UAE VAT Record Keeping: Rules, Retention Period & Penalties

UAE VAT records must be kept for 5 years after the tax period. See what to keep, the 10-year capital asset rule, Arabic requests and the penalty tiers.

11 November 2026Qawi8 min read

Key takeaways

A UAE VAT-registered company must keep its accounting records for 5 years following the tax period they relate to, under Article 3 of Cabinet Decision No. 74 of 2023.
Records for capital assets under UAE VAT must be kept for at least 10 years, because Article 60(2) of Federal Decree-Law No. 8 of 2017 sets that minimum.
The FTA can extend a UAE company's retention period by 4 years if there is a dispute, an ongoing audit, or a notified intention to audit, and by 1 year after certain voluntary disclosures.
UAE VAT records can be kept in English and as scans or electronic copies, but the FTA can ask for Arabic translations and for a readable copy on request.
Failing to keep required tax records is reported to carry an administrative penalty of AED 10,000 per violation from 14 April 2026, rising to AED 20,000 if repeated within 24 months; check the decision text before relying on the figure.

Which VAT records do I have to keep, and for how long?

You must keep the records that support every VAT figure on your returns, and the baseline period is five years following the tax period each record relates to. Article 78 of Federal Decree-Law No. 8 of 2017 requires a taxable person to keep records of supplies and imports, tax invoices and tax credit notes issued and received, and a tax record; Cabinet Decision No. 74 of 2023 (Article 3) sets the time limit.

Record type	Retention period	Where it comes from
General VAT and accounting records of a taxable person	5 years following the tax period they relate to	Cabinet Decision No. 74 of 2023, Article 3(1)(a)
Capital asset records	At least 10 years	Federal Decree-Law No. 8 of 2017, Article 60(2)
Real estate records	7 years from the end of the calendar year in which the document was created	Cabinet Decision No. 74 of 2023, Article 3(1)(c)
Extra time: dispute with the FTA	4 more years, or until the dispute is settled if later	Cabinet Decision No. 74 of 2023, Article 3(2)(a)
Extra time: ongoing audit, or FTA notice of intended audit	4 more years	Cabinet Decision No. 74 of 2023, Article 3(2)(b) and (c)
Extra time: voluntary disclosure filed in the fifth year	1 more year from submission	Cabinet Decision No. 74 of 2023, Article 3(2)(d)

Accurate as of 11 November 2026. The clock for a taxable person runs from the tax period, not from the date on the document. Say a SHAMS trading company files its return for the quarter ending 31 March 2026: its records for that quarter should stay available until at least the end of March 2031 (a hypothetical example).

What counts as a VAT record?

A VAT record is any document that supports a figure on your return or your right to recover input VAT. In practice that means:

tax invoices and tax credit notes you issue and receive
supplier invoices and customs documents for imports, including the supplier's invoice and a customs statement for reverse charge imports (Cabinet Decision No. 52 of 2017, Article 48)
evidence of exports for zero-rating, such as customs and shipping documents (Article 30)
your capital asset register, if you own assets under the capital assets scheme (Article 58)
the ledgers, VAT returns and EmaraTax acknowledgements that tie everything together

Article 2 of Cabinet Decision No. 74 of 2023 also lists wider business records the FTA can expect, such as financial statements, wage records, fixed asset records, inventory records, correspondence and the documents that show how tax was calculated.

Can I keep VAT records in English, or on a computer?

Yes to both, with conditions. The FTA may accept records in English, but it can ask you for an Arabic translation, which has to be approved under the law regulating translation in the UAE (Cabinet Decision No. 74 of 2023, Article 5); under the Tax Procedures Law, that translation is at your own expense. Electronic or photocopied records are accepted if a readable copy can be reproduced on request (Article 4(1)(b)(2)).

5 years: the baseline period a VAT-registered company must keep its records, counted from the end of the tax period they relate to. Source: Cabinet Decision No. 74 of 2023, Article 3(1)(a), checked 11 November 2026.

If you'd rather not track these dates by hand, the free 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.

What is the penalty for not keeping VAT records?

The reported penalty is AED 10,000 per violation, rising to AED 20,000 if the violation repeats within 24 months. Those amounts come from Cabinet Decision No. 129 of 2025, which Al Tamimi reports took effect on 14 April 2026 and replaced the earlier regime; we couldn't read the decision text itself, so confirm the figures on the FTA website.

Violation	Reported penalty	Date to check
Failing to keep required records	AED 10,000 per violation	Reported effective 14 April 2026
Repeating that violation within 24 months	AED 20,000	Reported effective 14 April 2026
Failing to submit requested information in Arabic	AED 5,000 (previously AED 20,000)	Reported effective 14 April 2026

Accurate as of 11 November 2026, based on a law firm summary rather than the decision itself. Penalties are the smaller problem; missing invoices can also mean a denied input VAT claim, because you can't prove the supply.

How do I set up VAT record keeping so it survives an FTA audit?

Set it up so any invoice can be found by tax period within a day, and so the FTA can see it without your accountant in the room. A workable routine:

Save each tax invoice, credit note and import document into a folder or system organised by VAT tax period, the same way your EmaraTax returns are organised.
Scan paper originals in full, every page in order, and keep them legible on screen; the FTA does not accept partial copies, according to a Grant Thornton summary of FTA Decision No. 4 of 2026 (check the decision on tax.gov.ae).
Keep a capital asset register if you have assets under the capital assets scheme, and keep it for at least 10 years.
Store EmaraTax return acknowledgements and FTA correspondence alongside the supporting invoices.
Name one person inside the company who can produce records on request, even if an outsourced accountant keeps the books.
Diarise the end of each retention period, and extend it if an audit, dispute or voluntary disclosure applies.

What most guides don't tell you

The five-year clock can be shorter than the FTA's audit window. Under Article 79 bis(7) of Federal Decree-Law No. 8 of 2017, where a person failed to register for VAT, the FTA can audit or assess within 15 years from the date the person should have registered. If you registered late, destroying records at year five may leave you without evidence for years the FTA can still examine.

Outsourcing doesn't move the legal duty. FTA Decision No. 4 of 2026 is reported to say that appointing an accountant or document provider leaves the legal responsibility with the taxable person. And if a legal representative holds your records, Cabinet Decision No. 74 of 2023 (Article 3(3)) has them keep the books for one year after the representation ends; your own obligation continues regardless, so take a copy when you switch accountants.

The real estate period isn't settled in older guidance. Articles published around the 2017 VAT regulations said real estate records should be kept for 15 years. Cabinet Decision No. 74 of 2023 now states 7 years for real estate records, counted from the end of the calendar year the document was created. We couldn't confirm which period the FTA applies to VAT real estate files, so if you hold property records, ask the FTA or a registered tax agent in writing before discarding anything.

Closing the company doesn't end the period. We found no provision in the VAT law that shortens retention on deregistration, and Article 21(3) keeps the FTA's right to claim tax and penalties after deregistration. Plan for someone to hold the records after you close.

Which deadlines apply to your company?

Retention periods, VAT filing dates and audit windows all run on different clocks. The free UAE compliance calendar lists the deadlines that apply to your company, personalised from a few questions.

Frequently asked questions

How do I correct a mistake on a previous VAT return? You correct it by filing a voluntary disclosure on EmaraTax, and you keep the working papers that show what was wrong and why. Under Cabinet Decision No. 74 of 2023, a voluntary disclosure filed in the fifth year can also add one extra year to your record retention.

When do I need to file a voluntary disclosure for VAT? You file one when you find an error in a VAT return you have already submitted and the correction can't be made on your next return under the FTA's current rules. Check the current thresholds and timing on the FTA's EmaraTax guidance before deciding, because they change.

How do I handle VAT on imports through customs? Keep the supplier's invoice and the customs documents for every import, because the Executive Regulation expects them as evidence for the VAT you account for or recover. For reverse charge imports, the Executive Regulation lists the supplier's invoice and a customs statement among the documents to keep.

What happens during an FTA VAT audit? The FTA requests your records and can ask for Arabic translations of anything in another language. If an audit is under way or the FTA has told you it intends to audit, Cabinet Decision No. 74 of 2023 adds four years to your retention period.

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

Last checked: 11 November 2026

General information, not tax or legal advice for your specific situation.