GULF CONSULT VAT Team on
UAE VAT Voluntary Disclosure: When to File, How to File and What Penalties Apply in 2026
When a VAT voluntary disclosure is required, how to file one on EmaraTax, and how the April 2026 penalty changes reward disclosing early.
A voluntary disclosure is how a business tells the FTA about an error in a VAT return, assessment or refund claim it has already filed. Filed early, it is the cheapest way to fix a mistake. Filed after the FTA has announced an audit, it costs considerably more.
Cabinet Decision No. 129 of 2025 changed the penalties from 14 April 2026, replacing the old tiered percentages with a monthly charge.
When a Disclosure Is Required
A disclosure is needed when an error means too little tax was paid or too much was refunded. Historically, errors of AED 10,000 or less could instead be corrected in the next return; the Executive Regulation was amended in 2026, so check the current threshold before relying on it.
The disclosure must be filed promptly after the error is found, within the period set by the Executive Regulation.
How to File
Disclosures are filed on EmaraTax:
- Identify every affected return and quantify the error for each
- Prepare supporting workings and documents
- Submit the voluntary disclosure form for each tax period on EmaraTax
- Pay the additional tax promptly to avoid late-payment penalties
The Penalties Since 14 April 2026
Under Cabinet Decision No. 129 of 2025, a disclosure made before the FTA gives notice of an audit attracts a penalty of 1% of the tax difference for each month, or part of a month, from the original due date until the disclosure is filed.
A disclosure made only after an audit notice costs more: a fixed 15% of the tax difference on top of the monthly charge. Late payment is charged at 14% a year, calculated monthly.
A Worked Example
A business finds that it under-declared AED 50,000 of output VAT in a return that was due eight months ago. Disclosing before any audit notice, the penalty is 1% x 8 months x AED 50,000 = AED 4,000, plus the AED 50,000 tax. Waiting until after an audit notice would add a further AED 7,500.
Frequently Asked Questions
What is a VAT voluntary disclosure in the UAE?
A form filed on EmaraTax to correct an error in a VAT return, tax assessment or refund application that has already been submitted.
What is the penalty for a voluntary disclosure in 2026?
Before an audit notice, 1% of the tax difference per month from the original due date. After an audit notice, an extra fixed 15% of the tax difference applies.
Is it better to disclose before the FTA starts an audit?
Yes. Disclosing before an audit notice avoids the fixed 15% charge, and every month of delay adds another 1%.
Sources
- PwC: Revised administrative penalty framework for violation of tax laws
- KPMG: Correcting VAT errors in the UAE
- Crowe: Updated voluntary disclosure user guide for VAT and Excise Tax
This article is general information, not advice for your situation. Rules change; check the current position or speak to an advisor before acting.
Need help with this? See our VAT & Compliance Services.
VAT & Compliance Services