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Small invoices, bigger obligations: the AED 100,000 line most teams miss

From 1 October 2026, supplier verification in the UAE stops being a big-deal concern. Once your dealings with a single supplier cross AED 100,000 over twelve months, the small-supply exception no longer applies, and most finance teams are not tracking cumulative spend per counterparty at all.

· 2 MIN READ · BY THE KYCK DESK

How the threshold is crossed without anyone noticing

A supply below AED 10,000 excluding VAT can be left unverified, but only while your total spend with that supplier over twelve months stays below AED 100,000. Twelve months of small invoices from the same supplier can cross that line on their own, and from that point every supply from that supplier needs the full check, whatever the invoice size.

The obligation is therefore already in place before anyone in the business notices it, because nobody is watching the running total per counterparty.

What verification covers

  • Business verification of the supplier against official registries, and the identity of the person authorised to represent it.
  • Ownership and control, meaning who really stands behind the entity.
  • Sanctions, PEP and adverse media screening.
  • A written policy naming who performs, reviews and supervises the checks.
  • Evidence kept with the date of each check, because the twelve month clock runs from it.

Being ready is a data problem first

The practical first step has nothing to do with software: pull twelve months of purchase data and sort suppliers by cumulative spend. That tells you which suppliers need the full check now and which need it plus a bank confirmation letter, above AED 375,000.

The full rule, with the three thresholds and what is at stake, is in our explainer on FTA Decision No. 13. KYCK collects the supplier documents through a link, screens the company and the people behind it, dates every check and keeps the file ready to export.

KYCK Limited is an independent software provider and is not affiliated with, endorsed by or acting for the Federal Tax Authority. This article is general information, not tax or legal advice.

Sources

Related reading

The full rule explainedCounterparty onboardingBest AML software in the UAE

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