VAT Administrative Exceptions – Key Updates & Guidance (December 2025)

FTA Issues Updated Guide VATGEX1

The Federal Tax Authority (FTA) has released the updated VAT Administrative Exceptions Guide (VATGEX1) dated December 2025, providing clearer rules, expanded definitions, and updated procedures for businesses applying for VAT-related administrative exceptions.

This newsletter highlights the major changes, eligibility rules, and procedural updates every VAT-registered business in the UAE should know.

What Are VAT Administrative Exceptions?

VAT administrative exceptions allow VAT-registered businesses (“Registrants”) to request special concessions in situations where they cannot meet certain administrative requirements under the VAT Law and Executive Regulations.

Exceptions are only available for four specific areas:

1. Tax Invoices
2. Tax Credit Notes
3. Alternative evidence to prove the Export of Goods
4. Extension of the 90-day export period

Note: Exceptions for VAT stagger and Tax Period length are no longer issued under this process—they must be amended directly in EmaraTax.

Why Apply for a VAT Administrative Exception?

Businesses should apply for a VAT administrative exception when they cannot meet certain VAT requirements due to practical or operational challenges.

An exception helps avoid penalties, maintain business continuity, and provides official FTA approval for alternative compliance methods. It ensures flexibility when standard documentation cannot be obtained, protects zero-rating on exports, and reduces audit risks. Overall, applying helps businesses remain compliant while managing real-world constraints.

Who Can Apply?

Only VAT Registrants with a TRN may submit requests. They must be filed by:

• The authorised signatory
• A Tax Agent listed for indirect taxes (VAT)
• A court-appointed Legal Representative

Tax consultants who are not registered Tax Agents cannot submit applications on behalf of clients.

What Are VAT Administrative Exceptions?

Eligible Cases (Summary)

Tax Invoices – Article 59(7)

Businesses may request:

• Not to include all required invoice particulars, or
• Not to issue/deliver Tax Invoices in certain situations

Conditions:

• Sufficient records must still be available
• Reasonable justification of impracticality must be provided

Tax Credit Notes – Article 60(2)

Similar to Tax Invoice exceptions, businesses may request:

• To omit certain details, or
• Not to issue/deliver Credit Notes

Conditions:

• Adequate records available
• Clear justification required

Alternative Evidence for Exports – Article 30(6)

From 15 November 2024, the rules for export evidence changed:

To prove a zero-rated export, businesses must retain one of the following:

• Customs declaration + Commercial Evidence, OR
• Shipping Certificate + Official Evidence, OR
• Customs suspension documentation

If unable to meet these requirements → an administrative exception may be requested.

Extension of 90-Day Export Period – Article 30(7)

Applicable if:

• Circumstances outside the supplier/recipient’s control prevent export within 90 days
• The nature of the supply makes timely export impractical

5.Submitting an Application (EmaraTax Process)

Applications must be submitted through EmaraTax:

1. Login → Dashboard → Taxable Person Account
2. Select VAT → Other Services
3. Choose VAT Administrative Exceptions
4. Start a New Request
5. Upload required documents and submit

Important Time Limits

• Drafts must be submitted within 40 Business Days
• Responses to FTA information requests must be submitted within 40 Business Days

Required Supporting Documents

• A proper application must include:
• Letter on company letterhead, signed by the authorised signatory, including:
  • Business background (mainland or Designated Zone)
  • Type of exception requested
  • Why compliance is impractical or impossible
  • Requested effective date
  • Accuracy declaration
• Documentary proof showing the business cannot meet its legal obligations
• Alternative evidence (if applicable)
• File type must be PDF/DOC/XLS/JPG/PNG (max 15 MB)

FTA Review Timeline

• 25 Business Days → Requests related to extension of export periods
• 45 Business Days → All other cases
• If additional information is requested, timelines restart once documents are re-submitted.

Validity of Administrative Exceptions

• Generally valid for 3 years
• Can request an effective date up to 5 years retroactively
• May be shorter depending on the nature of Goods/exports
• Exceptions for Invoices & Credit Notes automatically expire when e-Invoicing becomes mandatory for the Registrant

Common Application Errors (Avoid These!)

• A proper application must include:
• Letter on company letterhead, signed by the authorised signatory, including:
  • Business background (mainland or Designated Zone)
  • The FTA highlighted frequent mistakes, including:
  • Applying under the wrong category
  • Requesting exceptions for non-eligible topics (e.g., VAT refunds, VAT registration)
  • Missing or insufficient supporting documents
• Tax Agents listed only for Corporate Tax attempting to submit VAT-related exceptions
• Members of a Tax Group (not the representative member) filing requests
• Make sure your submission is correct to avoid rejection or delays.

Final Thoughts

The December 2025 update provides greater clarity and simplifies the application process for VAT administrative exceptions. Businesses are strongly encouraged to review these requirements carefully and ensure all criteria and documentation are met before submitting through EmaraTax.

If you need support preparing your administrative exception application—or determining whether your case qualifies—AZ Advisory Services can assist with:

• Drafting formal request letters
• Preparing supporting documentation
• Reviewing export documentation compliance
• Submission through EmaraTax via our registered Tax Agents