UAE Legal News
The UAE's mandatory e-invoicing machine is switching on; the only question is whether you're plugged in.
Electronic invoicing in the UAE is no longer a future plan - it is a build project with dates attached. A pilot phase begins on 1 July 2026, letting selected businesses and voluntary adopters test the system before mandatory use.
The regime rests on Cabinet Decision No. 106 of 2025, which applies to any person conducting business in the UAE regardless of VAT-registration status, with only limited exclusions. The UAE has adopted a Peppol-based 'continuous transaction control' model, meaning invoices are validated and reported through accredited channels rather than simply emailed as PDFs. Business-to-consumer invoices are excluded for now. Crucially, the deadline for large businesses (broadly those above AED 50 million in revenue) to appoint an Accredited Service Provider has been extended from 31 July to 30 October 2026, with the mandatory go-live for that group on 1 January 2027.
The sting is in the penalties and the plumbing: reports point to fines around AED 5,000 per month for non-compliance, and an unprepared accounting system simply cannot issue valid invoices once the mandate bites - which stops you billing customers.
Work out which wave you are in and treat ASP selection as a procurement project, not an afterthought, aiming to appoint well before 30 October 2026. Ask your accounting-software vendor now whether it will be Peppol/PINT AE compliant, and budget for the integration. Getting this wrong does not just risk fines - it can stop you invoicing at all.
International
A new circular spells out exactly how licensed firms must open and police client accounts.
Hong Kong's securities regulator is tightening the front door to its market. After reviewing how a sample of brokers actually onboard clients, the SFC has set out in writing what it now expects.
On 22 May 2026 the SFC issued a circular to licensed corporations outlining expected controls for account opening and the maintenance of client relationships. The circular followed the regulator's review of account-opening practices at 12 licensed securities brokers, which highlighted key deficiencies, and it sets standards aimed particularly at the opening and management of accounts held by Mainland-Chinese investors. Among the specific measures is the closure of zero-balance dormant investment accounts - those held by a Mainland investor with no asset balance as at 22 May 2026 or another specified date - and it was issued alongside a related announcement by the China Securities Regulatory Commission.
For UAE-based groups, the direct relevance is narrower than the crypto or AML items, but it still matters if you run or rely on a Hong Kong brokerage arm or hold HK investment accounts. The direction of travel - heavier scrutiny of onboarding and continuous client monitoring - is consistent with what regulators in the UAE and globally now expect.
If your group touches Hong Kong securities accounts, read the 22 May 2026 circular and benchmark your onboarding and ongoing-monitoring controls against it. Identify and deal with any zero-balance or dormant accounts now rather than waiting for a review. Document your client due diligence so it is inspection-ready.
Case of the Week
Lean on AI without checking it, and the bill - plus a penalty - lands on your lawyers.
Artificial intelligence is now in every lawyer's toolkit, but the ADGM Court of First Instance has drawn a hard line on using it carelessly. In a decision the legal market is treating as a landmark, the Court penalised a law firm whose court filing was built on AI output that nobody had checked.
In Arabyads Holding Limited v Gulrez Alam Marghoob Alam [2025] ADGMCFI 0032, the defendant's then legal representatives filed a Defence that was unnecessarily long and cited authorities which either did not exist or did not stand for the proposition for which they were cited. The Court held that the lawyer's failure to verify legal research produced through AI was reckless and amounted to a breach of the ADGM Rules of Conduct. Mr Justice Paul Heath KC reviewed how other common-law courts, including the English High Court, have recently dealt with the same problem.
The Court granted a wasted costs order against the law firm, stressing that the power to award costs against lawyers is not only compensatory but also punitive. In short: the cost of inventing or mis-citing authority does not fall on the client alone - it can fall on the firm, with a penalty element attached.
AI is fine as a research aid, but every authority, case number and quotation must be checked against the original before it goes into a court document. Insist your advisers have a verification step - and a sign-off - for anything AI-assisted. The downside is no longer just embarrassment; it is a personal costs penalty on the lawyers and a damaged case for the client.
Key Dates
- 28 April 2026VAT return + payment due for Q1 2026 (January-March tax period); 28-day rule from period end
- 29 June 2026FTA deadline for VAT and Excise Tax returns for the applicable June 2026 tax period (per FTA official announcement)
- 30 June 2026ESR Notification filing deadline for UAE entities with 31 December financial year-end (6 months from year-end per Cabinet Decision No. 57/2020)
- 28 July 2026VAT return + payment due for Q2 2026 (April-June tax period); 28-day rule from period end
- 30 September 2026Corporate Tax return and tax payment due for companies with 31 December 2025 financial year-end (9-month rule; FTA grants no routine extensions)
- 28 October 2026VAT return + payment due for Q3 2026 (July-September tax period); 28-day rule from period end
- 31 December 2026ESR Report submission deadline for UAE entities with 31 December financial year-end (12 months from year-end); also CT return due for entities with 31 March 2026 year-end
Fun Legal Fact
The oft-repeated claim that dying in the Houses of Parliament is illegal is technically a myth, but the grain of truth behind it is genuinely interesting: under the Coroners Act 1988, any death on Crown property historically triggered a right to a state funeral at public expense, which made Parliament administratively anxious about the precedent. Staff were therefore quietly encouraged to remove anyone who appeared gravely ill to a location off the estate before they expired - not to break the law, but to avoid creating one. The Law Commission of England and Wales noted the persistent urban legend when it reviewed obsolete legislation in the 2000s. So the law itself never existed, but the bureaucratic logic that spawned the rumour was entirely real.