The UAE has published Cabinet Decision No. 129 of 2025, setting out a unified administrative penalty framework for VAT and Excise Tax violations which will be effective from April 14, 2026. This comprehensive overhaul replaces the previous regime and introduces a more proportional, transparent, and business-friendly approach by aligning and simplifying enforcement across the Tax Procedures Law, VAT, Excise Tax, and Corporate Tax. The shift is focused on encouraging voluntary compliance, reducing fines for minor administrative missteps, and moving away from compounding penalties.

Key structural reforms include moving away from compounding penalties, setting a clear, fixed annualized rate of 14% for late tax payments, and implementing calibrated fixed penalties for Voluntary Disclosures. Additionally, the new framework standardizes definitions and reduces penalties for minor administrative missteps while strictly enforcing core obligations like timely payment and accurate invoicing to encourage early remediation of errors.

They table below includes an overview of the Key Amendments by Violation

What This Means for Your Business

The new framework is both an opportunity and an obligation. The opportunity lies in greater certainty: penalty calculations are simpler, and remediation through timely voluntary disclosures is expressly incentivised. The obligation is to use the transition window before 14 April 2026 to bring processes, systems, and controls up to standard.

To comply with the revised regime, businesses should take the following practical steps:

• Review Tax Governance: Assess the end-to-end tax governance model, focusing on the timeliness and accuracy of your VAT and Excise filings.
• Manage Cash Flow: Review cash management processes to ensure proper accruals are made for Payable Tax to avoid the new 14% annualized late payment penalty.
• E-Invoicing and Document Readiness: Verify that e-invoicing and document issuance workflows are ready to meet all statutory timeframes for tax invoices and credit notes.
• Voluntary Disclosure Strategy: Pay particular attention to the triggers for Voluntary Disclosures, ensuring you have robust documentation and audit trails to support any corrections.
• Prevent Error Compounding: Establish clear escalation paths and controls to ensure small errors are addressed quickly, preventing them from compounding into multi-month exposures.
• Complex Operations: For groups with complex supply chains or those operating within Designated Zones, the alignment of penalties across VAT and Excise requires a refreshed risk map and internal accountability model.

Why Engage Al Tamimi & Company

Navigating the new penalty framework requires more than technical awareness; it demands structured readiness. Al Tamimi & Company combines deep regulatory insight with pragmatic execution support across tax disputes, compliance reviews, and systems enablement. We can help you interpret the implications of Cabinet Decision No. 129 of 2025 for your specific operating model, design corrective action plans that stand up under audit, and prepare defensible positions where historical exposures exist.

Engaging early allows you to benchmark your current practices against the revised standards, quantify penalty risk, and implement targeted controls before the enforcement date. Whether you are refining your voluntary disclosure strategy, remediating invoice issuance processes, or stress‑testing cash‑flow impacts of the 14% annualised accrual on unpaid tax, Al Tamimi is positioned to support decisive, cost‑effective compliance.

For more information kindly contact, Shiraz Khan S.Khan@tamimi.com; Samer Qudah s.qudah@tamimi.com ; Anuj Bhasin A.Bhasin@tamimi.com; Sahid Daud S.Daud@tamimi.com ;  or any member of the Tax or Corporate Structuring teams