UMNIII branded card for the article on UAE supplier verification under FTA Decision No. 13 of 2026

UAE Federal Tax Authority Decision No. 13 of 2026 has applied since 1 October 2026. It sets out documented verification expected of taxable businesses in relation to their suppliers and the supplies they receive, before input tax is deducted.

For finance, procurement and compliance teams the practical question is rarely whether supplier due diligence is worth doing. It is what has to be established, when it has to be done again, and how the work can be shown months later when somebody asks to see it.


Who the decision addresses

The decision is addressed to taxable persons: businesses registered for VAT in the UAE, or required to register. It concerns the supplies they receive, and it matters at the point input tax is deducted.

It also carries an exception for smaller supplies, set out below, so its reach is narrower than a blanket rule covering every business and every supplier. Whether and how it applies to your circumstances is a question for your own tax adviser.


The AED 10,000 exception, and when it stops applying

A taxable person may disregard these measures on a taxable supply received where the consideration, excluding VAT, is less than AED 10,000. That is the threshold that keeps routine low-value purchases out of the process.

The exception has its own limit. It does not apply where the total value of supplies received from that supplier exceeds AED 100,000 over the previous twelve months, or is expected to exceed that amount over the next twelve months. So the test is not the invoice in front of you on its own. A supplier you buy from often can pass the AED 100,000 point and bring their smaller supplies back into scope with them.


Supplier verification and supply verification

The decision describes verification in relation to the supplier and, separately, in relation to each supply received. They are related pieces of work and it helps to keep them distinct.

  • Supplier verification is about the counterparty: who they are and whether they are a real business doing what they say they do.
  • Supply verification is about the transaction: whether the supply itself holds together commercially.

A supplier you verified last quarter does not remove the question of whether a particular supply makes sense, and a well documented transaction does not establish who you are dealing with.


First dealings, and the rolling twelve-month position

Supplier verification applies when you first deal with a supplier, and again on continued dealings where that supplier has not been verified in the previous twelve months. The window looks back from the dealing rather than landing on a fixed annual date, so it is rolling rather than an annual exercise you run once a year for everybody.

In practice the review itself is seldom the hard part. The difficulty is knowing which of several hundred supplier records is approaching the point where it should be looked at again, and being able to show that the ones you dealt with were in order at the time.


What verifying the supplier involves

The supplier side is concerned with establishing that the business is what it presents itself to be, and what it asks for depends on who the supplier is.

Where the supplier is a natural person, you obtain a copy of valid proof of identity, such as an Emirates ID or a passport, and you meet them, in person or virtually, before the supply is made. The meeting is part of the requirement rather than a nicety.

Where the supplier is a legal person, you verify its incorporation through official databases or obtain a copy of the certificate of incorporation, with the details valid and matching the entity's name, address and employees. You also verify the identity of the director, agent or employee authorised to represent it, again through valid proof of identity.

For the address and place of business, you establish that an actual place of business exists, using appropriate electronic means or a field visit, and that it is compatible with the nature of the activities the supplier carries out.

On risk, the decision names three indicators to check against:

  • the supplier has changed its address more than twice over the previous twelve months
  • the supplier has changed its key employees, meaning its managers or the people you deal with, more than twice over the previous twelve months
  • the supplier has undertaken transactions that are disproportionate or unexpected in volume, value or nature compared with the size of its business and its trading history

Where one of them applies, that is not the end of the matter. You retain a clear and justified explanation for why it applies, consistent with the evidence you hold, and provide it to the Authority on request.


The AED 375,000 threshold: bank confirmation and public review

Two further requirements attach to larger supplier relationships. Where the value of supplies received from a supplier exceeds AED 375,000 over the previous twelve months, or is expected to exceed that over the next twelve, you also:

  • obtain written confirmation from an authorised bank in the State that the supplier has a bank account, with no relevant reservations or conditions attached to it. The confirmation does not have to be addressed to you.
  • review and assess publicly available reviews and media coverage of the supplier from reliable sources, checking that they are consistent with the nature and size of its business and show no indicators of suspected tax evasion.

Note that this is a different figure from the AED 100,000 that governs the small-supply exception, and it does a different job. The AED 100,000 figure determines whether the small-supply exception remains available; the AED 375,000 figure adds two further requirements.


What verifying the supply involves

The supply side is concerned with whether the transaction makes sense on its own terms:

  • that the supplier's engagement in the transaction rests on genuine commercial reasons
  • that the payment method and conditions are commercially justifiable. Where a third party is involved in making or receiving payment, or payment goes to a bank account outside the supplier's country of incorporation, there has to be a reasonable commercial explanation that does not conflict with what you already know
  • that the consideration is paid by electronic means. Cash needs a documented commercial reason, has to sit within the thresholds in the applicable tax legislation, and has to be easily verifiable
  • that prices or profit margins are not commercially unjustifiable, or far from market conditions without a clear reason
  • that the goods or services do not fall outside the supplier's ordinary activity or what its commercial licence permits
  • the authenticity and origin of the goods received, and that the supplier validly owns them or has the right to dispose of them

Where the supplier acts as an intermediary, there has to be a clear and justifiable commercial explanation for its role in the supply. Most of this is question and answer work, which is worth designing once rather than improvising per transaction.


Electronic means or a field visit

On establishing a real place of business, the decision refers to appropriate electronic means or a field visit. Either route can satisfy it, so a visit is one available method rather than a standing requirement for every supplier, and which is appropriate in a given case is a judgement for your business.


Documenting the work, and who is responsible for it

Carrying out verification and being able to demonstrate it later are two different problems, and the decision addresses both. It asks that the verification carried out is documented, that supporting records are retained so they can be produced to the Federal Tax Authority, and that a business keeps a written policy setting out who carries out, reviews and supervises this work.

That last point is easy to overlook while the checks themselves get the attention. Naming who reviews and who supervises is part of what is expected, not an administrative extra.


How UMNIII Verify helps

UMNIII Verify is built around exactly this shape of work: a request that carries the forms, documents and checks your team selects, with the responses and the review kept together as one record.

  • Configurable forms and document requests, so the questions about commercial rationale, payment arrangements and licensed activities are asked the same way every time.
  • Supported identity, company and AML checks, selected per request rather than applied to everyone.
  • Shared review inside a Workspace, so the person who carries out the work and the person who reviews it are both recorded against it.
  • Verification-date tracking that shows when a supplier is approaching the point where it should be looked at again.
  • Reverification managed from the same Workspace, with the earlier evidence kept alongside the new request rather than starting over.
  • Supplier master data brought in through the supplier-integration capability, from SAP, Oracle or a structured export, so a large supplier base does not have to be recreated by hand. Bringing suppliers in does not start checks, spend credits or email anyone: your team still chooses who to verify and when.
  • One branded evidence pack per request, with individual documents, form-response PDFs and reports available separately.

The useful output is not a pass or a fail. It is an organised account of what was asked, what came back, who reviewed it and when.


Where to start

If you are working out what this means for your supplier base, the UAE supplier verification page sets out the decision and the workflow side by side, including reverification and evidence.

Read the UAE supplier verification guide


UMNIII Verify supports this work and evidences it. It does not make your tax, legal, compliance or supplier-acceptance decisions, and it does not file or submit anything to the Federal Tax Authority on your behalf. Nothing here is legal or tax advice. For the official text, see the Federal Tax Authority decision page, and for how it applies to your business take advice from a qualified UAE tax adviser.

Start verifying

UAE teams usually start by mapping the decision onto the supplier requests they already send, then add reverification tracking across the supplier base.