Article 3 of FTA Decision No. 13 of 2026 sets out what a UAE Taxable Person must verify about its suppliers before deducting input tax on what it buys from them. From 1 October 2026, these are the prescribed supplier-level measures — the ones whose omission engages the deeming rule in Article 54 bis of the VAT Law.
This article walks through what Article 3 requires, faithfully to the text, and flags the practical questions each requirement raises. What it deliberately does not do is tell you how to operationalise these checks at scale — that is a design exercise specific to each business's vendor base and systems.
Identity: Who Are You Actually Dealing With?
For a natural-person supplier, the Taxable Person must obtain a copy of a valid proof of identity — an Emirates ID or passport — and must meet the supplier, in person or virtually, before the supply is made. The meeting requirement is one of the most distinctive features of the Decision: it is a human act with a timestamp, and it cannot be performed retrospectively.
For a legal-person supplier, the Taxable Person must verify the supplier's incorporation through official databases or obtain the certificate of incorporation, with the incorporation details valid and matching the entity's name, address and employees and other related information — and must verify the identity of the director, agent or employee authorised to represent the supplier, again through a valid Emirates ID or passport.
The text reaches the authorised representative and stops there. It does not require beneficial ownership tracing, and it does not require sanctions or politically-exposed-person screening. Reading the ceiling accurately matters as much as reading the obligation — it keeps a programme proportionate.
Place of Business: Does the Supplier Physically Exist?
Article 3(2) requires verification of the existence of an actual place of business, using appropriate electronic means or through a field visit, and confirmation that the place of business is compatible with the nature of the activities the supplier carries out. A trading company claiming substantial volumes from premises that could not plausibly support them is precisely the pattern this test addresses.
What counts as "appropriate electronic means" is not yet defined in published guidance, which makes the evidencing question — what a contemporaneous record of the verification should contain to satisfy a reviewer years later — one of the interpretive positions each business should settle and document now.
Risk Indicators: The Rolling Twelve-Month Tests
Article 3(3) requires the Taxable Person to ensure that none of three risk indicators applies: the supplier has changed its address more than twice in the previous twelve months; the supplier has changed its key employees — defined as the supplier's managers or those with whom the Taxable Person deals — more than twice in the previous twelve months; or the supplier has undertaken transactions disproportionate or unexpected in volume, value or nature relative to the size and history of its business.
Where an indicator does apply, the relationship is not automatically off-limits: the Taxable Person must retain a clear and justified explanation and provide it to the Authority on request, provided the indicators do not contradict the evidence and information available to it. That proviso is important — it is a defence that works only if the explanation was recorded at the time.
Notice what these indicators assume: that the buyer is observing its suppliers' addresses and personnel over a rolling window. Most businesses have never captured that history. From October 2026, having it is what makes the indicator testable at all.
The AED 375,000 Tier: Bank Confirmation and Reputation Review
Where the value of supplies received from a supplier exceeds AED 375,000 over the previous twelve months — or is expected to over the next twelve — two enhanced measures apply. The Taxable Person must obtain a written confirmation from an authorised bank in the State that the supplier holds a bank account, free of relevant reservations or conditions; the text expressly provides that the confirmation need not be issued to the recipient, so a supplier's existing general-purpose bank letter can serve. And the Taxable Person must review and assess publicly available reviews and media coverage from reliable sources, checking consistency with the nature and size of the supplier's business and the absence of indicators of suspected Tax Evasion.
The Refresh Cycle
Under Article 5, supplier verification is required on first dealing, and again on recurrent dealings where the supplier has not been verified within the previous twelve months. Verification is therefore not an onboarding event but a cycle — one that decays silently, because nothing visibly fails when a verification lapses. How the cycle applies to a vendor base that predates 1 October 2026 is among the significant open questions each business should take a considered, documented position on.
How Contiqa Can Help
Knowing what Article 3 says is the easy part. Knowing which of your suppliers it applies to, where each check belongs in your onboarding and procurement process, and how the evidence should be captured so it defends the deduction years later — that is where programmes succeed or fail. Contiqa Systems designs that response end to end for UAE businesses. Contact Contiqa Systems to scope your supplier verification obligation before the effective date.
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.