Article 6 of FTA Decision No. 13 of 2026 looks, at first reading, like the provision that keeps the new input tax verification regime manageable: supplies under AED 10,000 are excepted. Then comes Clause 2, and with it the single most operationally demanding sentence in the Decision.
What Article 6 Actually Says
Clause 1 provides that a Taxable Person may disregard the Decision's measures and conditions for taxable supplies received where the consideration, exclusive of VAT, is less than AED 10,000.
Clause 2 provides that this exception does not apply where the total value of supplies received from the supplier exceeds AED 100,000 over the previous twelve months — or is expected to exceed that amount over the next twelve.
Read together: the de minimis is tested at invoice level, but the claw-back is tested at relationship level, on a rolling window, in both directions of time.
Why the Claw-Back Changes Everything
Consider a supplier that invoices you AED 9,500 eleven times across a year. Each invoice individually sits under the AED 10,000 line. The relationship crosses AED 100,000 — and from that point the exception falls away for the supplier, pulling every supply, including every small invoice, into the verification regime. Article 5 then requires the supplier itself to be verified under Article 3, because in-scope supplies are flowing from it.
The design consequence is blunt: any control built on an invoice-value filter alone will miss. A screen that waves through everything under AED 10,000 is testing the wrong variable. The variable the Decision tests is rolling twelve-month supplier-level aggregate value — recomputed as invoices arrive, because a supplier can cross the threshold mid-year and change the status of supplies that follow.
The Forward-Looking Limb
The claw-back is not only backward-looking. It applies equally where supplies are expected to exceed AED 100,000 over the coming twelve months. A new supplier signed on a substantial annual contract is in scope from the first invoice, whatever its value, because the expectation exists at the outset. That means scoping is not purely an accounting calculation on historical data — it requires connecting what procurement knows about contracted and planned spend to what accounts payable sees arriving. The same forward test appears again at the AED 375,000 threshold that triggers the enhanced supplier measures, so the capability has to exist at two levels.
The Question to Ask Your Own Business
Here is a fair self-test, and it is the question that most quickly reveals readiness: can you say, today, how many of your suppliers exceeded AED 100,000 in supplies over the last twelve months — and which suppliers you expect to cross that line in the next twelve?
Most UAE enterprises can produce annual spend by vendor for a financial year. Far fewer can produce a rolling twelve-month view that updates continuously. Fewer still can produce a defensible forward expectation, or handle the realities underneath the calculation: duplicate vendor records, the same supplier under two names, group entities buying from the same counterparty, and franchises or branches that blur what "the supplier" means. None of these are exotic problems — they are ordinary vendor master conditions — but every one of them distorts the aggregation on which scope now depends.
Proportionality Cuts Both Ways
It is worth crediting the design: the thresholds are a genuine proportionality mechanism. One-off small purchases stay out of scope entirely, and the enhanced measures reserve their weight for supplier relationships above AED 375,000. The regime concentrates verification effort where the value concentrates — which is exactly where a rational business would put it anyway. The demand it makes in return is a data capability: knowing your supplier relationships at aggregate level, continuously, rather than invoice by invoice. Businesses that build that capability once will find it pays for itself well beyond tax compliance.
How Contiqa Can Help
Sizing the in-scope population is the first deliverable of any serious Decision 13 response — and it is a data exercise most vendor masters cannot support without remediation. Contiqa Systems runs exactly this diagnostic for UAE businesses: which suppliers cross which thresholds, where the vendor data breaks the calculation, and what the in-scope supply volume actually is. Contact Contiqa Systems to establish your true Decision 13 scope before 1 October 2026.
Track how UAE businesses are responding to this Decision as it takes effect — visit the Decision 13 Tracker on this site.
This article is general commentary on published legislation (working from the unofficial English translation) and does not constitute tax or legal advice. Obtain advice on your specific circumstances before acting.