Our earlier Insight, A tax invoice is no longer enough, explains the new supplier and transaction checks under Federal Tax Authority Decision No. 13 of 2026, including the thresholds. These requirements took effect on 1 October 2026, so businesses should act now to put the checks into practice. This follow-on article looks at the practical question raised in our 14 October webinar: how can businesses make the checks part of work that already happens every day?
Start with the supplier record
Give each supplier a single record that staff can find and update. It should show the legal name and identity details checked, the authorised contact, the address and place of business reviewed, the evidence collected, who completed the check and when it must be refreshed. Store supporting documents with the record or link to a clearly identified location.
A common question in the webinar was how to manage suppliers already in your system. Grant clarified that businesses should begin creating records now for suppliers covered by the rules, even where the relationship began before 1 October. Set a review date so the supplier check does not become more than 12 months old.
Connect the purchase to the invoice
Supplier onboarding and transaction review are separate steps. A supplier file cannot explain whether a particular purchase made commercial sense. Before input VAT is claimed, the person reviewing the transaction should be able to connect the invoice to the business purpose, the goods or services received, the agreed price and terms, and the payment made.
In practice, that evidence may sit across a purchase order, contract, delivery note, service approval, payment record and invoice. Decide which documents are needed for your business, where they will be saved and how staff will record an unusual payment or an exception. A third-party payment or a supplier bank account outside the UAE is not automatically proof of a problem, but it should have a clear commercial explanation on file.
Monitor spend before a threshold is crossed
The thresholds in our earlier article are based on supplier spend over a rolling 12-month period, not a calendar or financial year. A spreadsheet, accounting system or purchasing report can help, provided it brings together the supplier’s invoices and highlights both actual and expected spend.
The person responsible for purchasing and payables should review the report regularly and alert the people who approve purchases when a supplier is approaching a threshold. That gives the business time to complete any additional checks before the next invoice is processed. It also reduces the chance that small invoices are treated separately when the supplier’s total spend changes what is required.
Make responsibilities clear
Responsibility for the end-to-end process should sit with the person responsible for purchasing and payables, who has the day-to-day connection with suppliers. They should coordinate supplier checks, spend monitoring and record-keeping, and make sure the people approving transactions complete and document their reviews.
If you don’t already have one, develop a short policy that sets out each step, who completes and reviews it, who can approve exceptions, where records are stored and how long they are retained. Keep it practical enough for staff to follow. During the webinar, Grant reminded attendees that tax records generally need to be kept for at least five years from the end of the relevant tax period.
If bookkeeping or VAT return preparation is outsourced, agree what information the external adviser needs and who in the business supplies it. The adviser may not have the commercial context behind a purchase, so responsibility for confirming the transaction should be clear before the return is prepared.
Test the process on real purchases
Before rolling out a new checklist across the business, try it on a small group of suppliers: a regular low-value supplier, a high-spend supplier and one with an unusual payment arrangement. Check whether staff can find the evidence, identify the person responsible and explain what happens when information is missing. Use what you learn to simplify the process and address gaps.
For TLB clients whose bookkeeping, purchase invoices or VAT returns are handled by us, we may ask you to confirm that the relevant checks have been completed and request supporting documents. If you are not currently working with TLB, we can help review your existing process and develop a practical action plan.
Editorial references
Earlier TLB Insight on the new VAT checks
