---
title: UAE VAT Input Tax Due Diligence Enters a New Era
description: FTA Decision No 13 of 2026 introduces new UAE VAT supplier verification requirements. Understand the impact on input tax recovery.
---

[Insights](https://varri.com/insights)

# [UAE VAT Input Tax Due Diligence Enters a New Era](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era)

 Written by [Johnny Kollin](https://varri.com/insights/author/johnny-kollin) | 28 September 2026, 20:36:03 Z

*From 1 October 2026, UAE businesses claiming input value-added tax (VAT) must undertake and document prescribed checks on suppliers and supplies before deducting input VAT. The new regime extends VAT control beyond invoice validation and into procurement, contracting, privacy, and audit defence.*

## Executive summary

- [Federal Tax Authority (FTA) Decision No 13 of 2026](https://tax.gov.ae/en/content/fta.decision.no.13.of.2026.on.measures.procedures.conditions.required.by.taxable.persons.for.verification.of.validity.and.integrity.of.supplies.aspx) (the ‘Decision’) introduces a structured verification regime that affects procurement, accounts payable, contracting, third-party risk management, data protection, and tax controversy. [\[1\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn1)
- The change comes amid a broader modernisation of UAE tax administration, including the updated Executive Regulation of the UAE VAT Law, several recently issued VAT directives and decisions, and the development of its electronic invoicing framework under Ministerial Decisions Nos. 243 and 244 of 2025.[\[2\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn2)
- The Decision applies for the purposes of Article 54(bis) of the UAE VAT Law and takes effect on 1 October 2026.
- It requires verification of both the supplier and each taxable supply received, subject to limited thresholds and exceptions.
- Supplier verification must occur on first dealing and again where the supplier has not been verified during the preceding 12 months. Each taxable supply must be assessed separately.
- Businesses must document their work, retain supporting evidence, and maintain a policy allocating implementation, review, and supervision responsibilities.
- The Decision sets out several judgement-based standards but provides no express safe harbour. Compliance should therefore be designed around contemporaneous evidence, reasoned decisions, and effective escalation.
- Collecting identification documents and authorised representative information also requires consideration of applicable UAE data protection requirements and, depending on the processing arrangements, the laws of other relevant jurisdictions.

## From invoice validation to substantive verification

Historically, the UAE VAT recovery framework focused primarily on compliance with the statutory requirements in Articles 54 and 55 of the UAE VAT Law,[\[3\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn3) and the corresponding provisions of the Executive Regulations.[\[4\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn4) In practice, this typically involved validating tax invoices, confirming the VAT registration details shown on them, and demonstrating that the relevant expenditure was incurred for taxable business activities and met the conditions for input tax recovery. While those checks remain relevant, additional obligations now require examining the commercial integrity of the supplier and the supply.[\[5\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn5)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn5>From 1 October 2026, a UAE taxable person must, subject to applicable thresholds and exemptions, verify the supplier’s identity, incorporation, authorised representatives, place of business, business activities, and prescribed risk indicators. The taxable person must also assess the relevant supply, including whether there are genuine commercial reasons for the transaction, the commercial justification for payment arrangements, the reasonableness of pricing and profit margins, whether the supply falls within the supplier’s ordinary or licensed activities, and, where relevant, the authenticity, origin and ownership of goods, as well as the commercial rationale for any intermediary involved in the transaction. [\[6\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn6)

The stipulated verification measures and conditions do not constitute a comprehensive financial-crime customer due diligence regime, nor does the Decision impose anti-money laundering and countering the financing of terrorism (AML/CFT) obligations. Nevertheless, several of the required controls are conceptually similar to those used in formal supplier due diligence and third-party risk management frameworks, including verifying identity and business operations, reviewing publicly available information, assessing unusual transactions, and periodically updating supplier information.

As a result, retaining a valid tax invoice alone is no longer sufficient. Taxable persons must also be able to demonstrate the checks performed, the information reviewed, the identification of any prescribed risk indicators, and the assessment and documentation of any concerns.

## What the Decision requires

### Supplier identity

Where the supplier is a natural person, the taxable person must obtain valid identity evidence, such as an Emirates ID or a passport, and meet the supplier in person or virtually before the supply.[\[7\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn7)

Where the supplier is a legal person, the taxable person must verify the supplier’s incorporation using official databases or by obtaining an incorporation certificate. The supplier’s name, address, employees, and related information must match the incorporation details. [\[8\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn8) The identity of the director, agent, or employee authorised to represent the supplier must also be verified. [\[9\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn9)

A registration certificate alone may not satisfy the full requirement. The Decision requires a comparison of formal corporate information with the supplier’s apparent operational profile.

### Address and place of business

The taxable person must verify that the supplier has an actual place of business, using appropriate electronic means or a field visit. [\[10\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn10) The premises must be compatible with the supplier’s activities. [\[11\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn11)

The Decision does not define ‘appropriate electronic means’. Businesses should therefore specify in their policies which forms of evidence they will accept. Potential internal standards may include an official registry extract, a licence record, recent premises evidence, geolocation verification, or a documented video walkthrough. These are implementation suggestions, not methods expressly prescribed by the Decision.

### Prescribed risk indicators

Article 3(3)(a) of the FTA Decision requires the taxable person to determine whether any of the following prescribed risk indicators apply:

- more than two address changes during the previous 12 months;
- more than two changes in key employees during the previous 12 months; and
- transactions disproportionate or unexpected in volume, value, or nature compared with the supplier’s size and trading history.[\[12\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn12)

The presence of one or more of the risk indicators mentioned does not automatically prohibit the relationship. However, where an indicator applies, Article 3(3)(b) requires the taxable person to retain a clear and justified explanation and provide it to the FTA upon request. The explanation must not contradict the evidence or information available to the taxable person. [\[13\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn13)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn13><https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn13>This distinction is important. A supplier that is a fast-growing business, a newly funded company, a reorganised group, or a relocating free-zone entity may trigger an indicator for legitimate reasons. The control should therefore prompt investigation and documentation, not automatic rejection.

### Enhanced checks at AED 375,000

Where supplies received from a supplier in the preceding 12 months exceed AED 375,000 or are expected to do so in the next 12 months, the taxable person must verify that the supplier holds a bank account and review client recommendations where available. The taxable person must also: [\[14\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn14)

- obtain written confirmation from a bank authorised in the UAE that the supplier holds a bank account, without any relevant reservations or conditions;[\[15\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn15) and
- review and assess publicly available reviews and media coverage from reliable sources for consistency with the nature and size of the business and for indications of suspected tax evasion. [\[16\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn16)

The requirement extends beyond conducting a basic search. The Decision mandates both review and assessment. Accordingly, records should document the sources examined, the review date, material findings, and the conclusions reached.

### Verification of each supply

Article 4 of the Decision concerns the transaction itself. The taxable person must assess the conditions surrounding the transaction and ensure that the supplier’s engagement in it is based on genuine commercial reasons. [\[17\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn17)

Payment methods and conditions must also be commercially justifiable. A reasonable commercial explanation is required where:

- a third party participates in making or receiving payment; or
- payment is made to a bank account outside the supplier’s country of incorporation. [\[18\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn18)

Consideration shall be paid electronically. A cash payment must have a documented commercial reason, remain within applicable tax-law thresholds, and be readily verifiable. [\[19\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn19)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn19>The supply-level review also covers pricing, margins, licensed activities, authenticity and origin of goods, ownership or disposal rights, and the role of any intermediary. [\[20\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn20)

### Thresholds do not eliminate the need for supplier-level monitoring

Taxable persons may disregard the measures and conditions set out in the Decision where a taxable supply is below AED 10,000, excluding VAT. [\[21\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn21) That exception does not apply if cumulative supplies from the supplier exceed AED 100,000 in the preceding 12 months or are expected to exceed that amount in the next 12 months. [\[22\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn22)

| **Threshold** | **Consequence** |
| --- | --- |
| Below AED 10,000 per supply | The Article 6 exception may apply |
| Above AED 100,000 cumulatively or prospectively | The small-supply exception ceases to apply |
| Above AED 375,000 cumulatively or prospectively | Bank account confirmation and public source review apply |

 

These thresholds require both retrospective and prospective monitoring, as a system that tests only the individual invoice amount will not identify aggregation or forecast triggers. A practical accounts-payable control should therefore calculate rolling supplier spend, flag anticipated spend under open contracts or purchase orders, and prevent the AED 10,000 exception from being repeatedly applied when the AED 100,000 relationship threshold has been exceeded.

## Unresolved legal questions

The Decision uses terms such as ‘genuine commercial reasons’, ‘reasonable commercial explanation’, ‘commercially unjustifiable’, ‘appropriate electronic means’, and ‘reliable sources’. It does not provide detailed definitions, prescribed scoring, materiality tolerances, or a complete evidential standard for these terms. While it prescribes what must be verified, it offers less guidance on the legal consequences of compliance, the expected evidential threshold, and the handling of borderline cases.

### First, does procedural compliance protect the deduction?

The Decision requires the prescribed checks to be carried out and documented. It does not expressly state that completing them provides an absolute safe harbour if the supplier is later found to have participated in tax evasion. Businesses should therefore avoid describing the process as guaranteeing input tax recovery. A more defensible position is that robust compliance provides evidence that the taxpayer followed the prescribed regime and acted on the information available at the relevant time.

### Second, how intensive must verification be?

The Decision prescribes *minimum* measures but offers no universal risk-rating methodology. Its differentiated thresholds suggest some calibration, but ‘proportionality’ should be presented as an implementation principle rather than as an express statutory defence.

A sensible policy can apply the mandatory baseline to all in-scope relationships, with enhanced review for higher-value, unusual, intermediary-led, cash-based, cross-border, or otherwise elevated-risk transactions.

### Third, what happens when there is conflicting evidence?

A search of public information may raise concerns even if a supplier provides valid corporate documents. The Decision expressly requires that explanations not contradict evidence or information available to the taxable person.[\[23\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn23) The control framework should therefore include escalation, independent review, and documented acceptance or rejection. Merely retaining supplier-provided documents may be insufficient where conflicting information was known to exist.

## Contemporaneous evidence and audit defence

Taxable persons must document verification steps and retain supporting documents and records to enable the FTA to verify correct implementation. They must also maintain a documented policy identifying those responsible for implementation, review, and supervision, together with their powers and responsibilities. [\[24\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn24)<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn24>This makes contemporaneous evidence central to implementation. While the Decision does not prescribe a specific file structure, a defensible supplier file should, as applicable, contain the following to provide practical evidence of the requirements set out in Articles 3 to 5:

- the onboarding checklist;
- registry and license evidence;
- identity and authority verification;
- place-of-business evidence;
- the 12-month risk-indicator assessment;
- threshold calculations;
- bank confirmation;
- public-source review;
- commercial rationale;
- payment-routing explanation;
- pricing or market-comparison evidence;
- proof of delivery or performance;
- intermediary rationale;
- exceptions and escalation decisions; and
- approval and review dates.

Explanations prepared only after receipt of an FTA enquiry may be less persuasive than a dated assessment that was prepared before the deduction. Businesses should therefore prioritise capturing evidence at supplier onboarding, purchase approval, invoice processing, and the applicable re-verification stage.

## Contractual implications

The Decision applies directly to taxable persons claiming input tax. It does not, in itself, create specific supplier warranties, indemnities, or information covenants. Nevertheless, a customer cannot perform several required checks without the supplier’s cooperation.

Businesses should, therefore, consider including proportionate contractual provisions covering:

- accuracy and ongoing validity of incorporation, licence, address, representative, and banking information;
- confirmation that supplies fall within licensed and ordinary activities;
- notice of material changes to address, key personnel, ownership, authority, or banking arrangements;
- provision of evidence reasonably required for VAT verification;
- cooperation with FTA enquiries relating to the supply;
- restrictions on third-party or foreign-account payment without prior disclosure and explanation; and
- remedies where materially inaccurate information causes a demonstrable tax loss.

Any indemnity should be drafted carefully. A broad clause purporting to transfer all VAT risk to the supplier may be commercially difficult and may not address the customer’s failure to perform mandatory checks. The better approach is to allocate risk according to control: supplier liability for misrepresentation or non-cooperation, and customer responsibility for its own verification and filing decisions.

## Privacy and information governance

The Decision requires businesses to obtain identity documents for individual suppliers and authorised representatives.[\[25\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn25) Passports, other identity documents, identification numbers, and related verification records constitute personal data. Federal Decree-Law No 45 of 2021 Concerning the Protection of Personal Data is active federal legislation that took effect on 2 January 2022. Under this law, personal data includes information relating to an identified or identifiable natural person, such as names, images, identification numbers, electronic identifiers, and other identifying characteristics.[\[26\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn26)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn26>Businesses implementing the new procedures of the Decision should therefore also address:

- the lawful basis and stated purpose for collection;
- data minimisation, including whether a full unredacted copy is necessary;
- secure transmission and storage;
- access limited to authorised personnel;
- retention aligned with applicable tax and legal requirements;
- processor and service-provider controls; and
- cross-border transfers, particularly where procurement or finance operations are outside the UAE.

Businesses operating in the DIFC, ADGM, EU, UK, or Switzerland should also assess whether another data-protection regime applies to the relevant processing. Centralising supplier files outside the UAE may create a cross-border data-transfer issue even when the supplier and supply are domestic.

## Relationship with UAE e-invoicing

The Decision should not be implemented in isolation from the UAE electronic invoicing programme. Ministerial Decision No 243 of 2025 establishes the Electronic Invoicing System, while Ministerial Decision No 244 of 2025, as amended by Ministerial Resolution No 66 of 2026, addresses implementation. The service-provider accreditation framework is governed by Ministerial Decision No 64 of 2025, as amended by Ministerial Resolution No 56 of 2026.[\[27\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn27)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn27>The Ministry of Finance defines identifiers such as the Tax Identification Number (TIN), Tax Registration Number (TRN), and Universally Unique Identifier (UUID) in its [UAE Electronic Invoicing Guidelines](https://mof.gov.ae/wp-content/uploads/2026/02/UAE-Electronic-Invoicing-Guidelines_V-1.0-23Feb2026.pdf), highlighting the growing role of structured identifiers and transaction-level data in UAE tax administration.[\[28\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn28)

<https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn28>E-invoicing and supplier due diligence address different problems. A technically valid electronic invoice cannot, by itself, establish genuine commercial purpose, explain unusual payment routing, verify a business location, or resolve adverse information. Conversely, a robust supplier-verification file does not replace invoice-format and transmission requirements. Nevertheless, businesses should design the two programmes together. Supplier master data, licence information, TRNs, TINs, bank details, transaction approvals, invoice data, and supporting evidence should reconcile across procurement, enterprise resource planning, accounts payable, and tax reporting systems.

## A practical implementation model

The Decision requires a documented policy, allocated responsibilities, supplier and supply verification, supporting documents, and supplier re-verification where the Article 5(1) conditions are met.[\[29\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_edn29) A workable operating model could allocate responsibilities as follows:

| Control | Primary owner | Independent review or escalation |
| --- | --- | --- |
| Identity, incorporation, and licence checks | Procurement or vendor management | Legal or Compliance |
| Rolling-spend thresholds | Finance or accounts payable | Tax |
| Supply and invoice assessment | Business owner and accounts payable | Tax |
| Unusual payment routes | Finance | Tax, Compliance, or Legal |
| Public-source review | Compliance or procurement | Tax or legal |
| Privacy controls | Privacy or information governance | Legal or Data Protection Officer |
| Policy ownership | Head of Tax or CFO | Senior management or risk committee |
| Senior management or risk committee | Internal audit or control function | Audit and risk committee or management |

 

For smaller businesses, it may be necessary for one person to hold several roles. Where practicable, the operating model should separate supplier initiation or approval from the review of material exceptions. For smaller organisations, compensating senior-management review may be required where full segregation is not feasible.

### Implementation priorities

**Before 1 October 2026:**

1. approve a written supplier and supply verification policy;
2. map suppliers against the AED 100,000 and AED 375,000 thresholds;
3. identify suppliers not verified within the previous 12 months;
4. add mandatory evidence fields to vendor onboarding;
5. introduce supply-level exception questions into invoice approval;
6. define escalation for unusual pricing, payment routing, intermediaries, and adverse information;
7. establish protected storage for identity documents; and
8. align the control design with e-invoicing and supplier-master-data work.

**After implementation:**

- test whether required records are present;
- monitor rolling spend and expected contract value;
- review overrides and exceptions;
- reverify suppliers at least when Article 5 requires it;
- train procurement, finance, tax, and business approvers; and
- retain evidence in an audit-retrievable format.

## Conclusion

FTA Decision No 13 of 2026 alters the practical meaning of input tax control in the UAE. It requires taxpayers to look beyond the invoice and examine the supplier, the transaction, the payment, and the surrounding commercial circumstances. The principal risk is not limited to overtly suspicious suppliers. It also lies in ordinary businesses relying on fragmented files, undocumented judgement, outdated onboarding records, and accounts-payable systems that cannot detect rolling thresholds or unusual arrangements.

Companies should avoid over-engineering and instead focus on implementing the Decision’s mandatory checks proportionately and consistently, applying enhanced scrutiny where value or risk requires it, protecting the collected personal data, and preserving a contemporaneous record of the reasoning.

The organisations best prepared for FTA scrutiny will be those that can answer four questions clearly:

1. What did the business verify?
2. What evidence did it obtain?
3. What risks or inconsistencies did it identify?
4. Why was the supplier and supply accepted?

## Editorial note

This article provides general information and implementation observations. It does not constitute legal or tax advice. The official Arabic legislation should be consulted where interpretation turns on the wording of an unofficial English translation.

 

[\[1\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref1) Federal Tax Authority, *Decision No 13 of 2026* *concerning* *Measures, Procedures and Conditions Required by Taxable Persons for the Verification of the Validity and Integrity of Supplies before Deduction of Input Tax* (22 July 2026, effective 1 October 2026) (‘Decision No 13 of 2026’).

[\[2\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref2) United Arab Emirates, Ministry of Finance, *Ministerial Decision No 243 of 2025 on the Electronic Invoicing System* (2025); *Ministerial Decision No 244 of 2025 on the Implementation of the Electronic Invoicing System* (2025); and *Ministerial Decision No 64 of 2025 on the Eligibility Criteria and Accreditation Procedure for Service Providers Under the Electronic Invoicing System* (as amended).

[\[3\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref3) Federal Decree-Law No 8 of 2017 on Value Added Tax (‘UAE VAT Law’) arts 54–55.

[\[4\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref4) Cabinet Decision No 52 of 2017 Concerning the Executive Regulation of Federal Decree-Law No 8 of 2017 on Value-Added Tax, as amended; and Cabinet Decision No 149 of 2026 Amending Certain Provisions of the Executive Regulation of Federal Decree-Law No 8 of 2017 on Value-Added Tax (effective from 1 October 2026)

[\[5\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref5) Federal Tax Authority Decision No 13 of 2026.

[\[6\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref6) Decision No 13 of 2026 arts 3–4.

[\[76\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref7) ibid art 3(1)(a).

[\[8\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref8) ibid art 3(1)(b)(1).

[\[9\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref9) ibid art 3(1)(b)(2).

[\[10\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref10) ibid art 3(2)(a).

[\[11\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref11) ibid art 3(2)(b).

[\[12\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref12) ibid art 3(3).

[\[13\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref13) ibid art 3(3)(b).

[\[14\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref14) ibid art 3(4).

[\[15\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref15) ibid art 3(4)(a).

[\[16\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref16) ibid art 3(4)(b).

[\[17\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref17) ibid art 4(1).

[\[18\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref18) ibid art 4(2)(a).

[\[19\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref19) ibid art 4(2)(b).

[\[20\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref20) ibid art 4(3).

[\[21\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref21) ibid art 6(1).

[\[22\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref22) ibid art 6(2).

[\[23\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref23) ibid art 3(3)(b).

[\[24\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref24) ibid art 5(3)–(4).

[\[25\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref25) Decision No 13 of 2026 arts 3(1)(a) and 3(1)(b)(2).

[\[26\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref26) Federal Decree-Law No 45 of 2021 Concerning the Protection of Personal Data, art 1.

[\[27\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref27) *Ministerial Decision No 243 of 2025 on the Electronic Invoicing System* (2025), *Ministerial Decision No 244 of 2025 on the Implementation of the Electronic Invoicing System* (2025); and *Ministerial Decision No 64 of 2025 on the Eligibility Criteria and Accreditation Procedure for Service Providers Under the Electronic Invoicing System* (as amended).

[\[28\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref28) UAE Ministry of Finance, *UAE Electronic Invoicing Guidelines* (Version 1.1, 1 June 2026).

[\[29\]](https://varri.com/insights/uae-vat-input-tax-due-diligence-enters-a-new-era?hs_amp=true#_ednref29) Decision No 13 of 2026 art 5(1)–(4).

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