On 22 July 2026 the Federal Tax Authority issued Decision No. 13 of 2026, setting out the measures, procedures and conditions a Taxable Person must satisfy to verify the validity and integrity of the supplies it receives before deducting input tax. The Decision takes effect on 1 October 2026, and it applies to every VAT-registered business in the UAE.
If your business recovers input VAT — and almost every registered business does — this Decision changes what you must be able to demonstrate about your suppliers and your purchases. This article explains what the Decision is, where it comes from, and why it deserves board-level attention rather than a line on the tax team's to-do list.
Where Decision 13 Comes From: Article 54 bis of the VAT Law
Decision No. 13 does not stand alone. It gives operational content to Article 54 bis of Federal Decree-Law No. 8 of 2017 on Value Added Tax, a provision inserted by Federal Decree-Law No. 16 of 2025 with effect from 1 January 2026. Article 54 bis addresses a problem every mature VAT system has had to confront: input tax claimed on supplies that formed part of a chain connected with Tax Evasion.
The structure is a knowledge standard, familiar internationally. Where a supply formed part of such a chain and the Taxable Person knew of the connection, the deduction is refused. Where the Taxable Person should have been aware of it, the deduction may be refused. And — this is the part that gives Decision 13 its force — a Taxable Person who has not verified its supplies in accordance with the measures the Authority prescribes is treated as having been required to be aware. Performing the prescribed verification is what keeps that question open and evidence-based.
Seen in that light, Decision 13 is a practical benefit to the honest taxpayer: it tells you exactly what the Authority expects, in a way many other jurisdictions never have. But it also means the prescribed measures are not optional good practice. They are the specification.
What the Decision Requires, at a Glance
The Decision operates at three levels.
Supplier-level verification (Article 3). Before dealing with a supplier — and again on recurrent dealings where the supplier has not been verified in the previous twelve months — a Taxable Person must verify the supplier's identity, its incorporation or the identity documents of a natural-person supplier, the identity of the person authorised to represent it, the existence of an actual place of business compatible with its activities, and a set of defined risk indicators covering address changes, changes in key employees, and transactions disproportionate to the size and history of the supplier's business. Where supplies from a supplier exceed AED 375,000 over a rolling twelve months, enhanced measures apply, including a bank account confirmation and a review of publicly available reviews and media coverage.
Supply-level verification (Article 4). For each taxable supply received, the Taxable Person must assess the transaction's conditions and commercial rationale, the payment method and routing, the pricing against market conditions, whether the supply falls within the supplier's licensed activities, the authenticity and origin of goods, and the commercial explanation for any intermediary in the chain.
Procedures and governance (Article 5). The verification steps must be documented and supporting records retained so the Authority can confirm correct implementation, and the business must maintain a documented policy identifying the persons responsible for implementing, reviewing and supervising the verification procedures, with their powers and responsibilities clearly stated.
The Thresholds — and the Rule That Surprises People
Article 6 provides a de minimis: the measures may be disregarded where the consideration for a taxable supply, excluding VAT, is less than AED 10,000. But that exception falls away entirely where total supplies from the supplier exceed AED 100,000 over the previous twelve months — or are expected to exceed it over the next twelve. A supplier billing modest invoices month after month crosses that line, and the whole relationship comes into scope. Screening by invoice value alone will not answer the question the Decision asks.
Why This Is Bigger Than a Tax Task
Three features make Decision 13 different from most compliance updates. First, the trigger is unobservable in advance: no business can know which of its suppliers might later be found connected to an evasion chain, so protection has to be built across the whole in-scope supplier population. Second, much of the evidence is point-in-time — a meeting held before a supply, an address verified on a date — and cannot be recreated later. Third, the acts the Decision requires sit in vendor onboarding, purchasing, accounts payable and payment execution, functions well outside the tax department, while the tax consequence lands squarely on the input tax line.
With the Decision effective from 1 October 2026, the window for scoping the in-scope supplier population, settling interpretive positions and standing up the documentation discipline is short. The businesses that treat this as a design exercise now will be in a very different position from those that discover it during their first tax audit of the new era.
How Contiqa Can Help
Contiqa Systems works with UAE businesses on exactly this problem: sizing the in-scope supplier and supply population, identifying where the verification obligations land in your procure-to-pay process, and designing a defensible, sustainable compliance response across tax, technology, data, process and governance — without turning your finance team into a verification bureau.
If you want to understand what Decision 13 means for your specific vendor base before 1 October 2026, contact Contiqa Systems for a scoping conversation.
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.
