UAE Input VAT: New Supplier Verification Rules from 1 October 2026 (FTA Decision No. 13)

By Alena Radkova, Founder of RAS for Tax Consultant · Updated 14 October 2026

From 1 October 2026, every VAT-registered business in the UAE must verify its suppliers and each purchase before deducting input VAT. A valid tax invoice and a supplier TRN are no longer enough on their own. The rules are set out in FTA Decision No. 13 of 2026 and apply to mainland and free zone businesses alike.

This guide from RAS Accounting explains, in plain language, when you must check a supplier, what to check, and what records to keep. At the end you can request our free Supplier Verification Checklist.

Why it matters: Article 54(bis) of the VAT Law

Article 54(bis), added to the UAE VAT Law by Federal Decree-Law No. 16 of 2025, lets the FTA deny input VAT where a purchase is linked to tax evasion and the buyer knew, or should have known, about it.

Decision No. 13 defines what “should have known” means in practice. If you did not carry out the prescribed checks, the FTA does not need to prove you knew about the fraud. Your input VAT can be refused, and VAT you expected to recover becomes a real cost.

When do you need to check a supplier?

Check a supplier the first time you deal with them, and again whenever their last check is more than 12 months old. Check each purchase every time, before you claim its input VAT.

Track running totals per supplier. A small supplier can cross AED 100,000 or AED 375,000 during the year, and the stricter rules apply from that point.

What to check about the supplier (Article 3)

1. Identity. For a company, confirm incorporation through official records or a certificate, check that its name, address and other details match, and identify the person who represents it (Emirates ID or passport). For an individual, take a copy of their Emirates ID or passport and meet them in person or by video call before the supply.
2. Real place of business. Confirm the supplier operates from real premises that suit its activity, either by a site visit or by video or online evidence. A virtual or shell address is a warning sign.
3. Risk indicators. Check whether, in the last 12 months, the supplier changed its address more than twice, changed key staff more than twice, or made deals unusual in volume, value or nature for its size and history. If any applies, keep a written explanation on file; the FTA can ask for it.
4. Enhanced checks above AED 375,000. Obtain a letter from a UAE bank confirming the supplier holds an account with no reservations (the supplier requests it; it need not be addressed to you). Review reliable public reviews and media to confirm they fit the business and show no signs of tax evasion.

What to check on each purchase (Article 4)

A verified supplier is not enough. Each supply must also make sense before you claim its VAT:

• The deal has a genuine commercial reason, and the supplier’s role is clear, especially if it acts as an intermediary
• The goods or services fall within the supplier’s normal business and licence
• The price or margin is reasonable for the market
• For goods, origin, authenticity and the supplier’s ownership are supported by documents
• Payment terms and method make commercial sense
• Payments to a third party, or to an account outside the supplier’s country of incorporation, have a reasonable explanation
• Payment is electronic; cash needs a documented reason, must stay within legal limits and be easy to trace

Internal policy and records (Article 5)

Completed checks are not enough without a written internal policy. It must name who carries out the verification, who reviews it and who supervises it, with their powers and responsibilities.

Document every step and keep the supporting evidence (company records, ID copies, site-visit photos, bank letters, explanations of risk indicators) with your VAT records, so the FTA can confirm the checks were done correctly.

Common mistakes to avoid

• Relying only on the tax invoice and TRN. A valid TRN shows the supplier is registered, not that the deal is genuine.
• Treating the AED 375,000 checks as optional. The bank letter and public-information review are required once purchases cross the threshold.
• Checking the supplier but not the invoice. Supplier and supply checks are separate obligations.
• Forgetting the 12-month refresh. Regular suppliers must be re-verified at least once a year.
• No written policy. Forms alone do not meet Article 5.
• No evidence. A ticked box without photos, documents or notes is hard to defend in an FTA audit.

Frequently asked questions

What is FTA Decision No. 13 of 2026?

It is a UAE Federal Tax Authority decision that sets the checks a VAT-registered business must carry out on its suppliers and purchases before deducting input VAT. It takes effect on 1 October 2026.

Does it apply to free zone companies?

Yes. It applies to all taxable persons registered for VAT in the UAE, on the mainland and in free zones.

Is a valid tax invoice still enough to recover input VAT?

No. From 1 October 2026 you also need documented verification of the supplier and the supply.

Are small purchases exempt?

A single purchase under AED 10,000 excluding VAT is exempt, unless total purchases from that supplier exceed AED 100,000 over the last 12 months or are expected to over the next 12.

How often must suppliers be re-verified?

When you first deal with them, and again if they have not been verified in the previous 12 months.

What happens if I don’t verify?

The FTA may deny your input VAT on purchases linked to tax evasion, even if you did not know about the evasion.

Does a site visit have to be in person?

No. The supplier’s place of business can be confirmed by a site visit or by appropriate electronic means, such as a video call or online evidence.

Get our free Supplier Verification Checklist

RAS Accounting has prepared a ready-to-use Supplier Verification Checklist and Field Visit Record based on FTA Decision No. 13 of 2026. Each line is linked to the relevant article, so your team knows exactly what to check and what evidence to keep. Request it free of charge with the form below, by email at info@rasacc.com, or on WhatsApp at +971 54 445 9856.

We can also help you write your internal verification policy, sort your suppliers by threshold, and review completed checklists before your VAT return. RAS for Tax Consultant Co LLC has supported UAE mainland and free zone businesses for more than 9 years.

This article is for general information and is not tax advice. It is based on an unofficial English translation of FTA Decision No. 13 of 2026; the official Arabic text prevails.