UAE VAT records: what the law requires you to keep
Article 78 of Federal Decree-Law No. 8 of 2017 on Value Added Tax lists the records a Taxable Person must keep [1]:
- records of all supplies and imports of goods and services;
- all tax invoices, and alternative documents, received and issued;
- all tax credit notes, and alternative documents, received and issued;
- records of goods and services disposed of or used for non-business purposes, with the tax paid on them;
- records of purchases on which input tax was not deducted;
- records of exported goods and services;
- records of adjustments or corrections to accounts or tax invoices;
- records of supplies made or received under the reverse charge, with the related declarations;
- a Tax Record showing VAT due on taxable supplies, VAT due under the reverse charge on imports, VAT due after corrections, recoverable tax, and recoverable tax after corrections.
A business must also keep a Capital Asset register [2], and to recover input tax it must hold the tax invoice, or for imported goods the invoices and import documents [1].
How long to keep VAT records
| Record | Minimum retention | Source |
|---|---|---|
| Records of a Taxable Person | 5 years following the Tax Period they relate to | TP Executive Regulation, Art. 3(1)(a) [3] |
| Records of a person who is not a Taxable Person | 5 years from the end of the calendar year the document was created | Art. 3(1)(b) [3] |
| Real estate records | 7 years from the end of the calendar year the document was created | Art. 3(1)(c) [3] |
| Capital Asset records | At least 10 years | VAT Law, Art. 60(2) [1] |
| E-invoices and e-credit notes | The period set by the Tax Procedures Law | MD 243 of 2025, Art. 11, as amended [9][10] |
| Dispute, ongoing audit or notified audit | An extra 4 years (for a dispute, until it is settled if later) | Art. 3(2)(a)–(c) [3] |
| Voluntary disclosure made in the fifth year | An extra 1 year from submission | Art. 3(2)(d) [3] |
| Refund claim submitted before the limitation period expires, not yet decided by the FTA | An extra 2 years | TP Executive Regulation as amended from 1 April 2026 [13] |
The Ministry of Finance’s June 2026 e-invoicing guidelines restate the five-year, real estate, dispute and voluntary disclosure periods [11]. Corporate Tax records follow a longer seven-year rule; see our guide to UAE corporate tax record-keeping, which also covers the rules on electronic copies and record language that apply to VAT as well.
UAE tax invoice requirements and credit notes
A registrant making a taxable supply issues a tax invoice within 14 days from the date of supply [1]. A full tax invoice must show [2]:
- the words “Tax Invoice”;
- the supplier’s name, address and Tax Registration Number (TRN);
- the recipient’s name, address and TRN, where the recipient is registered;
- a sequential or unique invoice number;
- the date of issue, and the date of supply if different;
- a description of the goods or services;
- for each line, the unit price, quantity, tax rate and amount payable in AED;
- any discount;
- the gross amount payable in AED;
- the tax charged in AED, with the exchange rate where another currency is converted;
- where the recipient must account for the tax, a statement saying so and the legal provision.
A simplified tax invoice may be issued where the recipient is not a registrant, or is a registrant and the consideration does not exceed AED 10,000 [2]. It shows the words “Tax Invoice”, the supplier’s name, address and TRN, the date, a description, and the total consideration and tax in AED [2]. No tax invoice is required for a wholly zero-rated supply [2].
A tax credit note is issued when output tax is reduced [1]. It must show the words “Tax Credit Note”, the supplier’s and (if registered) the recipient’s details and TRN, the date of issue, the original value, the corrected value, the difference and the tax on it in AED, a brief reason, and information that identifies the original supply [2].
Tax invoices may already be issued electronically, provided a copy is stored securely under the record-keeping rules and the authenticity of origin and integrity of content are guaranteed [2].
VAT return deadline and voluntary disclosure
The standard Tax Period is three calendar months, although the FTA can assign a shorter or longer period [2]. The return must be received by the FTA no later than the 28th day after the end of the Tax Period, and the tax payable must reach the FTA by the same date [2].
If a return understated the tax payable, the Tax Procedures Law requires a voluntary disclosure [4]. Under the Executive Regulation as issued in 2023, an error above AED 10,000 is disclosed within 20 business days of becoming aware of it, while an error of AED 10,000 or less can be corrected in a later return [3]. Amendments in force from 1 April 2026 clarified the voluntary disclosure procedures [13], so check the current consolidated text on tax.gov.ae before correcting an error.
UAE e-invoicing: confirmed timeline as of October 2026
The Ministry of Finance defines an e-invoice as structured invoice data issued, exchanged and reported electronically; PDFs, scans, images and emails are not e-invoices [5]. Invoices pass through Accredited Service Providers (ASPs), which report tax data to the FTA [5]. Business-to-business and business-to-government transactions are in scope; supplies to natural persons who are not in business are not [11].
| Who | Appoint an ASP by | Implement by | Source |
|---|---|---|---|
| Voluntary adopters (any size) and pilot participants | — | From 1 July 2026 | [7][11] |
| Revenue of AED 50 million or more | 30 October 2026 | 1 January 2027 | [8] |
| Revenue below AED 50 million | 31 March 2027 | 1 July 2027 | [7] |
| Government entities | 31 March 2027 | 1 October 2027 | [7] |
Revenue means gross income in the most recent accounting period [7]. Ministerial Resolution No. 66 of 2026 moved the ASP appointment date for the AED 50 million group from 31 July 2026 to 30 October 2026 [8]; the Ministry’s guidelines V1.1 of June 2026 still show the earlier date [11].
From 1 October 2026, Ministerial Decision No. 197 of 2026 excludes transactions between members of the same Tax Group (VAT group) for 24 months from 1 January 2027, and removed the requirement to store e-invoices inside the UAE. E-invoices must still be kept for the Tax Procedures period and produced to the FTA on request [9][10]. Exempt and zero-rated financial services, and certain airline transactions, are also excluded [6][9].
How to reconcile UAE VAT before each return
This method is recommended professional practice, not regulation. Run it monthly, even if you file quarterly, while documents are easy to trace.
- Close the period. Post every invoice, credit note and supplier bill dated in the period.
- Sales VAT against revenue. Split the sales VAT report by treatment: standard-rated, zero-rated, exempt and out of scope. Standard-rated value times 5% should equal output VAT. Agree values to the revenue ledger and explain VAT-bearing items outside revenue, such as asset sales.
- Credit notes. Check each credit note issued identifies the original supply and states a reason [2], and that credit notes received reduce input VAT in the right period.
- Input VAT against purchases. Confirm each claim is supported by a tax invoice you hold [1]. Record non-recoverable input tax separately, because the law requires a record of it [1]. The FTA has also issued Decision No. 13 of 2026 on measures for verifying the validity and integrity of supplies [12]; review it with your adviser.
- Imports, reverse charge and exports. Confirm each reverse charge appears as both VAT due and recoverable VAT where recovery is allowed, match imports to import documents, and keep export evidence with zero-rated sales [1].
- VAT control account. Roll the account forward: opening balance, plus output VAT, less input VAT, plus or minus adjustments, less payments to the FTA. The closing balance should equal the return figure, or be explained line by line.
- Archive. File the reconciliation, the return and the payment receipt together.
Worked example: one quarter
| Check | VAT report (AED) | General ledger (AED) | Difference | Explanation |
|---|---|---|---|---|
| Standard-rated sales, net of credit notes | 2,390,000 | Revenue 2,360,000 | 30,000 | Vehicle sold, booked to fixed asset disposals |
| Output VAT | 119,500 | Output VAT account 119,500 | 0 | Agrees |
| Reverse charge on imported services of 200,000 | 10,000 due, 10,000 recoverable | 10,000 / 10,000 | 0 | Both sides posted |
| Input VAT claimed | 46,000 | Input VAT account 47,250 | 1,250 | Supplier bill of 25,000 received without a valid tax invoice; VAT held until one arrives |
The return shows net VAT payable of 119,500 + 10,000 − 10,000 − 46,000 = AED 73,500. The ledger shows AED 72,250. The AED 1,250 difference is the held input VAT, which the team moves to a separate “input VAT pending invoice” account so the ledger agrees with the return.
VAT reconciliation checklist
Sources
- Federal Decree-Law No. 8 of 2017 on Value Added Tax and its amendments (Articles 3, 48, 55, 60, 67, 70, 78) — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2025/07/Federal-Decree-Law-No.-8-of-2017-and-amendments.pdf (accessed October 2026)
- Cabinet Decision No. 52 of 2017 on the Executive Regulation of the VAT Law and its amendments (Articles 58, 59, 60, 62, 64) — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2025/10/Cabinet-Decision-No.-52-of-2017-of-the-Executive-Regulation-of-the-Federal-Decree-Law-No.-8-of-2017-on-Value-Added-Tax-and-its-amendments.pdf (accessed October 2026)
- Cabinet Decision No. 74 of 2023 on the Executive Regulation of Federal Decree-Law No. 28 of 2022 on Tax Procedures (Articles 3, 4, 10) — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2023/07/Cabinet-Decision-No-74-of-2023-On-Executive-Regulations-of-Federal-Decree-Law-No.-28-of-2023-Tax-Procedures-Law.pdf (accessed October 2026)
- Federal Decree-Law No. 28 of 2022 on Tax Procedures, as amended (Article 10) — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2025/07/Federal-Decree-Law-No.-28-of-2022.pdf (accessed October 2026)
- eInvoicing programme page — UAE Ministry of Finance — https://mof.gov.ae/einvoicing (accessed October 2026)
- Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2025/09/Ministerial-Decision-no.-243-of-2025-on-the-Electronic-Invoicing-System.pdf (accessed October 2026)
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2025/09/Ministerial-Decision-No.-244-of-2025-on-the-Implementation-of-the-Electronic-Invoicing-System.pdf (accessed October 2026)
- Ministerial Resolution No. 66 of 2026 Amending Certain Provisions of Ministerial Resolution No. 244 of 2025 — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2026/05/Ministerial-Resolution-No.-66-of-2026-Amending-Certain-Provisions-of-Ministerial-Resolution-No.-244-of-2025-Regarding-the-Implementation-of-the-Electronic-Invoicing-System-En-20260514.pdf (accessed October 2026)
- Ministerial Decision No. 197 of 2026 Amending Certain Provisions of Ministerial Decision No. 243 of 2025 — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2026/10/Ministerial-Decision-No.-197-of-2026-–-Amending-Certain-Provisions-of-Ministerial-Decision-No.-243-of-2025-on-the-Electronic-Invoicing-System_En.pdf (accessed October 2026)
- Ministry of Finance Amends Electronic Invoicing Regulations to Ease the Burden on Businesses (19 October 2026) — UAE Ministry of Finance — https://mof.gov.ae/en/news/ministry-of-finance-amends-electronic-invoicing-regulations-to-ease-the-burden-on-businesses/ (accessed October 2026)
- UAE Electronic Invoicing Guidelines, Version 1.1 (1 June 2026) — UAE Ministry of Finance — https://mof.gov.ae/wp-content/uploads/2026/06/UAE-Electronic-Invoicing-Guidelines_V-1.1-01June2026.pdf (accessed October 2026)
- Legislation listing: FTA Decision No. 13 of 2026 on Measures, Procedures and Conditions Required by Taxable Persons for Verification of Validity and Integrity of Supplies — Federal Tax Authority — https://tax.gov.ae/en/legislation.aspx (accessed October 2026)
- Ministry of Finance announces amendments to Tax Procedures Executive Regulations effective April 2026 — UAE Ministry of Finance — https://mof.gov.ae/en/news/ministry-of-finance-announces-amendments-to-tax-procedures-executive-regulations-effective-april-2026/ (accessed October 2026)
This guide is general information based on official sources as of October 2026. Confirm your specific situation with the authority or a qualified adviser.