redesign, end-to-end testing takes time that the window between 30 October and 1 January does not generously provide.

The businesses that will go live smoothly in January are the ones who started their data assessment and ASP evaluation months ago. If that isn’t where you are, you are not yet in a position where speed alone fixes the problem. You need the right support.

If you are above the revenue threshold and have not yet begun your readiness programme, contact us this week. We have been working through e-invoicing implementations with UAE businesses all year. We know where the time goes and where the problems hide.

Small Business Relief Extended to 31 December 2029

The welcome news from September: Ministerial Decision No. 131 of 2026 extends the Small Business Relief threshold to 31 December 2029.

Eligible UAE resident businesses with gross revenue of AED 3 million or less continue to benefit from 0% Corporate Tax and are exempt from transfer pricing documentation requirements throughout the relief period.

Three more years of significantly simplified Corporate Tax compliance for qualifying businesses: more time, more headroom, more focus on growth.

Two things we always remind clients about SBR:

It must be actively elected in your Corporate Tax return each period. It is not applied automatically. If you have not elected it and you qualify, you have been leaving a benefit unclaimed.

And eligibility must be assessed properly. Businesses that are part of a multinational enterprise group or a UAE large business group do not qualify, regardless of their own revenue. If you have not formally reviewed your eligibility, do that now, particularly given the extension makes this benefit worth claiming correctly for the next three years.

Top-Up Tax: New Registration Deadlines and Guides

September brought important formalisation of the registration and deregistration framework for the Qualified Domestic Minimum Top-up Tax, through FTA Decision No. 12 of 2026.

For MNE groups with annual consolidated revenues of EUR 750 million or more, the registration deadline for entities with fiscal years ending before 30 April 2026 is 30 November 2026. That is eight weeks away. The FTA also published two new substantive guides in September, one on excluded entities and investment entities, one on scope and registration, both of which should form part of any MNE group’s compliance assessment.

Deregistration obligations have also been clarified. Entities that ceased to exist before 30 June 2026 must deregister by 31 December 2026. Where a Domestic Designated Filing Entity is appointed, it carries the responsibility for all registrations and notifications on behalf of group members.

If your group is in scope and you have not yet completed your registration assessment, November 30 is not far away.

Record-Keeping Rules: Already In Effect

FTA Decision No. 4 of 2026 has been in effect since 30 July, but September is a good moment to make sure your business has genuinely reviewed its document management practices against the new requirements, not just noted that the decision exists.

The specific points that catch businesses out: partial document scanning is explicitly prohibited. Every document must be retained in full, in original page order, and be clearly legible. The FTA must be granted access to all records on request, including passwords and encryption keys for electronic systems. And using a third-party provider to manage your records does not transfer the legal compliance responsibility; it remains with you.

If your record-keeping processes have not been reviewed against these requirements, that review is overdue.

What to Focus on in October

The first week of October should look like this for most UAE finance teams:

If you are above AED 50 million in revenue and your e-invoicing programme is not yet underway, make that call today. The 30 October appointment deadline is the first milestone; the real work starts the moment you appoint, and the clock to January begins properly.

If you are VAT-registered and have not yet run your supplier purchase analysis for Decision 13, do that this week. The decision is live. Build your verification files starting with your highest-spend suppliers.

If you are part of an MNE group within Top-up Tax scope, confirm your registration timeline against the 30 November deadline and review the new FTA guides.

If your business qualifies for Small Business Relief and you have not been formally electing it, speak to your accountant about correcting that and confirming you remain eligible under the extended framework.

At Nishe, we are working alongside UAE businesses on all of this not as advisors handing over reports, but as a team that gets into the detail alongside you.

If your Q4 compliance calendar feels like it is carrying more than one team can manage, we would love to have a conversation about how we can help.

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