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FTA Penalty Notice? How to Request Reconsideration or a Waiver in UAE (Step by Step)

An FTA penalty notice starts a clock of 40 business days. This guide shows how to count it, which grounds actually work, how to write the request on EmaraTax and what to do if the FTA says no.

JW
James Whitfield, ACA CTA
Head of Corporate Tax Advisory · Paci Finance
Updated 20 min read Checked against FTA sources
FTA Penalty Notice? How to Request Reconsideration or a Waiver in UAE (Step by Step)
Quick answer

To challenge an FTA penalty in the UAE, submit a reconsideration request on EmaraTax within 40 business days of the penalty decision, under the Tax Procedures Law (Federal Decree-Law 28/2022). Set out the facts, your legal or factual grounds and the evidence. If the FTA refuses, the next step is the Tax Disputes Resolution Committee. File overdue returns and pay undisputed tax first, because other penalties keep running.

This applies to you if
  • You received an FTA penalty for late registration, a late return, late payment or an incorrect return
  • You believe a penalty was issued even though you met a waiver condition
  • The FTA rejected your reconsideration request and you want to know the next step
  • Penalties have grown far beyond the original tax and you want to know what can be reduced
  • You are deciding whether to pay a penalty now or dispute it

Not sure where you stand? Get a free 15-minute review or ask us on WhatsApp.

40 bus. days
Window to request reconsideration of an FTA decision
AED 10,000
Late registration penalty (VAT and Corporate Tax)
14% a year
Late payment penalty, calculated monthly
1%/month
Voluntary disclosure penalty before an audit notice

Which FTA penalties can you ask the FTA to reconsider?

You can request reconsideration of any FTA decision, including every administrative penalty for VAT and Corporate Tax. Whether it is worth doing depends on your grounds: a request succeeds on facts and evidence, not on hardship alone.

The table lists the penalties owners bring to us most often, with the grounds that tend to matter for each.

VAT: Cabinet Decision 129/2025, in force 14 April 2026. Corporate Tax: Cabinet Decision 75/2023 as amended
PenaltyAmount as of September 2026Grounds that can matter
VAT late registrationAED 10,000 plus backdated output VATYou applied within 30 days of crossing AED 375,000, or income counted was exempt
Corporate Tax late registrationAED 10,000First return filed within 7 months of the end of the first tax period, so the waiver condition was met
Late VAT returnAED 1,000 first, AED 2,000 repeat within 24 months, per returnReturn was filed on time, period assigned wrongly, or a system failure is documented
Late Corporate Tax returnAED 500 a month for 12 months, then AED 1,000 a monthTax period on the registration was wrong, or a correction request was pending with the FTA
Late payment14% a year, calculated monthlyPayment was made on time but allocated to the wrong liability
Incorrect returnVAT AED 500 first, AED 2,000 repeat; Corporate Tax from AED 500 plus 1% a month on the differenceThe return was right and the FTA’s calculation is wrong
Late VAT or Corporate Tax deregistrationAED 1,000 a month, capped at AED 10,000Application was made on time, or the trigger date used is wrong

Violations that happened before 14 April 2026 are still assessed under the earlier VAT penalty rules, so older notices can show much larger amounts. Check the violation date on each penalty before you compare it with the current table in our UAE VAT penalties guide or our Corporate Tax penalties guide.

How the 40 business day reconsideration window works

You have 40 business days from being notified of the FTA decision to submit a reconsideration request, under the Tax Procedures Law. Business days exclude weekends and public holidays, so the window is roughly 8 calendar weeks when no holidays fall inside it.

Counting the deadline

Count from the date on the penalty decision you received, not the date you first noticed it on EmaraTax. For example, a decision dated Monday 14 September 2026 with no public holidays in between gives a last day of Monday 9 November 2026. Treat that as a hard stop and aim to submit two weeks earlier, because gathering evidence always takes longer than expected.

One request per decision

Each penalty decision has its own window. An owner with a late registration penalty in March and three late return penalties issued later has four clocks, not one. List every decision with its date before you start writing.

What a strong request contains

  • The decision: penalty type, amount, tax period and decision date
  • The facts: a short, dated timeline of what actually happened
  • The grounds: why the penalty should not apply or should be reduced, tied to the rule
  • The evidence: submission receipts, emails, screenshots, bank proofs, contracts
  • The request: exactly what you want, such as cancelling the penalty or correcting the period

Reconsideration, waiver or voluntary disclosure: which route fits your notice?

Reconsideration is the formal route for disputing a decision already issued; a waiver is a condition the FTA has published for removing a specific penalty; voluntary disclosure is how you correct your own error before or after the FTA finds it. Using the wrong one wastes the 40 business days.

RouteUse it whenTime limitWhat it can achieve
Reconsideration requestYou disagree with a penalty or other FTA decision40 business days from the decisionThe FTA reviews and can uphold, amend or cancel its decision
Published waiver conditionThe FTA has announced a waiver, such as the Corporate Tax late registration waiver for a first return filed within 7 months of the first period endSet by the waiver termsRemoval of that penalty when the condition is met
Voluntary disclosureYou find an error in a return you filedBefore an audit notice to keep the lower rateCorrects the return; penalty of 1% a month before an audit notice, 15% plus 1% a month after
Tax Disputes Resolution CommitteeThe FTA rejected your reconsideration requestThe limit stated in the FTA’s rejectionAn independent review of the dispute

The conditions of published waivers are set out on the FTA’s waiver of penalties page, listed in the sources below. Where a waiver condition was met but the penalty still shows, reconsideration is how you ask the FTA to apply it. For errors you discover yourself, see when and how to file a voluntary VAT disclosure.

Should you pay the penalty or dispute it, and what happens after a rejection?

Pay the underlying tax straight away even while you dispute the penalty, because late payment on unpaid tax runs at 14% a year, calculated monthly, and a pending request should not be assumed to pause that clock. Whether to pay the penalty itself is a separate decision, and paying does not remove your right to request reconsideration within the window.

When disputing is worth it

Dispute when you have documents that contradict the FTA’s facts: a submission receipt dated before the deadline, an application date within 30 days of the trigger, or a first Corporate Tax return filed inside the 7-month waiver window. Requests based only on not knowing the law, cash flow problems or an adviser’s mistake are much weaker, although a clearly documented error by the FTA’s own systems can help.

The Tax Disputes Resolution Committee

If the FTA rejects your reconsideration request, you can take the dispute to the Tax Disputes Resolution Committee. Read the rejection letter carefully, because it sets out the time limit and any conditions for objecting. The Committee reviews the documents from your request, so a well-evidenced first request makes this step far stronger. Beyond the Committee, disputes can go to the courts.

Grounds you can adapt

GroundFits whenEvidence to attachSample wording
Return filed on timePenalty for a late return you submitted before the deadlineEmaraTax submission receipt with date and timeThe return for the period was submitted on [date], before the due date of [date], as shown in the attached receipt.
Waiver condition metCorporate Tax late registration penalty still shownFirst return submission receipt and first tax period datesThe first return was filed on [date], within 7 months of the end of the first tax period on [date].
Registration applied for in timeVAT late registration penaltySales table showing the trigger month and application dateTaxable supplies first exceeded AED 375,000 on [date] and the application was started on [date], within 30 days.
Wrong tax periodCorporate Tax late return penalty based on an incorrect periodMemorandum of association, amendment request and FTA correspondenceThe financial year ends on [date]; a correction was requested on [date] and the return was filed within 9 months of that year end.
Payment misallocatedLate payment penalty despite paying on timeBank transfer confirmation and payment referencePayment of AED [amount] was made on [date] with reference [number] against this liability.

How to submit a reconsideration request on EmaraTax

A reconsideration request is submitted on EmaraTax against a specific decision. These steps take a notice from your inbox to a complete, evidenced request.

How to request reconsideration of an FTA penalty
1

List every decision and its date

Open the penalties section of your EmaraTax account and note each penalty, its amount, tax period and decision date. Calculate 40 business days for each.

2

Stop the penalties that are still running

File any overdue returns and pay undisputed tax. A request about an old penalty does not stop new monthly penalties from being added.

3

Identify your ground

Match each penalty to a ground: filed on time, waiver condition met, registered in time, wrong period, or payment misallocated. Drop penalties with no factual ground.

4

Gather the evidence

Download submission receipts, save emails and screenshots with dates, pull bank confirmations and contracts. Translate key documents into Arabic if the FTA may need them.

5

Write the request

Keep it factual: the decision, a dated timeline, the ground, the evidence list and the outcome you ask for. One page of clear facts beats five pages of explanation.

6

Submit on EmaraTax and save the receipt

Select the decision, complete the reconsideration form, upload the evidence and submit before the deadline. Download the acknowledgement.

7

Track the decision and plan the next step

Watch for the FTA’s decision. If it is rejected, note the time limit in the letter and prepare the objection to the Tax Disputes Resolution Committee.

Evidence to collect before you write the request

The FTA decides on the documents you send, so collect them before drafting. Anything without a date is weak evidence.

  • The penalty decision or notice, with its date and reference
  • EmaraTax submission receipts for every relevant return
  • Registration certificates showing tax periods and effective dates
  • Bank transfer confirmations with payment references
  • Emails and correspondence with the FTA, including correction requests
  • Screenshots of system errors, with date and time visible
  • Sales tables, contracts or invoices proving when a threshold was crossed
  • Memorandum of association showing the financial year
  • Arabic translations of key documents where needed

Dates that matter after an FTA penalty notice

The reconsideration window is the date that cannot be missed, but return and payment dates keep running alongside it.

As of September 2026
DeadlineRuleExample
Reconsideration request40 business days from the decisionDecision on 14 September 2026, last day 9 November 2026 if no public holidays fall in between
Tax Disputes Resolution Committee objectionTime limit set out in the FTA’s rejectionRead the rejection letter on the day it arrives
VAT return and payment28th of the month after the tax periodQuarter ending 30 September 2026, due 28 October 2026
Corporate Tax return and payment9 months after the financial year endYear ending 31 December 2025, due 30 September 2026
Corporate Tax late registration waiverFirst return within 7 months of the end of the first tax periodFirst period ending 31 December 2025, return by 31 July 2026

The 2026 penalty amounts you may be disputing

Before disputing, confirm the amount on your notice matches the current rule for the violation date. VAT penalties follow Cabinet Decision 129/2025 for violations from 14 April 2026, and Corporate Tax penalties follow Cabinet Decision 75/2023 as amended.

As of September 2026
TaxViolationPenalty
VATLate registrationAED 10,000 plus backdated output VAT
VATLate returnAED 1,000 first, AED 2,000 repeat within 24 months, per return, nil returns included
VATLate payment14% a year, calculated monthly
VATIncorrect returnAED 500 first, AED 2,000 repeat
VATVoluntary disclosure1% a month before an audit notice; 15% plus 1% a month after
VATTax invoice or credit note not issuedAED 2,500 per case
VATRecords not keptAED 10,000 for a first violation
Corporate TaxLate registrationAED 10,000, waived if the first return is filed within 7 months of the first period end
Corporate TaxLate returnAED 500 a month for 12 months, then AED 1,000 a month
Corporate TaxLate deregistrationAED 1,000 a month, capped at AED 10,000

Penalties stack across decisions. A trading company with a late VAT registration (AED 10,000), a first late return (AED 1,000), a repeat late return within 24 months (AED 2,000) and AED 24,000 of VAT unpaid for 6 months faces AED 13,000 in fixed penalties plus about AED 1,680 of late payment (AED 24,000 x 14% / 12 = AED 280 a month, x 6). Reconsideration can only address the decisions that were wrong; paying the VAT is what stops the AED 280 a month.

Not sure if your penalty is even correct?

A qualified accountant can check each decision date, amount and ground against the 2026 rules in a free 15-minute review.

6 mistakes that sink FTA reconsideration requests

Most failed requests fail on timing or evidence, not on the merits. Avoid these.

  • Paying and hoping. Paying without checking the decision means an incorrect penalty stays on your record, and a repeat within 24 months can be charged at the higher rate.
  • Missing the 40 business day window. Once it closes, the decision stands, however strong your facts were.
  • Disputing while returns are still overdue. New late return penalties keep being issued, and the request looks weak when the underlying problem is still open.
  • Writing a hardship letter instead of grounds. Not knowing the rules or being short of cash rarely changes a penalty; dated evidence does.
  • Sending one request for several decisions without listing each. Every decision has its own reference and window, and a vague request can leave some unaddressed.
  • Leaving the underlying tax unpaid. Late payment runs at 14% a year calculated monthly, so the amount under dispute grows while you wait.

How to avoid the next FTA penalty notice

The cheapest penalty is the one never issued. This routine removes the triggers behind almost every notice we review, and repeat violations within 24 months are charged at higher rates.

  • Track rolling 12-month taxable supplies against AED 375,000 every month
  • File and pay VAT by the 28th after each period, including nil returns
  • Diary the Corporate Tax return 9 months after year end
  • Reconcile the sales ledger, POS or platform reports and the VAT 201 each period
  • Issue tax invoices within 14 days and a credit note for every refund
  • Correct errors by voluntary disclosure before the FTA contacts you
  • Check the EmaraTax penalties tab monthly so no decision date is missed
  • Keep every submission receipt and payment confirmation in one folder

Request rejected, window missed or more notices arriving?

If the FTA rejected your request, prepare the objection to the Tax Disputes Resolution Committee within the time limit in the rejection letter, using the same evidence with any gaps filled. If you missed the 40 business days, the decision generally stands, so focus on stopping further penalties.

Stopping further penalties means filing every outstanding return and paying the tax. For Corporate Tax, our missed Corporate Tax deadline guide sets out the first 7 days, and dormant companies should read the nil Corporate Tax return guide. For VAT registration penalties, see late VAT registration and backdated VAT.

If the notice is part of an audit rather than a standalone penalty, read how to respond to an FTA tax audit notice before sending anything.

Holding an FTA penalty notice right now?

Send it to us with the decision date and we will tell you whether reconsideration grounds exist and how many business days you have left.

Worked example: a trading company's penalty notice, week by week

Take an illustrative Ajman trading company that receives penalty decisions dated Monday 14 September 2026: AED 10,000 for late VAT registration and AED 1,000 for a late return, with AED 24,000 of VAT still unpaid. The owner’s evidence shows the registration application was started within 30 days of crossing the threshold, so that penalty has a factual ground. The late return does not.

Illustrative business; outcomes of reconsideration are decided by the FTA case by case
WhenActionMoney at stake
Week 1Pay the AED 24,000 VATStops late payment of AED 280 a month (AED 24,000 x 14% / 12)
Week 1Pay the AED 1,000 late return penalty, which has no groundAED 1,000
Weeks 2 to 3Gather the sales table and application screenshotsEvidence for the AED 10,000 request
Week 4Submit reconsideration of the late registration penalty on EmaraTaxAED 10,000 under review
By 9 November 2026Last day of the 40 business day window if no public holidays fall in betweenMissing it would leave AED 10,000 standing
If rejectedObject to the Tax Disputes Resolution Committee within the limit in the letterAED 10,000 still under dispute
Cost of doing nothing for 6 monthsVAT unpaid and no request filedAED 1,680 late payment plus AED 11,000 of penalties left standing

The owner controls two numbers: the AED 280 a month that stops when the VAT is paid, and whether a well-evidenced request reaches the FTA before the window closes. Everything else is the FTA’s decision.

Write the request yourself, use a freelancer or hire a firm?

A single penalty with a clean submission receipt is often simple enough to dispute yourself. Several decisions, older penalties under the earlier rules or a rejection heading to the Committee usually justify professional help.

OptionCostTimeRiskSuits
DIY on EmaraTaxNo fee, your time onlyMedium: evidence gathering and draftingWeak grounds or missed windowsOne penalty with an obvious documentary ground
Freelance consultantTypical market range: varies widely, often per requestLowQuality of grounds and follow-up variesSimple, single-decision disputes
Accounting firm (Paci)Fixed quote within 24 hours after a free 15-minute review of your noticeLowLower: a qualified accountant checks every decision date, ground and the returns still openSeveral penalties, VAT and Corporate Tax together, rejections

If you are choosing an adviser, our guide on how to choose a tax agent in the UAE lists the red flags. To have your notice reviewed and the request prepared, see our VAT audit and penalty support service.

What owners holding FTA penalty notices ask us

I registered for VAT late and filed a return late, so the FTA charged AED 10,000 plus AED 1,000. My reconsideration was rejected. Is there any other way?

After a rejected reconsideration you can take the case to the Tax Disputes Resolution Committee, within the time limit stated in the rejection. It is only worth it if your evidence contradicts the FTA’s facts. The AED 1,000 matches the first late return penalty, which rises to AED 2,000 for a repeat within 24 months, so make sure every later return is on time.

My father's small AC repair shop turns over AED 80,000 to 100,000 a year. It registered for VAT years ago and now has around AED 70,000 in VAT penalties. What can we do?

File every outstanding return first, because late return penalties apply per return, nil returns included: AED 1,000 first and AED 2,000 for a repeat within 24 months under the current rules. Then review each penalty decision: violations before 14 April 2026 were assessed under the earlier rules, and reconsideration must be requested within 40 business days of each decision. At that turnover it is also worth asking an accountant whether the shop should stay VAT registered.

About AED 24,000 of VAT was unpaid and with penalties it is now around AED 146,000. The FTA has warned of legal action. Can the penalties be reduced?

Deal with the tax first: pay or arrange the AED 24,000, since late payment keeps accruing, now at 14% a year calculated monthly for violations from 14 April 2026. Much of the balance probably comes from older violations assessed under the earlier rules. Any decision still inside its 40 business day window can be reconsidered, with the Tax Disputes Resolution Committee as the next step. No adviser can promise a reduction.

I only found out about Corporate Tax at my 2026 licence renewal. I registered, but there is a AED 10,000 penalty and another AED 5,000. How do I write a reconsideration request?

Submit it on EmaraTax within 40 business days of each decision, setting out the facts, the returns you have now filed and your ground. Check what the AED 5,000 is for: late return penalties are AED 500 a month for the first 12 months, so a return outstanding for 10 months reaches that figure, and it keeps growing until the return is filed. Not knowing about the tax is a weak ground on its own.

My Sharjah free zone company missed Corporate Tax registration because the free zone never told us. How do I qualify for the waiver?

File the first Corporate Tax return within 7 months of the end of your first tax period; that is the condition for the AED 10,000 late registration penalty to be waived. If you met it and the penalty still shows, request reconsideration within 40 business days with the submission receipt. If the 7 months have passed, reconsideration remains open but needs a factual ground.

Will pending FTA penalties for late Corporate Tax filing stop my trade licence renewal?

Rules differ between licensing authorities, so confirm with yours before renewal. Either way, file the late return now, because the penalty grows by AED 500 a month for the first 12 months and AED 1,000 a month after that, and an up-to-date EmaraTax account removes the question.

Frequently asked questions

How do I appeal an FTA penalty in the UAE?+

Start with a reconsideration request to the FTA on EmaraTax within 40 business days of the penalty decision. If the FTA rejects it, object to the Tax Disputes Resolution Committee within the time limit in the rejection. Build the request on dated evidence, not hardship.

Can FTA penalties be waived?+

Some can. The FTA publishes waiver conditions, such as the Corporate Tax late registration waiver when the first return is filed within 7 months of the end of the first tax period. Other penalties can be cancelled or reduced through reconsideration when the facts support it. Outcomes are decided case by case.

Can I cancel an FTA penalty that was issued by mistake?+

Yes, through a reconsideration request with the evidence that shows the mistake, such as a submission receipt proving a return was filed on time. Submit it within 40 business days. Paying the penalty first does not stop you from requesting reconsideration.

Does a reconsideration request stop penalties from running?+

Do not assume it does. Late payment on unpaid tax runs at 14% a year calculated monthly, and late Corporate Tax returns add AED 500 a month, so pay the tax and file overdue returns while the request is reviewed.

What is the Tax Disputes Resolution Committee?+

It is the independent body that hears objections after the FTA has rejected a reconsideration request. It reviews the documents in your dispute, which is why the first request should be complete and well evidenced. The time limit to object is stated in the FTA’s rejection.

What if I received the penalty during an FTA audit?+

Treat the audit and the penalty together, because the audit findings usually drive the penalty. Our guides on how FTA audits work and responding to an FTA audit notice cover the audit side.

Can I dispute a late deregistration penalty after closing my company?+

Yes, within 40 business days of the decision, if the application date or trigger date used is wrong. Late deregistration is AED 1,000 a month capped at AED 10,000. See our Corporate Tax deregistration guide and catch-up bookkeeping guide if the final returns still need books.

Consult Paci for free

Get your FTA penalty notice reviewed for free

In a free 15-minute review we list every decision and its 40 business day deadline, check the grounds and flag returns that are still generating penalties. You get a fixed quote to prepare the request within 24 hours.

  • A free 15-minute review with a qualified accountant
  • A fixed quote within 24 hours, no hourly billing
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Prefer chat? Message us on WhatsApp. We only use your details to reply to you.

JW

James Whitfield, ACA CTA

Head of Corporate Tax Advisory · Paci Finance

James is dual-qualified as a Chartered Accountant and Chartered Tax Adviser (CTA) with 15 years in London and Dubai tax advisory. He leads Paci's corporate tax practice, focusing on DIFC and ADGM structures, group tax planning, Tax Group formation, and FTA audit defence for complex multi-entity UAE groups.

Official sources

Checked against these sources on 15 September 2026. This guide is general information for UAE businesses, not advice on your specific facts.

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