VAT Late Filing Penalty in the UAE

A penalty for lateness is only as certain as the deadline it hangs off, and three provisions decide that deadline.

Article 62(1) of the VAT Executive Regulation makes the standard tax period three calendar months, ending on the date the Authority determines. Article 62(2) lets the FTA assign a person or a class of persons a shorter or longer period where it considers that necessary or beneficial to reduce the risk of tax evasion, to improve its monitoring of compliance or collection, or to reduce the administrative or compliance burden. Article 62(3) lets a taxable person on the standard period ask that the period end with a month of their choosing, which the Authority may accept at its discretion.

Nothing in those three clauses ties the length of the period to turnover. This page therefore states no revenue threshold for monthly filing, although one is widely quoted: the criterion in the text is the Authority's judgement, not a number. The period you were actually assigned is the one recorded against your registration, and that record is the only reliable source for it.

Article 64(1) then requires the tax return to be received by the Authority no later than the 28th day following the end of the tax period concerned, or by such other date as directed by the Authority. That closing phrase carries more weight than it looks. It means a direction addressed to you displaces the general rule, and item 8 attaches to the timeframe the Tax Law actually set for you rather than to a date read off a generic calendar. Article 64(3) requires the payable tax to be received by the Authority by that same date.

Because a standard period ends at the end of a calendar month, the due date in practice is the 28th of the following month. Read strictly, though, the Regulation counts the 28th day following the end of the tax period rather than naming the 28th of a month, so a non-standard period ending mid-month does not produce a 28th-of-the-month deadline. Read in the consolidated Regulation on 17 August 2026.

Item 8 of Table 1 is short enough to quote in full. The violation is the "failure of the Registrant to submit the Tax Return within the timeframe specified in the Tax Law", and the penalty is "1,000 for the first time" and "2,000 in case of repetition within 24 months". That is the whole of it.

Item 7 charges the identical failure where a legal representative is the person obliged to file, at the same AED 1,000 and AED 2,000, with one difference that matters to the individual concerned: the penalty is due from the legal representative's own funds, not the taxable person's.

The drafting leaves one question open, and it is worth being explicit about rather than papering over. Items 1 and 5 of the same table state their anchor in terms — the higher amount applies to a repeated violation "within 24 months from the date of the last violation". Items 7 and 8 say only "in case of repetition within 24 months" and do not name the date the 24 months run from. On either reading the window is rolling rather than tied to a calendar year or a tax year, so a second late return two years and a day after the first is a first violation again, while one eleven months later is not. What the text does not settle is whether the clock starts at the last violation or at the last penalty, and no FTA guidance resolving it could be found.

One date carries two obligations. Article 64(1) is about the return arriving; Article 64(3) is about the money arriving. Item 8 prices a breach of the first and item 9 prices a breach of the second, and neither absorbs the other.

The practical conclusion is blunt. If you are going to miss something, miss the payment rather than the return. A return filed on time with the tax unpaid attracts no item 8 penalty at all and leaves you with a charge that is at least computed on a known amount. A return not filed leaves the Authority with no figure to apply a payment against, adds the flat penalty, and opens the period to an assessment.

One thing this page will not do is convert 14% per annum into a monthly percentage. Item 9 fixes an annual rate and monthly charging dates; it does not fix the apportionment, and neither the Cabinet nor the FTA has published a worked calculation choosing between twelfths, daily accrual, or a part month treated as a whole month. Dividing 14 by 12 is arithmetic, not law. The assessed figure on the EmaraTax ledger is the authoritative one.

Item 8 is drafted against the act of not submitting. It says nothing about how much tax was due, and it does not carve out a period in which nothing happened. A dormant company with no supplies in the quarter still owes a return, and filing that return a day late costs the same AED 1,000 as filing one with a large output tax figure on it.

The same holds in the opposite direction. Article 64(4) of the Executive Regulation expressly contemplates a period in which recoverable tax exceeds due tax, with the excess repayable to the taxable person. A return in a refund position — one where the Authority ends up owing you money — is still a tax return for the purposes of item 8, and filing it late attracts the same flat penalty as any other.

Two consequences follow. First, it is registration rather than activity that creates the obligation: for as long as the registration is live, every assigned tax period produces a return whether or not anything was supplied in it. Second, if there is genuinely nothing left to report, the correct response is to apply to deregister rather than to quietly stop filing — and the deregistration application carries its own penalty for being late, dealt with below. Stopping filing without deregistering converts a fixed AED 1,000 per return into an open-ended sequence of them.

This is the part that the AED 1,000 headline hides, and it is the reason a long-overdue return is a bigger problem than a late one.

Article 23(1)(b) of Federal Decree-Law No. 28 of 2022 says the Authority shall issue a tax assessment where a registrant fails to submit a tax return within the timeframe specified by the Tax Law, and shall notify the taxpayer within 10 business days of its issuance. Article 23(2) then covers the case the flat penalty does not: where it is not possible to determine the actual amount of due tax, or the correctness of the return, the Authority may issue an estimated tax assessment. If new relevant information later surfaces that affects it, the Authority must amend the estimate and notify the person within 10 business days of the amendment.

An estimate is the Authority's figure, not yours. The input tax you would have recovered in the missing return is not in it unless the Authority has a basis for putting it there, so the assessed amount can exceed what an on-time return would have produced — and it then carries its own payment clock of 20 business days from receipt under item 9(2). Administrative penalties travel alongside it: Article 24 requires the Authority to issue an administrative penalties assessment and notify the person within 5 business days for the violations it lists.

Time does not quietly solve this either. Article 46(1) gives the Authority five years from the end of the relevant tax period to audit or assess, but Article 46(8) extends that to fifteen years from the date a person should have registered where the failure is a registration failure, and Article 46(7) gives fifteen years for tax evasion.

Searches for a late amendment penalty are looking for something the schedule does not contain. No item in Table 1 or Table 3 is titled that, and item 8 is not it: item 8 prices a return that never arrived on time, not a return that arrived and was later changed.

A submitted VAT return is not simply edited. The mechanism for changing one is a voluntary disclosure, and what the schedule prices is the disclosure and the error inside it rather than the delay in getting to it. Three items do the work. Item 10 charges AED 500 for an incorrect return, with exactly two escapes in the text: correcting it within the deadline for submitting that return, or a disclosure that produces no difference in the due tax. Item 11 charges 1% of the tax difference for each month or part thereof. Item 12 applies where you did not disclose before the Authority notified you of an audit, and adds a fixed 15% of the tax difference on top of that same 1% a month.

So the delay does have a price — it is 1% of the difference a month, not a flat fee — and the far larger variable is who found the error first. The timing obligation itself sits in Article 10 of the Tax Procedures Law and Article 10 of Cabinet Decision No. 74 of 2023: where an error understates payable tax by more than AED 10,000, a voluntary disclosure is due within 20 business days of becoming aware of it; at or below AED 10,000, the correction goes into the next return that has not yet fallen due. Article 46(6) bars a voluntary disclosure altogether more than five years after the end of the relevant tax period, subject to a narrow exception for a disclosure connected to a refund application the Authority has not yet decided.

Deregistration sits in this cluster of searches for a reason: people who stopped trading discover the filing penalty and the deregistration penalty at the same moment, usually months later.

The deregistration charge is item 4, and it behaves differently from item 8. It is AED 1,000 on late submission of the deregistration application and the same amount on the same date monthly thereafter, up to a maximum of AED 10,000 — the only fixed-amount VAT penalty in Table 1 that compounds. Ten months of inattention reaches the whole ceiling. The trigger, the 20 business days allowed by the Executive Regulation, and the interaction with the Authority's own power to deregister are set out in full on the penalty schedule page rather than repeated here.

What belongs here is the part that catches people after the application goes in. Article 64(2) of the Executive Regulation requires a person whose registration has been cancelled to provide a final tax return for the last tax period for which they were registered. That final return is a tax return like any other: it carries the same deadline and the same item 8 penalty for being late. And the periods between the event that triggered deregistration and the date the registration is actually cancelled are ordinary tax periods, each producing its own return. A single late deregistration can therefore generate the monthly item 4 charge, ordinary item 8 penalties for the returns in the gap, and a further item 8 penalty on the final return itself.

A refusal is more useful than a plausible figure when someone is about to file on the strength of it.

• A monthly percentage for the late-payment charge. Item 9 states 14% per annum and charges it for each month or part thereof. The apportionment is not published by the Cabinet or the FTA, so dividing 14 by 12 would be an inference dressed as a statutory rate.
• A turnover threshold for monthly VAT periods. Article 62 gives the Authority a discretion and states no revenue figure. The assigned period is the one on your own registration record.
• The date the 24-month repeat window runs from for item 8. Items 1 and 5 name their anchor; items 7 and 8 do not, and no guidance settling it could be found.
• The Article 24(4) two-times ceiling as an applied cap. The Tax Procedures Law says an administrative penalty shall not exceed two times the tax the administrative penalties assessment was issued in respect of, but the text does not resolve whether that operates penalty by penalty or across an assessment. It is an outer boundary to argue, not a cap to rely on.
• Which rate applies to months either side of 14 April 2026. Cabinet Decision No. 129 of 2025 states an effective date and rewrites the tables. No transitional provision for a charge that straddles the change appears in the consolidated text.
• Your own exposure, any success rate, or any fee. Penalties are assessed by the Authority on the EmaraTax ledger and that ledger is the only authoritative figure. No case studies, statistics or prices are published by this firm, and none are invented here.

One defect in the primary text is worth flagging because it looks like a mistake in any page that quotes it. Article 5 of Cabinet Decision No. 40 of 2017 still directs a person objecting to an administrative penalty to the procedures in Federal Law No. 7 of 2017 on Tax Procedures, a law repealed by Article 55 of Federal Decree-Law No. 28 of 2022. Cabinet Decision No. 129 of 2025 rewrote the tables and left that cross-reference untouched.