Supplier due diligence became a more formal VAT control in the UAE on 1 October 2026. Federal Tax Authority Decision No. 13 of 2026 sets out measures, procedures and conditions that taxable persons must use to verify the validity and integrity of supplies. This is not a reason to refuse legitimate purchases automatically; it is a reason to replace informal onboarding with documented, risk-aware checks.
The controlling source is the official FTA Decision No. 13 of 2026 page, which links the decision text. Businesses should read the legislation and obtain qualified tax advice for their facts rather than relying on a media summary or a generic checklist.
Map the rule to the purchase process
Start by identifying who approves a new supplier, who verifies documents, who confirms delivery and who authorises payment. If one person performs every step, an error or conflict may be difficult to detect. The control should cover onboarding, purchase, receipt, invoice review and record retention.
The UAE VAT invoice guide helps distinguish invoice fields from supplier verification. Use the business record-keeping guide to create a file that another reviewer can understand later.
| Control | Evidence to retain | Red flag |
|---|---|---|
| Identity | Verified person or authorised representative | Details do not match documents |
| Legal existence | Current incorporation or licence evidence | Expired or unrelated activity |
| VAT status | TRN verification and invoice check | Invalid number or inconsistent name |
| Premises/capability | Documented verification appropriate to risk | No credible ability to supply |
| Transaction | Contract, delivery and payment trail | Unexplained routing or missing goods |
Verify identity and authority
For an individual supplier, confirm identity using the method required by the decision and keep evidence proportionate to the rule. For a company, verify legal existence and the authority of the person acting for it. A trade licence name, bank account and VAT invoice should not contradict one another without a documented explanation.
Use the UAE tax-registration checklist as a model for controlled document collection, while remembering that VAT supplier checks serve a different purpose.
Supplier-verification checklist
- Assign a named owner for supplier onboarding and review.
- Verify identity, legal existence and representative authority.
- Confirm the supplier’s activity is consistent with the purchase.
- Check VAT registration and invoice details where applicable.
- Document capability or premises checks required by the rule.
- Match contract, order, delivery, invoice and payment records.
- Escalate inconsistencies before input tax is claimed.
Check the supply, not only the supplier
A legitimate company can still issue an incorrect invoice or bill for something not supplied. Match quantities, dates, descriptions and delivery evidence. Confirm that the business actually received the goods or services and that the expense relates to taxable activity before considering input-tax recovery.
The business expense-records guide explains how approvals and supporting documents connect. For contract changes, preserve versions using the Dubai dispute-records guide.
Use thresholds carefully
The decision contains conditions and exceptions that require close reading. Do not treat a monetary threshold as permission to ignore repeated small transactions or divide an order. Aggregation, frequency and related purchases may matter. Configure accounting controls to flag cumulative dealings where appropriate.
If an existing supplier’s licence, ownership, bank account, address or VAT status changes, re-verify the affected information. A due-diligence file is not permanent simply because it passed once.
Prepare for review
The file should show what was checked, when, by whom, against which source and how a discrepancy was resolved. Avoid storing more personal data than necessary, restrict access and follow applicable data-protection obligations.
The UAE VAT-return guide illustrates why transaction evidence should be ready before the filing deadline. Supplier verification belongs in daily purchasing, not in a last-minute return review.
A sound response is practical: read the official decision, update onboarding, train the relevant staff and test a sample of supplier files before a tax period closes.
Questions people often ask
When did FTA Decision No. 13 of 2026 take effect?
The decision is effective from 1 October 2026. Businesses should confirm the official text and its application to their transactions.
Is checking a VAT number enough?
No. VAT status is one part of a broader verification process covering the supplier and the validity and integrity of the supply.
Do existing suppliers need attention?
Yes. Review existing suppliers against the applicable requirements and re-check material changes such as licences, ownership, addresses or bank details.
Can one employee complete and approve every check?
The law and the business’s controls should guide the process, but separating preparation and approval can reduce error and fraud risk.
What should happen when information conflicts?
Pause the affected approval or tax claim, investigate through reliable sources, document the resolution and obtain professional advice when needed.
