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Lesson 5 — Exclusions and penalties

Two questions people ask in the same breath: does this apply to me at all, and what does it cost if I am late?

Start with what sits outside. MD 243/2025 Art. 4 excludes these from the electronic invoicing system:

  • Government sovereign activities.
  • International airline passenger services issued with an electronic ticket.
  • Ancillary passenger services supplied by airlines.
  • International airline cargo, excluded for 24 months from implementation.
  • Financial services that are exempt from VAT or zero-rated.

Read that as a list of activities rather than a list of businesses — the exclusions attach to what is being supplied. And note that the cargo item carries its own clock: 24 months from implementation, after which it stops being excluded. Source: MD 243/2025 Art. 4.

B2C is out of scope for now, and "for now" is doing real work in that sentence. MD 244 Art. 5(2) keeps business-to-consumer transactions outside the system until a further Ministerial decision brings them in. Design your process so that adding B2C later is a configuration change rather than a second project. Source: MD 244/2025 Art. 5(2).

Now the cost of being late. Cabinet Decision 106 of 2025, issued in December 2025, sets the administrative penalties for the electronic invoicing system.

Failure Penalty
Failure to implement the system, or to appoint an ASP AED 5,000 for each month of delay
Failure to issue or transmit an e-invoice or e-credit note AED 100 per document, capped at AED 5,000 per month
Failure to notify a system failure, or a change in data AED 1,000 per day

The arithmetic, in three short cases. A Phase 1 business that appoints its provider three months late owes AED 15,000, being 3 × 5,000. A business that fails to transmit 80 documents in one month owes 80 × 100 = AED 8,000, capped at AED 5,000; the cap bites at 50 documents, so past fifty the monthly figure stops rising even though the underlying problem does not. A system failure left unreported for 12 days costs 12 × 1,000 = AED 12,000 — more than either of the others, from a notification nobody remembered to send. Source: Cabinet Decision 106/2025.

Voluntary adopters are excluded from these penalties. That is the strongest argument for joining early rather than waiting for your phase to arrive. A business that starts in the voluntary window learns the process, finds its data gaps and settles its provider integration with the penalty regime switched off. A business that starts on the first day of its own phase does all of that live.

The misreading to avoid is that an exclusion from e-invoicing is not an exclusion from anything else — not from VAT, not from record-keeping, not from Corporate Tax. A business supplying exempt financial services still carries every other obligation it carried last year. In the same spirit, "not yet dated" for Phase 4 means a date that has not been published, not a phase that will not happen.

The idea to carry forward: the cheapest month in which to make your mistakes is a month where penalties do not apply, and that window is open now.

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