Two FTA decisions issued in 2026 are usually discussed separately, and should be scoped as one programme. FTA Decision No. 13 of 2026 governs what verification evidence has to exist before input tax is deducted. FTA Decision No. 4 of 2026 — issued 2 June 2026, effective from its publication — governs the condition that evidence, and all your accounting records, must be kept in.
A verification file that fails the applicable record-keeping standard is not the defence you think you have. That is why the two instruments belong in the same conversation.
What Decision 4 Requires
Decision No. 4, on the rules and requirements for maintaining the information contained in accounting records and commercial books, sets three rules in Article 2, each elaborated in Article 3.
Complete and identical to the originals. Records retained as electronic copies or photocopies must include all the data and details of the original document — every page, in the same order. Partial scanning of any part of a document is expressly not accepted. The first page of a contract, or the summary sheet of a bank letter, is not the record.
Clear and easily legible. Copies must be of sufficient quality and resolution that the data is clear and easily legible when displayed on a computer screen. For physical records, ink and paper must be of a quality that will not fade over the record-keeping period. Non-coloured copies of coloured documents may be retained, provided the details remain clearly legible.
Accessible to the Authority on request. Access must extend to the system in which records are saved. Where electronic copies or the systems holding them are protected by encryption or passwords, the encryption keys or passwords necessary to enable access must be provided. For physical records, access must be available to the places where they are stored.
Article 4 adds a provision with real consequences for how businesses structure their archiving: a person may engage a third party to maintain records — but remains legally responsible for maintaining them and ensuring their safety. Outsourced document storage does not outsource the obligation.
Why This Pairs With Decision 13
Decision 13 generates a substantial new evidence population: identity documents, incorporation records, licence copies, place-of-business verification records, risk-indicator explanations, bank confirmations, media review notes, per-supply assessments, and the Article 5(4) policy itself. Article 5(3) of Decision 13 requires the verification steps to be documented and supporting records retained in a way that enables the Authority to verify correct implementation.
The record-keeping framework then does the rest of the work. Under Cabinet Decision No. 74 of 2023, business records — expressly including correspondence, invoices, licences and contracts related to the business — must be retained for five years following the relevant tax period, with defined extensions in specific circumstances. The verification evidence Decision 13 requires falls naturally within that record set, and Decision 4 defines the standard it must be kept to across that entire period.
Put the pieces together and the specification becomes concrete: complete copies of every verification document, legible on screen, retrievable on request — including from within whatever system holds them — for years after the transaction, with responsibility remaining yours whoever hosts the archive.
The Practical Test
Here is the exercise worth running before October: pick one real supplier and one real invoice, and attempt to assemble today what a reviewer would ask for in 2030 — the verification file, complete, legible, linked to that supplier and that transaction, produced from your systems on request. Most businesses that run this test discover the same three gaps: documents that exist but cannot be found, documents that can be found but are partial or illegible, and documents that exist only as an attachment in someone's inbox — which is not an archive, and not access the Authority can be given.
Evidence architecture — where verification records live, how they link to suppliers and transactions, who can retrieve them, and how the standard is maintained for years — is unglamorous, and it is where Decision 13 compliance is genuinely won or lost.
How Contiqa Can Help
Contiqa Systems designs the evidence and retention architecture that makes Decision 13 and Decision 4 work together: what gets captured, where it lives, how it links to the vendor and the supply, and how it stays complete, legible and retrievable for as long as the law requires. Contact Contiqa Systems to test whether your records would pass the request you have not received yet.
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 translations) and does not constitute tax or legal advice. Obtain advice on your specific circumstances before acting.
