Bottom Line:

From October 1, 2026, Input Tax recovery will require an audit trail. If the FTA identifies fraud or evasion in the supply chain, a business may need to prove that it applied the prescribed supplier and transaction checks and could not reasonably have known of the issue. The risk is no longer limited to whether the invoice is valid. It is whether the business can demonstrate a documented, risk-based process that protects its recovery position.

This should not affect ordinary commercial purchases where the supplier is genuine, and the business has basic controls in place.

The real risk is a challenge: can the business show that it had sensible checks, applied them, and kept the evidence? That is why the practical focus should be on process, ownership, and the audit trail.

Article 3 — Supplier Verification (at onboarding, then every 12 months)

Identity

• For individuals, obtain valid ID and meet the supplier in person or virtually before the supply.
• For companies, verify incorporation details using official sources or corporate documents.
• Confirm that the person acting for the supplier is properly identified and authorized.

Place of business

• Check that the supplier has a real place of business, using desktop evidence or a site visit where appropriate.
• Check that the location makes sense for what the supplier does.

Risk indicators and red flags:

Watch for repeated changes in address or key contacts, unusual transaction size or value, or activity that does not fit the supplier’s normal business.

If a red flag exists, keep a brief explanation showing why the supplier was still accepted or what further checks were perfomed.

Bank account and other verification:

• For higher-value supplier relationships, additional checks apply.
• Obtain confirmation that the supplier has a UAE bank account.
• Check reliable public information for signs of concern.

Vendor onboarding will need to capture more than a trade license and VAT TRN. Businesses should build defined supplier checks into onboarding and annual refresh processes.

Place-of-business checks should be practical and risk-based. Site visits may be reserved for higher-risk suppliers. For others, a dated desktop review using official records, address evidence, mapping imagery, and correspondence should usually be more workable.

Systems will also need to flag changes in supplier address, key contacts, and transaction profile. The FTA is likely to focus less on whether every risk was eliminated and more on whether the business had a documented process to identify, assess and respond to red flags.

Bank confirmation is a new and potentially burdensome requirement. The cleanest approach is likely to build it into supplier onboarding, contracting, and renewal cycles rather than chasing confirmations later.

Some of this can be aligned with e-invoicing data cleansing, as both workstreams touch vendor master data. It will not be a complete answer, however, because several Decision 13 data points are not required for e-invoicing and may not currently be collected.

Article 4 — Supply Verification (potentially every taxable supply)

• There should be a clear commercial reason for using the supplier.
• Unusual payment arrangements should be explained and recorded.
• Prices and margins should make commercial sense.
• The goods or services should fit the supplier’s normal licensed activity.

Although the Decision refers to supplies received, it should be possible to apply the checks through upstream controls rather than testing every invoice individually. The practical answer is to embed supplier and transaction verification into onboarding, procurement, payment, and monitoring processes.

Many of the required checks rely on information that Accounts Payable teams do not typically hold, such as the supplier's business activities, commercial rationale, or payment arrangements.

Manual review should be focused on higher-risk suppliers, unusual payments, and exception cases. There may also be a case for statistical sampling where full population testing is not practical.

Article 5 — Procedures and Evidence

• Document the verification steps and retain supporting records so the FTA can check them.
• Maintain a written policy naming the persons responsible for implementing, reviewing, and supervising the procedures, and setting out their powers, held at the designated document location.

A business with sound informal practice and no written policy would be treated as non-compliant on the face of the Decision.

Ownership must be agreed between tax, finance, procurement, and AP, and recorded.

Article 6 — Thresholds

• The measures need not be applied to a supply where the consideration, excluding VAT, is less than AED 10,000.
• That exception does not apply where the total value of supplies received from the supplier exceeded AED 100,000 over the previous 12 months or is expected to exceed AED 100,000 over the next 12 months.
• Separately, the enhanced checks are applicable at AED 375,000 of supplies received from the supplier tested over the same two periods.

While the de minimis thresholds provide some relief, they are narrower than they initially appear.

Businesses should monitor cumulative supplier spending, not just individual invoices. Recurring suppliers may come into scope quickly, so this is likely to need system support rather than manual review.