UAE VAT Administrative Exceptions: Complete Guide for Businesses

VAT Administrative Exceptions in the UAE: A Complete Guide for Businesses (2025–2026 Update)

Based on the Latest FTA VAT Administrative Exceptions Guide — December 2025

In recent times, we are coming across numerous updates in the UAE; however, one of the most important updates is on the VAT, which is of utmost importance to the taxable persons.

The VAT compliance in the UAE has significantly evolved when compared to where it started in 2018, especially with the latest FTA updates on VAT Administrative Exceptions. We come across many businesses that are still unclear about:

• What qualifies as an exception

• Who can apply

• Which errors lead to rejections

• How the process works in EmaraTax.

In this blog, we aim to provide a simple and practical explanation of the new VAT Administrative Exceptions Guide issued in December 2025, in order to help the UAE business entrepreneurs to understand the eligibility, process, documentation and common mistakes in one go.

What Are VAT Administrative Exceptions?

VAT administrative exceptions may sound complex, but in simple terms, these are special concessions allowed by the FTA only in very limited cases where a business is genuinely unable to meet specific VAT obligations due to operational circumstances.

These exceptions can be applied only under the following four categories:

1. Tax Invoice exceptions

With reference to Article 59(7) of the Executive Regulation, a business may request permission from the FTA for the below reasons:

• Not to include all required fields on a tax invoice, or

• Not to issue/deliver a tax invoice in specific cases.

2. Tax Credit Note exceptions

With reference to Article 60(2) of the Executive Regulation, the same rules apply for Tax Credit Notes, as well.

3. Alternative evidence to prove the export of goods

With reference to Article 30(6) of the Executive Regulation, in cases where the Official Evidence or Commercial Evidence cannot be obtained, alternative documents to prove the export of the goods can be submitted.

4. Extension of the time period for exporting goods

With reference to Article 30(7) of the Executive Regulation, the entity can request for time extension to export the goods, when the business cannot export goods within 90 days due to reasons beyond their control.

Please note that the FTA will automatically reject the request that falls outside these four categories discussed.

Who Can Apply for VAT Administrative Exceptions?

Now this is the next question that pops up in our mind!

Only a VAT Registrant with an active TRN can apply for Administrative Exceptions.

The applications must be submitted only by:

• The Authorised Signatory, OR

• An FTA-approved Tax Agent (Indirect Tax), OR

• A Legal Representative appointed by the court.

In the cases where the applications submitted by any of the following people will be rejected by the FTA:

• Non-registered persons

• Tax Consultants (not Tax Agents)

• Natural persons representing a legal entity

• Tax Agents registered only for Corporate Tax

Eligible Scenarios Explained

Let’s break down each allowed category in simple terms:

1. Exceptions Related to Tax Invoices

A business may request an exception only under the following conditions:

• It is impractical to issue tax invoices for certain supplies

• It is impossible to include all mandatory fields

• Sufficient records are maintained to establish supply details

For Example:

A logistics company issuing daily delivery receipts may find it impractical to issue detailed tax invoices for every small transaction.

2. Exceptions Related to Tax Credit Notes

Similar to invoices, these exceptions may apply in the cases where:

• It is not practical to issue tax credit notes

• The ERP cannot display all required fields

• Bulk transaction adjustments are necessary

3. Alternative Evidence for Export of Goods

Effective 15 November 2024, new export documentation rules apply.

Based on the same to prove a direct or indirect export, businesses must provide:

• Customs declaration + commercial evidence, OR

• Shipping certificate + official evidence, OR

• Customs declaration proving suspension arrangement

If none of these can be obtained due to genuine reasons, the business may request an exception.

For example:
A shipping carrier loses the air waybill, but the exporter provides customs exit confirmation.

4. Extension Beyond 90 Days for Export

The Exceptions can be applied only when

• There are delays beyond the supplier/recipient’s control

• Nature of goods requires longer export preparation

• International logistics constraints exist

For example:
Industrial machinery requiring dismantling, special handling or third-party certification prior to export.

How to Apply for a VAT Administrative Exception (EmaraTax Process)

Step-by-Step:

1. Login to EmaraTax

2. Open Taxable Person Account

3. Select VAT → Other Services → VAT Administrative Exceptions

4. Click New Request → Proceed

5. Upload:

• Letter on company letterhead

• Explanation of the issue

• Supporting documents

• Alternative evidence (if applicable)

6. Submit the application

Important timelines:

• Draft requests must be submitted within 40 business days

• Further information requested must be provided within 40 business days

• FTA response time:

  • 25 business days (export extension cases)

  • 45 business days (all other exceptions)

Validity of Administrative Exceptions

• Generally valid for 3 years

• Can request backdating up to 5 years

• Exceptions for invoices & credit notes expire automatically once e-invoicing becomes mandatory

Common Errors That Lead to Rejection

Based on FTA findings, the most common mistakes include:

• Requesting exceptions not listed in Article 59, 60, or 30

• Asking for VAT refund under exception request

• Requesting waiver of VAT registration requirement

• Incorrect category selection

• Missing supporting documents

• No explanation of why compliance is impossible

• Consultant (not Tax Agent) filing the request

• Tax group member (not representative member) filing the request

• Using the wrong evidence for export

FTA is very strict, even small errors lead to rejection.

Why VAT Administrative Exceptions Matter for UAE Businesses

These exceptions matter because they help companies:

• Remain compliant when operational challenges exist

• Avoid penalties due to unavoidable circumstances

• Protect zero-rating benefits for exports

• Ensure documentation validity during FTA audits

• Navigate the transition to the UAE’s upcoming e-invoicing mandate

Businesses dealing with exports, high-volume invoicing, ERP limitations, or special operations benefit the most.

How Flyingcolour Tax Consultant Can Help

As an FTA-Approved Tax Agent, we assist with:

• Preparing administrative exception applications

• Drafting justification letters & supporting evidence

• Advising correct documentation for exports

• VAT audits & FTA queries

• VAT refunds & compliance reviews

• E-invoicing readiness

Our experts ensure your application is bulletproof, increasing chances of approval.

Frequently Asked Questions (FAQs)

Q. Can I apply for an administrative exception if I lost the export documents?

Yes, only if you can provide valid alternative evidence and explain why the official documents cannot be obtained.

Q. Can a VAT Consultant (not a Tax Agent) submit the exception request?

No. Only an Authorised Signatory, FTA-Approved Tax Agent (Indirect Tax), or court-appointed Legal Representative can submit.

Q. Can I request an exception to avoid issuing tax invoices under e-invoicing rules?

No. Once e-invoicing becomes mandatory, all exceptions for invoices/credit notes automatically expire.

Q. Do administrative exceptions apply to VAT refunds or penalty waivers?

No. These require separate applications — exceptions cannot be used to bypass VAT refund rules or penalties.

Q. How long does the FTA take to approve the request?

25–45 business days, depending on the category, but may take longer if additional information is requested.

Need Help Submitting a VAT Administrative Exception in the UAE?

Our VAT Tax Agents handle the full process from drafting to submission, ensuring compliance and reducing rejection risk.

To learn more about UAE VAT Administrative Exceptions: Complete Guide for Businesses, book a free consultation with one of the Flyingcolour team advisors.

Disclaimer: The information provided in this blog is based on our understanding of current tax laws and regulations. It is intended for general informational purposes only and does not constitute professional tax advice, consultation, or representation. The author and publisher are not responsible for any errors or omissions, or for any actions taken based on the information contained in this blog.