UAE eInvoicing deadlines and penalties clarified

Welcome to this issue of UAE Law Watch, covering the past fortnight from 2026-10-20 to 2026-11-02. This edition focuses on practical changes for businesses, regulated firms, employers, families and property owners across the UAE.

Business & Tax

First UAE e-Invoicing deadline has arrived for AED 50 million businesses

The Federal Tax Authority called on persons subject to the UAE e-Invoicing System to comply with the legal requirements and phased implementation timelines. Persons with annual revenues equal to or exceeding AED 50 million must appoint an Accredited Service Provider by 30 October 2026 and implement the e-Invoicing System by 1 January 2027. Persons below the AED 50 million revenue threshold must appoint an Accredited Service Provider by 31 March 2027 and implement the system by 1 July 2027. The FTA also confirmed that an administrative penalty of AED 5,000 applies for each month or part-month of delay in implementing the system, including failure to appoint an Accredited Service Provider within the prescribed deadline.

What this means for you: Businesses should urgently confirm their revenue threshold, provider appointment and implementation timetable, rather than treating e-Invoicing as a later 2027 issue.

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Ministry of Finance eases some eInvoicing rules for tax groups and data storage

The Ministry of Finance announced Ministerial Decision No. 197 of 2026, amending Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. The amendments create a temporary 24-month exclusion, from 1 January 2027, for business transactions between persons that are members of the same tax group. The decision also amends the data-retention rule so that electronic invoices, electronic credit notes and associated data must be retained for the period prescribed under the Tax Procedures Law and be available to the Federal Tax Authority on request, while removing the previous requirement to store that data within the UAE. It also repeals the “system failure” provisions, including the requirement to notify the FTA within two business days of a system failure; the Ministry states that the decision became effective on 1 October 2026.

What this means for you: Groups using UAE tax-group structures should revisit implementation plans, data-hosting arrangements and internal eInvoicing procedures.

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Dubai to introduce digital authorisations for low-risk government services

Dubai’s Executive Council approved a new Digital Authorisation System for individuals and companies, to be developed and operated by Digital Dubai. The system will allow users to authorise others digitally to complete government transactions on their behalf, but only within low-risk services that do not require notary public or legal attestation procedures. The announcement states that the system will use UAE PASS for verification, integrate with digital applications and service channels, and provide a real-time, paperless mechanism to create, manage and activate authorisations. The same Executive Council meeting also approved the Urban Centres Development Plan and the Sustainable Population Planning Policy.

What this means for you: The system may reduce the need for notarised powers of attorney for routine administrative steps, but it will not replace notarisation where legal attestation is still required.

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Financial Centres & Regulation

Central Bank imposes AED 200 million penalty on UAE branch of foreign bank

The Central Bank of the UAE imposed an AED 200 million financial penalty on a UAE branch of a foreign bank under the Federal Decree-Law Regarding the Central Bank and Organisation of Financial Institutions and Activities. The penalty followed examinations that identified significant and repeated failures in AML/CFT, governance, compliance management and sanctions controls. The CBUAE also imposed individual penalties of AED 500,000 on the Chief Executive Officer and AED 300,000 on the Head of Compliance and Money Laundering Reporting Officer. The bank must implement a mandatory remediation programme subject to independent validation, and the CEO and Chief Compliance Officer must undergo fit-and-proper reassessment.

What this means for you: Regulated businesses should treat AML, sanctions governance, independent testing and remediation evidence as board-level priorities, with personal accountability for senior management.

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DFSA warns of crypto recovery scam impersonating the regulator

The Dubai Financial Services Authority issued an alert warning the public and the financial services community about a cryptocurrency recovery scam impersonating the DFSA. The scammers used fabricated documents titled “Notice of Investigation” and “Investigation Report”, including the DFSA’s name, logo, address and website, and falsely claimed that the regulator had traced and seized 0.7 Bitcoin from a cold wallet. The alert states that the scammers directed recipients to communicate through a Gmail address and a North American WhatsApp telephone number, which are not official DFSA contact details. The DFSA emphasised that it does not use free email accounts for official business, does not ask recipients to communicate through foreign WhatsApp numbers, and that any claim that cryptoassets have been traced, seized or recovered by the DFSA should be verified independently through official DFSA channels.

What this means for you: Anyone approached by a supposed regulator or recovery agent should verify the communication through official channels before sharing information or making any payment.

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Visas & Residency

Dubai tourist-visa applications to be available through Visit Dubai in November 2026

Sheikh Hamdan bin Mohammed announced two tourism-sector initiatives, including integration of tourist-visa applications into Visit Dubai, the city’s official tourism website. The announcement states that, during November 2026, Visit Dubai will offer applications for single-entry and multiple-entry tourist visas, with further visa categories planned later. The initiative is being implemented by GDRFA Dubai, the Department of Economy and Tourism and Digital Dubai under the Shared Digital Channels Initiative. GDRFA Dubai remains responsible for assessing applications and issuing visas, and further service details are still to be announced.

What this means for you: This is a new application channel, not a change in visa eligibility, so applicants should still treat GDRFA Dubai as the decision-maker.

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Employment

Upgraded Wage Protection System adds seven more financial institutions

The Ministry of Human Resources and Emiratisation, with the Central Bank of the UAE and Al Etihad Payments, announced further rollout of the upgraded Wage Protection System. The system enables employers to manage salary payments digitally through secure APIs, replacing paper-based registration and supporting real-time data exchange between MoHRE and participating financial institutions. Seven additional institutions — First Abu Dhabi Bank, Emirates NBD, Dubai Islamic Bank, Mashreq Bank, Ajman Bank, Lari Exchange and First Gulf Exchange Centre — are being added, bringing the total number of partners to 17. The announcement states that the WPS covers more than 99% of private-sector workers and processes average monthly wage transfers of AED37 billion.

What this means for you: Employers should ensure their payroll processes use authorised channels and maintain accurate WPS records, which are also important evidence in salary and maintenance disputes.

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Family & Personal Matters

Abu Dhabi court uses AED 300,000 conditional fine to secure child’s return

An Abu Dhabi court imposed a conditional AED 300,000 fine on a mother who failed to return her four-year-old daughter to the UAE after an authorised trip to the Philippines. The judgment gives the mother three months to bring the child back; if the child is not returned by 20 January 2027, the father may apply to remove the mother from the joint-custody arrangement and seek sole custody. The report states that the fine ceases to have effect once the child returns, indicating that the measure is directed at compliance rather than punishment alone. The court also took account of repeated breaches of custody orders, including a prior AED 80,000 fine that was reportedly upheld on appeal.

What this means for you: Parents should ensure travel permissions, return dates and custody terms are clear and documented before a child leaves the UAE.

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Dubai court orders ex-husband to reimburse AED 828,000 for jointly registered property

The Dubai Real Estate Court ordered a man to pay AED 828,000 to his former wife, plus 5% annual interest from the date of the claim until full payment, after she proved that she had funded instalments and registration fees for a property registered equally in both spouses’ names. The report states that the couple purchased the residential unit in November 2024, but the wife paid more than AED 1.6 million from her personal account, including instalments and registration fees, with no evidence that the husband had contributed. The court relied on bank statements, transfer notices and the property account statement, and treated the husband’s half-share of the payments as an amount acquired without legitimate legal basis. The court found the claim for future instalments premature and did not need to consider the alternative request to amend the property registration because the reimbursement claim succeeded.

What this means for you: Former spouses in property disputes should preserve bank records, developer statements and transfer evidence showing who actually paid.

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Property & Real Estate

Dubai court orders AED 1.95 million award in The Heart of Europe property dispute

Gulf News reported that a Dubai court ordered a real estate developer to refund AED 1,805,040 to a buyer in relation to a unit in The Heart of Europe phase two after finding that the developer failed to complete the sale and register the property. The court rescinded the agreement, ordered repayment with 5% annual interest from the date of the judicial claim until full payment, and awarded AED 150,000 in compensation for loss of investment benefit. The court noted that the building was already complete and that the case was not being treated as an off-plan unit at the relevant stage. It rejected the buyer’s additional claim for 10% expected appreciation because that alleged increase was not established through expert evidence.

What this means for you: Buyers claiming more than refund and interest should be ready to prove investment loss or appreciation with clear expert evidence.

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