Every discussion of FTA Decision No. 13 of 2026 eventually has to leave the legal text and confront an operational question that boards will find harder than the law itself: who, exactly, is going to do this work?
The Work Is Real Work
Consider what the Decision asks, multiplied across a real vendor base. Supplier verification — incorporation checks, representative identity, premises verification, risk-indicator assessment, and for larger suppliers a bank confirmation and media review — refreshed on a twelve-month cycle for every in-scope supplier. Supply verification — a multi-point assessment covering commercial rationale, payment routing, pricing, licence scope, provenance and intermediaries — on each in-scope supply received.
For an enterprise with substantial local procurement — a contracting group, a distributor, a retail or hospitality operator — the in-scope population can easily run to hundreds of suppliers and tens of thousands of invoices a year. Performed manually and documented properly, that is not a task absorbed into someone's existing role. It is several full-time roles' worth of new, recurring work — before exception handling, before the refresh cycle stabilises, and before anyone builds the governance layer around it.
The Function That Would Absorb It Is Already Stretched
The natural assumption is that the tax function absorbs the obligation. The published research on tax function capacity says otherwise. Thomson Reuters' research with the Tax Executives Institute reports 58% of corporate tax departments describing themselves as under-resourced — a figure that has risen year on year. EY's 2025 Tax and Finance Operations survey, spanning 1,600 executives across 30 jurisdictions, finds tax teams spending 53% of their time on routine activities against a stated target of 21%. Deloitte's transformation research finds a majority of tax leaders expecting budget constraints or hiring freezes within two years. A typical UAE in-house indirect tax team — two to four people covering returns, refunds, audits, advisory, corporate tax and e-invoicing readiness — has no spare six roles hiding in it.
Accounts payable fares no better. Benchmarking puts median AP productivity at roughly 12,000 invoices per full-time employee per year — a figure achieved by minimising per-invoice attention. Layering a documented multi-point assessment onto that workflow, uncosted, is how programmes fail in their first quarter.
And the Skill Is Not the Skill You Have
There is a subtler gap beneath the numbers. Verifying counterparty substance — registry research, premises verification, adverse media assessment, judging whether a payment routing has a commercial rationale — is the working method of customer due diligence, a discipline that lives in banks and regulated institutions. Institutions that do it professionally, with mature tooling, still find corporate counterparty verification slow and expensive. Outside financial services and the businesses covered by AML obligations, most enterprises have simply never needed to build this muscle. The obligation is new in kind, not just in volume.
The Way Through: Design, Not Headcount
The honest arithmetic is not an argument for despair — it is an argument against answering the obligation with brute force. The variable that actually determines the recurring cost is what proportion of the population can be cleared systematically, from data the business already holds or can obtain, so that human judgement concentrates on the exceptions and on the tests that genuinely require it. That proportion is not fixed: it is a function of design — of vendor data quality, of where controls sit in the process, of what can be verified from structured sources rather than by hand. Two enterprises with identical vendor bases can land at wildly different steady-state costs depending on choices made before day one.
There is also a part of the work that no design removes: meetings held, premises confirmed, judgement exercised on the unusual. A credible programme is honest about that residue and sizes the human layer for it — rather than pretending either that everything can be automated or that nothing can.
How Contiqa Can Help
Contiqa Systems builds the effort model for your actual vendor base — what the obligation costs performed naively, what it costs designed well, and where the line between systematic clearance and human judgement should sit for your business. That model is the difference between budgeting this obligation and being surprised by it. Contact Contiqa Systems before you commit to a staffing answer.
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 and third-party research (working from the unofficial English translation of UAE instruments) and does not constitute tax or legal advice. Obtain advice on your specific circumstances before acting.