FTA Decision 13: a 90-day implementation plan for AP and procurement

First published 5 October 2026. Updated 19 October 2026. Reading time: about 7 minutes.

Looking for the rules themselves? Our FTA Decision 13 supplier verification guide explains each article, threshold and date. This post covers how to put the checks into daily operation.

In brief

• FTA Decision No. 13 of 2026 has applied since 1 October 2026. A 90-day plan does not postpone it. Run interim checks from day one and build the full process alongside them.
• Days 1-30: list your suppliers, your current supplier files and who owns each check, and start a manual check before input tax is booked.
• Days 31-60: design the applicability rules (AED 10,000, AED 100,000 and AED 375,000), the evidence standard for each control, and the documented policy the Decision requires.
• Days 61-90: run the process, sample the records, fix the gaps and set the rolling 12-month re-verification.

The question this guide answers

How do AP, procurement and tax teams turn the Decision 13 supplier and supply checks into a routine they can show to the FTA?

What the plan has to deliver

The plan works backwards from what the Decision requires (FTA Decision No. 13 of 2026, checked 15 Oct 2026):

The phasing below is our recommendation, not something the Decision prescribes.

Days 1-30: inventory and an interim control

1. List active suppliers with their 12-month spend, and flag those above AED 375,000 and those above AED 100,000. Include expected spend for the next 12 months, because both thresholds look forwards as well as backwards.
2. Sample current supplier files. Take a handful of suppliers from each spend band. For each, check whether the file holds what Article 3 asks for: the incorporation record, the representative's ID, place-of-business evidence, and the bank confirmation where needed. Note what is missing.
3. Map who does what today across procurement (onboarding), AP (invoice booking) and tax (the input-tax claim). Note any decisions that live only in email.
4. Start an interim gate. Before input tax is booked on a supply from a new or unverified supplier, a named reviewer confirms the Article 3 checks, or records why the AED 10,000 exception applies.

You leave with: a supplier list split by threshold band, a gap list, and an interim gate with a named owner. ◇ Human decision: the tax owner confirms the interim gate is in force.

Days 31-60: design the rules, evidence and policy

1. Applicability rules. Write down how you will:
   • test the AED 10,000 exception per supply, including the AED 100,000 per-supplier cap;
   • test the AED 375,000 trigger per supplier;
   • re-test both thresholds on a rolling 12-month basis.

   The Decision does not say whether the AED 100,000 and AED 375,000 totals include VAT, so agree a basis with your tax adviser and apply it consistently.

2. Evidence standard per control. For each check, define the acceptable source, how it is recorded and how long it stays valid. The full evidence map is in our supplier verification guide.
3. Risk-indicator monitoring. Keep a change history for supplier addresses and key contacts. The Decision flags more than two changes of either within 12 months, as well as disproportionate or unexpected transactions. Decide who writes the justified explanation when an indicator applies.
4. Per-supply checks in AP. Add the Article 4 questions to invoice or PO approval:
   • Is there a genuine commercial reason?
   • Is payment electronic? Is any third-party or foreign-account payment explained?
   • Is the price in line with market?
   • Is the supply within the supplier's licensed activity?
   • Is the goods origin and ownership verified?
   • Is any intermediary's role explained?
5. The documented policy (Article 5(4)). Name who implements, who reviews and who supervises, with their powers, and keep the policy with your required records. Our vendor onboarding policy framework and the policy template give you a free starting structure.

You leave with: written rules, an evidence standard, AP approval questions and an approved policy. ◇ Human decision: the policy owner signs off on it.

Days 61-90: run, test and set the re-check clock

1. Run the full process for all new suppliers and every supply above the exception.
2. Sample approved records. Can a reviewer who was not involved see the source, date, outcome and approver for each check?
3. Measure: first-pass completeness, how long checks take, the share of supplies booked under the exception, and how many risk-indicator explanations were written.
4. Fix the gaps found in the Days 1-30 sample, starting with suppliers above AED 375,000.
5. Set the re-verification clock. Store a "last verified" date on every supplier. Before booking input tax, check that it falls within the last 12 months. The 12 months run separately for each supplier; there is no single company-wide date.

You leave with: a working process, test results and a re-verification schedule. ◇ Human decision: the supervisor named in the policy accepts the test results.

Common mistakes

1. Treating the AED 10,000 exception as a per-supplier pass. It applies per supply and falls away once supplies from that supplier exceed AED 100,000 over the previous or next 12 months.
2. Checking only at onboarding. The Article 4 checks apply to every supply, not once a year.
3. Confusing an IBAN check with the bank confirmation. Above AED 375,000, the Decision asks for a written confirmation from an authorised UAE bank that the supplier has an account, without relevant reservations or conditions. It need not be addressed to you.
4. Looking only backwards. Both value tests include spend "expected to exceed" the threshold over the next 12 months.
5. No written policy. Article 5(4) requires one that names who implements, reviews and supervises.
6. Treating an e-invoice as proof. UAE e-invoicing is a separate Ministry of Finance programme. Decision 13 does not say that a valid eInvoice satisfies its checks (MoF eInvoicing).

Who owns what (suggested)

The Decision does not assign roles. These are our suggestions; adapt them to your delegation of authority.

Checklist

Use the free one-page FTA Decision 13 supplier and supply verification checklist (A4 PDF) for each supplier. For how to complete it as preparer and then approver, see how to complete the FTA Decision 13 checklist.

Where Vendoreye fits

Vendoreye's vendor verification workflow brings identity, UAE licence, VAT and bank-account checks into one governed workflow with continuous monitoring. Each result keeps its source, date and reviewer. Automated checks produce signals; a named person decides. Vendoreye does not give tax advice or decide whether input tax is recoverable.

FAQs

Does a 90-day plan delay our obligations?

No. The Decision has applied since 1 October 2026 (Article 7). The plan is how you build a sustainable process. Run interim checks while you do.

Which suppliers should we fix first?

We suggest starting with suppliers above AED 375,000 over the previous or next 12 months, because they need the most evidence. Then move to recurrent suppliers whose last verification is more than 12 months old.

Do we re-check every supplier on the same date each year?

No. Article 5(1) ties re-verification to recurrent dealings with a supplier that has not been verified for 12 months, so the clock runs separately for each supplier.

References and further reading (checked 15 Oct 2026)

1. FTA Decision No. 13 of 2026 (FTA page)
2. FTA Decision No. 13 of 2026, English PDF (unofficial translation)
3. Federal Decree-Law No. 8 of 2017 on VAT, consolidated (Article 54(bis))
4. MoF eInvoicing programme

Related resources

• FTA Decision 13 supplier verification guide
• FTA Decision 13 checklist (free A4 template)
• How to complete the FTA Decision 13 checklist
• Vendor due diligence and risk-tiering framework
• UAE VAT supplier checks before input tax
• Resource library

Change log

• 5 October 2026: first published as "FTA Decision No. 13 of 2026: Supplier Verification Guide".
• 19 October 2026: rewritten as a 90-day implementation plan. Added article references and the AED 10,000, AED 100,000 and AED 375,000 thresholds. The rules overview moved to the supplier verification guide.