Missed the UAE VAT registration deadline? What to do now

Many small companies cross the VAT registration threshold without noticing — often because their sales go to clients abroad, or because one large contract pushes them over. If that has happened to you, the cost grows every month you wait. This guide explains what the law does with a late registration and what you can still do about it.

Were you required to register?

You must apply for VAT registration within 30 days of either of these:

your taxable supplies and imports over the past 12 months exceeded AED 375,000; or
you expect them to exceed AED 375,000 in the next 30 days.

Taxable supplies are sales that carry VAT at 5% or 0%. Zero-rated sales — for example services to clients outside the UAE — are taxable supplies and count towards the threshold. Exempt supplies do not. Our article on VAT registration for exporters of services covers that trap in detail.

What happens when you register late

Your registration date	Under the past-12-months test, the FTA registers you from the first day of the month after the month in which you became required to register — whether or not you applied. Under the next-30-days test, from the date you had reasonable grounds to expect to cross the threshold.
VAT on past sales	You must account for VAT on taxable supplies made from that registration date, even if your invoices did not show VAT. If your prices did not include VAT, it may have to come out of your margin.
Late-registration penalty	AED 10,000. The penalty reform that took effect on 14 April 2026 did not change this amount.
Late payment	Since 14 April 2026, unpaid tax attracts a late-payment penalty of 14% a year, charged monthly from the day after the due date.
VAT on your costs	VAT paid on goods and services received before registration can generally be recovered in your first return, if they are used to make taxable supplies. It cannot be recovered on services received more than five years before registration, or on the part of an asset's cost already written off (depreciated) before registration.

What to do now

Work out the exact date you crossed the threshold from your sales month by month, and apply on EmaraTax straight away with the correct effective date. Waiting does not help — the FTA can register you itself from the date you became liable.
If all your sales are zero-rated, consider applying for an exception from registration instead. It is granted only on request, and you must notify the FTA within 10 business days if you start making sales that carry 5% VAT.
Calculate the VAT on past sales and include it in your first return, together with VAT you paid on business costs before registration, where it can be recovered. Pay on time — the late-payment penalty runs monthly.
Look at your customer contracts before trying to recover VAT from customers for past sales. Whether you can depends on what was agreed and when; take advice before re-billing.
If you have grounds, request reconsideration of the penalty within 40 business days of being notified. The FTA's waiver initiative for the Corporate Tax late-registration penalty does not extend to the VAT penalty at the date of writing, so a request must rest on the facts of your case. No adviser can guarantee the outcome.
Fix the cause — a monthly check of your rolling 12-month sales, so it does not happen again.

Why it happens

Export sales assumed not to count because no VAT is charged on them.
Invoices issued from a bank or payment app with no monthly totals kept.
A single large contract that takes 12-month sales over the line within weeks.

We can work out your registration date from your actual invoices, prepare and submit the VAT registration or exception application, prepare your first returns and, where there are grounds, the penalty reconsideration request. If an earlier return needs correcting, see voluntary disclosure. Not sure of your date? Talk to us.

Sources: Federal Decree-Law No. 8 of 2017 on VAT, as amended (Articles 13, 15, 19 and 56); Cabinet Decision No. 52 of 2017 on the VAT Executive Regulation, as amended (Articles 7 and 16); Cabinet Decision No. 40 of 2017 on administrative penalties, as amended by Cabinet Decision No. 129 of 2025 (in force 14 April 2026); Federal Decree-Law No. 28 of 2022 on Tax Procedures, as amended (Article 29); FTA Waiver of Penalties page.

Disclaimer: This article is provided for general information and knowledge purposes only, based on the legislation and official guidance as at 12 October 2026. It does not constitute legal, tax or other professional advice, and should not be relied on as such. Rules and deadlines may change; please seek advice on your specific circumstances before acting. Get in touch for advice on your own company.