Key takeaways
- The FTA expects a reply to a clarification request by the deadline in its notification, and where neither the VAT law nor the Tax Procedures Law sets one, the FTA must allow between 5 and 40 business days (Article 48, Federal Decree-Law No. 28 of 2022).
- The FTA treats a notice as received once it has sent it to your registered address, so the reply period can start running before anyone at your company has read the notice (Article 11, Federal Decree-Law No. 28 of 2022).
- Documents sent to the FTA must be in Arabic, or in another language with an Arabic translation if the FTA asks for one, and failing to submit requested tax records in Arabic costs AED 5,000 (as of 13 November 2026; it was AED 20,000 before 14 April 2026).
- Not assisting an FTA tax auditor carries a penalty of AED 20,000, and deliberately giving the FTA false information or documents can bring a fine of up to AED 1,000,000, a prison sentence, or both.
- Each extra round of documents restarts the FTA's review period (a further 25 business days on a VAT refund, up to 60 on a private clarification), so one complete reply beats several partial ones.
- A decision the FTA issues after your reply, such as a tax assessment or a refund rejection, can be challenged with a reconsideration request within 40 business days of being notified.
What is an FTA clarification request and where does it arrive?
The FTA sends one when it needs facts or documents before it will approve, refund or finalise something on your account, most often on a VAT registration application, a VAT refund application or a tax audit.
Notices go to the address registered on your tax record (Article 11 of Federal Decree-Law No. 28 of 2022). For applications, the FTA's service pages say it asks for additional documentation and you resubmit through EmaraTax, and its website states that FTA services are available only through UAE Pass, so whoever holds your EmaraTax access has to check it regularly.
A private clarification is a separate thing that shares the name: you ask the FTA how a rule applies to your facts, for a fee of AED 1,500 for one tax or AED 2,250 for several (FTA service card, updated 17 September 2026). If the FTA comes back with questions on that request, the steps below apply to you too.
How long do you have to respond to an FTA request?
Your deadline is the one stated in the FTA's notification, and where neither the VAT law nor the Tax Procedures Law sets a period, the FTA must give you at least 5 and at most 40 business days, and it may extend that period (Article 48).
Under Article 49 the day of notification isn't counted, and a deadline falling on a non-business day moves to the next business day.
| Request type | Your deadline to reply | FTA's time after your reply | Source |
|---|---|---|---|
| VAT registration application | Stated in the FTA's request; the service card sets no fixed reply period | 20 business days from receipt of the completed application | FTA VAT registration service card, updated 19 August 2026 |
| VAT refund application | Stated in the FTA's request; the service card sets no fixed reply period | 25 business days from a completed application; a further 25 business days after additional documents; 55 working days from receipt of all requested information if Audit needs to investigate | FTA refund service card, updated 19 August 2026 |
| Private clarification (FTA asks you for more information) | 40 business days from the date the FTA sent the request, or the FTA rejects the request | Up to 60 business days from receipt of the additional information | FTA private clarification service card, updated 17 September 2026 |
| Tax audit information request | Stated in the audit notification, which must arrive at least 10 business days before the audit starts | Result notified within the timeframe in the Executive Regulation | Federal Decree-Law No. 28 of 2022, Articles 16, 20 and 22 |
Checked 13 November 2026. If you need longer, ask before the deadline passes: the law lets the FTA extend the period, but it doesn't promise an extension.
Your reply deadline comes from the notice itself, but your filing deadlines don't, and the free UAE compliance calendar lists those for your company.
How do you respond to an FTA clarification request, step by step?
Reply through the same EmaraTax workflow the request came from, with every item the FTA asked for, in Arabic or with an Arabic translation, before the stated deadline.
- Log in to EmaraTax with UAE Pass and open the application, refund or notification the request relates to. Read the request for the deadline, the exact items and the format asked for.
- Decide who replies. You, your Legal Representative or a Tax Agent on the FTA's Register of Tax Agents can act for you, and your own responsibility stays with you (Article 14). For private clarifications and reconsideration requests, the FTA says tax advisers who aren't registered Tax Agents can't submit on your behalf.
- Match each question to evidence: tax invoices, contracts, ledger extracts and bank statements. Attach support for every point, because you carry the burden of proving that your tax return is accurate (Article 51).
- Check the language. Documents go to the FTA in Arabic by default; it can accept another language but may ask for an Arabic translation, which you pay for and answer for (Article 5).
- Check your own return before sending anything. If the request exposes an error that understated your VAT or overstated a refund, Article 10 requires a voluntary disclosure, and disclosing before an audit notice costs 1% of the tax difference per month, against a fixed 15% plus 1% a month afterwards (Cabinet Decision No. 40 of 2017, as amended by Cabinet Decision No. 129 of 2025, in force from 14 April 2026).
- Submit everything in one go through EmaraTax, keep the confirmation, and check EmaraTax for a second request after the FTA's response time in the table above.
What happens if you miss the deadline or reply incompletely?
The FTA can reject an application or a private clarification, and in an audit the penalties are fixed amounts that apply whatever the tax outcome.
| Situation | Penalty (as of 13 November 2026) | Reference |
|---|---|---|
| Requested tax records not submitted in Arabic | AED 5,000 (AED 20,000 before 14 April 2026) | Cabinet Decision No. 40 of 2017, Table 1 item 2, as amended by Cabinet Decision No. 129 of 2025 |
| Tax auditor not assisted | AED 20,000, due from the own funds of the person concerned | Federal Decree-Law No. 28 of 2022, Articles 20 and 24(1)(m); Cabinet Decision No. 40 of 2017 |
| False information or documents given deliberately | Prison sentence, fine up to AED 1,000,000, or both | Federal Decree-Law No. 28 of 2022, Article 25(4) |
Source: Federal Decree-Law No. 28 of 2022 and Cabinet Decision No. 40 of 2017 as amended, checked 13 November 2026. An administrative penalty is also capped at twice the tax it relates to (Article 24(4)).
Can you challenge what the FTA decides after your reply?
Yes, if the FTA issues a decision such as a tax assessment, a penalty assessment or a refund rejection: you ask the FTA to reconsider it within 40 business days of being notified (Article 29).
The FTA must decide within 40 business days and tell you within 5 more. If you still disagree, you object to the Tax Disputes Resolution Committee within 40 business days of the FTA's reconsideration decision, and the Committee won't accept the objection unless you asked for reconsideration first and paid the tax in full (Articles 29 and 32). A private clarification answer is different: the FTA says clarifications aren't decisions, so they can't go through reconsideration.
5 to 40 business days: the period the FTA must allow you where neither the VAT law nor the Tax Procedures Law sets a deadline for an obligation; the notice itself states the actual date. Source: Federal Decree-Law No. 28 of 2022, Article 48, checked 13 November 2026.
What most guides don't tell you
- A notice counts as delivered once the FTA sends it to your registered address, whether or not anyone reads it (Article 11). If your EmaraTax contact details are out of date, the reply period can run out unseen, and the law gives you 20 business days to update your tax record after a change (Article 6(2)(b)).
- An explanation without evidence doesn't discharge the burden of proof, which sits with you for the accuracy of your return (Article 51). Send the invoice, contract or ledger extract behind each statement.
- A private clarification can't be used to get ahead of an audit on the same issue: the FTA says it rejects requests where the subject matter is already under tax audit, tax assessment or inspection.
Which deadlines apply to your company?
Replying on time starts with knowing which dates are yours. The UAE compliance calendar is a free calendar of your company's UAE tax and compliance deadlines, personalised from a few questions, as a PDF and calendar file: get your free compliance calendar.
Frequently asked questions
What happens during an FTA VAT audit?
The FTA must notify you at least 10 business days before it starts, and its auditors can inspect your premises, records and systems at your place of business or the FTA's. You must assist them, and you have the right to see their job identification card and to get a copy of the audit notification.
Can I appeal a VAT penalty?
Yes. Ask the FTA to reconsider the decision within 40 business days of being notified, then object to the Tax Disputes Resolution Committee within 40 business days of the FTA's reconsideration decision. The Committee only accepts the objection if you filed a reconsideration request first and paid the tax in full.
How do I apply for a VAT penalty waiver or reconsideration?
File a reconsideration request through EmaraTax (Taxable Person Profile, Other Services, Reconsiderations, New Request) with your reasons and supporting documents, within 40 business days of being notified; the service is free. Article 50 also lets an FTA committee approve instalments or a waiver of penalties under Cabinet-set controls, but the criteria sit outside the law itself, so check the FTA's current guidance first.
What is a Tax Agent and do I need one for VAT?
A Tax Agent is a person on the FTA's Register of Tax Agents, with a licence from the competent local authority, appointed to represent you before the FTA (Articles 12 and 14). The law says you may appoint one rather than requiring it, and appointing one doesn't remove your own responsibility.
About Qawi · Qawi is a corporate services firm licensed in the Sharjah Media City (SHAMS) free zone, handling company formation, visas and PRO, bookkeeping, VAT and corporate tax for UAE businesses. Guides are researched from FTA, Ministry of Finance and free zone sources. Qawi on LinkedIn
Sources
Official sources:
- Federal Decree-Law No. 28 of 2022 on Tax Procedures, consolidated text (Ministry of Finance)
- Ministry of Finance: amendments to the Tax Procedures Law from 1 January 2026 (Federal Decree-Law No. 17 of 2025)
- Cabinet Decision No. 40 of 2017 and its amendments, including Cabinet Decision No. 129 of 2025 (Ministry of Finance)
- FTA announcement that the amended administrative penalties took effect, 15 April 2026
- FTA service card: Tax Refund to Registered Tax Payers
- FTA service card: Private Tax Clarifications Request
- FTA service card: Value Added Tax (VAT) Registration
- FTA service card: Reconsideration Request
Interpretation used alongside the official texts:
- Andersen UAE: key amendments to UAE administrative penalties (Cabinet Decision No. 129 of 2025)
- Al Tamimi & Company: UAE tax penalty reform, effective 14 April 2026
- Habib Al Mulla and Partners: analysis of Federal Decree-Law No. 17 of 2025
Last checked: 13 November 2026
General information, not tax or legal advice for your specific situation.