A taxable person in the United Arab Emirates that receives a supply and intends to deduct the input tax on it will, from 1 October 2026, have to be able to show what it did to verify who the supplier was and whether the supply was real. The duty comes from Federal Tax Authority Decision No. 13 of 2026, issued on 22 July 2026 for the purposes of Article 54(bis) of the VAT Law, and it applies to the recipient of the supply rather than to the supplier. Two further decisions of the same summer, on accounting records and on seized goods, took effect earlier, on 30 July 2026.
Symbol Consulting reads the three together because they were issued within seven weeks of each other and published in the same section of the Federal Tax Authority portal, all in English versions carrying the notice that they are not official translations. The account below follows the order in which they were signed, and each date is quoted as the opening line of the instrument prints it.
2 June 2026: what an accounting record has to look like
Federal Tax Authority Decision No. 4 of 2026 sets the rules and requirements for maintaining the information contained in accounting records and commercial books. It was issued on 2 June 2026 and took effect on 30 July 2026, under Federal Decree-Law No. 28 of 2022 on Tax Procedures and Cabinet Decision No. 74 of 2023 (per the Value Added Tax legislation section of the Federal Tax Authority, as of 22 August 2026).
Its three base rules are short: records must be complete and identical to the original documents, clear and easily legible, and accessible to the Authority on request, including access to the system in which they are kept. The requirements that follow are where the operational detail sits.
An electronic copy or a photocopy must reproduce the original with all its pages in the same order, and partial scanning of any part of a document is not accepted. Quality and resolution must be sufficient for the data to be legible on a computer screen, and the ink and paper used must be such that the copy does not fade during the retention period. A non-coloured copy of a coloured document is permitted, provided the details remain clearly legible.
11 June 2026: what happens to goods the Authority seizes
Federal Tax Authority Decision No. 7 of 2026 covers procedures for the disposal of seized and abandoned goods. It was issued on 11 June 2026 and took effect on the same day as the previous one, 30 July 2026, and its scope is narrower than the title suggests (per FTA Decision No. 7 of 2026, as published by the Federal Tax Authority, as of 22 August 2026).
Its scope is narrower than the title suggests: it applies to seized or abandoned goods that are perishable, subject to shortage or leakage, or in a condition that might endanger the safety of other goods or of the facilities holding them. The storage and movement rules are written as duties on the Authority itself. Storage conditions must preserve condition, quality and quantity so that the goods can be returned to their owner if necessary or kept for valuation and sale. A stocktaking record is maintained before, during and after any move and reconciled against the actual inventory, and access records and periodic condition reports are kept.
Sale is possible only by decision of the Committee and only where all the stated conditions are met, including that the owner has failed to request retrieval after settling the full tax, administrative penalties and related expenses, or has exhausted or waived that right. The composition of that Committee is not set out in the decision itself.
22 July 2026: the check that has to happen before the deduction
Federal Tax Authority Decision No. 13 of 2026 is the one that changes daily practice. It states what a taxable person must do to verify the supplies it receives before deducting input tax, for the purposes of Article 54(bis) of the VAT Law. It was issued on 22 July 2026 and takes effect on 1 October 2026 (per FTA Decision No. 13 of 2026, as published by the Federal Tax Authority, as of 22 August 2026).
The supplier check has four layers. Identity comes first: for a natural person, a copy of a valid Emirates ID or passport and a meeting, in person or virtually, before the supply is made; for a legal person, verification of incorporation through official databases or a copy of the certificate, plus identification of the director, agent or employee authorised to represent it. Address is second: the existence of an actual place of business is verified by appropriate electronic means or by a field visit, and it must be compatible with the activities carried on.
The third layer is a risk test with three named indicators, and the fourth is a financial check that switches on at a threshold. The table sets both out as the decision states them.
| Check under Decision No. 13 of 2026 | What triggers it and what it requires |
|---|---|
| Address changes | Risk indicator where the supplier changed address more than twice in the previous 12 months |
| Key personnel changes | Risk indicator where key employees changed more than twice in the previous 12 months |
| Transaction pattern | Risk indicator where transactions are disproportionate or unexpected in volume, value or nature |
| Bank confirmation and reviews | Required where supplies from that supplier exceeded AED 375,000 over the previous 12 months or are expected to exceed AED 375,000 over the next 12 |
Where a risk indicator applies, the taxable person is not barred from the deduction but must retain a clear and justified explanation and submit it to the Authority on request, provided the indicators do not contradict the evidence available to it. The bank confirmation must be issued by an authorised bank in the State and must carry no relevant reservations or conditions, and it need not be addressed to the recipient of the supply.
The supply itself is checked separately under Article 4: a general assessment of the circumstances of the transaction, confirmation that the supplier’s engagement rests on genuine commercial reasons, and an assessment of whether the payment method and conditions are commercially justifiable. Article 5 adds a written policy setting out the procedures, powers and responsibilities, retained at the location designated for the required documents (per FTA Decision No. 13 of 2026, Articles 4 and 5, as of 22 August 2026).
Where the input tax verification exception stops working
Article 6 exempts a taxable person from all of the above for supplies where the consideration excluding value added tax is less than AED 10,000. The second clause of the same article withdraws that exemption where the total value of supplies received from that supplier exceeds AED 100,000 over the previous 12 months, or is expected to exceed it over the next 12.
Read together, the two clauses work at different levels. The first is a test on a single supply; the second is a test on the relationship with one supplier across a year. A stream of small purchases from the same supplier therefore leaves the exception behind on the aggregate, not on any individual invoice, and the moment it does so the full set of identity, address, risk and financial checks applies to that supplier.
What the three dates add up to
The sequence has a shape. Two decisions of June 2026 fixed how records are kept and how the Authority handles goods in its possession, and both started on 30 July 2026. The third, signed in July, does something different: it moves part of the verification burden onto the buyer and gives it until 1 October 2026 to have the process in place.
That leaves a narrow window for the work that the decision assumes has already been done — a written policy under Article 5, a way of recording meetings and identity documents, a method for spotting the three risk indicators, and a rule for when the AED 375,000 bank confirmation is obtained. None of that is retrospective, but none of it can be assembled after a deduction has been claimed either (per FTA Decision No. 13 of 2026, Article 7, as of 22 August 2026).
This material is a general analysis of published rules. It is not legal, tax, immigration or financial advice.