27 July 2026 · AED 100m Rule
The AED 100m Emirate-Reporting Rule
Standard VAT registrants report all their supplies at the Emirate of their business establishment, regardless of where individual customers are located. But once a business's e-commerce supplies exceed AED 100 million within a calendar year, it becomes a "qualifying registrant" under the amended VAT Executive Regulation, introduced by Cabinet Decision No. 99 of 2022 and clarified in FTA Public Clarification VATP033, and must instead report those supplies by the Emirate in which each supply is received. This special reporting has applied to tax periods on or after 1 July 2023 for businesses that cross the threshold, and it exists because large-scale online selling spreads consumption across the UAE in a way a single-Emirate report does not capture. Crossing AED 100 million is as much a systems and data question as a tax one — Emirate-level reporting needs delivery-address data most e-commerce platforms were not originally built to track for tax purposes.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Over AED 100m
The AED 100 million threshold is tested against e-commerce supplies specifically, within a calendar year, and once crossed it changes how — not whether — VAT is reported. A qualifying registrant does not pay more VAT because of this rule; it reports the same VAT differently, splitting supplies by the Emirate in which the customer actually received them rather than lumping everything under the seller's home Emirate.
- Tested against e-commerce supplies over a calendar year, not a rolling period.
- Crossing AED 100m makes the business a "qualifying registrant."
- Special reporting is by the Emirate where the supply is received, not the seller's Emirate.
- Introduced by Cabinet Decision No. 99 of 2022 amending the VAT Executive Regulation.
- Clarified in FTA Public Clarification VATP033.
- Applies to tax periods on or after 1 July 2023 for those crossing the threshold.
Everyone else
The overwhelming majority of online sellers never reach AED 100 million in e-commerce supplies and continue reporting exactly as before — everything attributed to the Emirate of their business establishment. There is no partial or phased version of Emirate-level reporting below the threshold; a business is either a qualifying registrant with the full reporting obligation, or it is not and reports normally.
- Report all supplies at the establishment's Emirate below the AED 100m threshold.
- No Emirate-by-Emirate split required until the threshold is actually crossed.
- Monitor e-commerce turnover annually if you are scaling toward the figure.
- There is no phased or partial version of the obligation below AED 100m.
- Once triggered, the obligation applies to the qualifying registrant going forward, not retroactively to prior years.
What changes operationally at AED 100m
Emirate-level reporting is less a tax-rate question than a data question, which is why it catches fast-growing online sellers off guard. The business needs to capture, at the point of sale, which Emirate the customer actually received the supply in — the delivery address, not the billing address or the seller's own location — and then reconcile that data against the VAT return figures every period. Platforms and fulfilment systems built only to track a single national VAT total often need real changes to produce this split reliably.
- Capture the delivery Emirate at point of sale, not just the billing address.
- Reconcile Emirate-level sales data against the VAT return every period.
- Review fulfilment and order-management systems well before the threshold is reached, not after.
- Build the reporting capability in advance if your growth trajectory points toward AED 100m.
- Treat this as a systems project, not just a filing adjustment.
Setting up Emirate reporting
Exiloz works with large online operators to determine whether the AED 100 million threshold has been or will soon be crossed, and to build the Emirate-level reporting process that VATP033 expects — from data capture at checkout through to the figures that land on the VAT return.
- We assess whether and when your e-commerce supplies cross AED 100m.
- We map delivery-address data to the correct Emirate for reporting purposes.
- We reconcile Emirate-level figures against your VAT return each period.
- We prepare the systems and data changes before the threshold forces a rushed fix.
Related guides
Frequently Asked Questions
Answers for large online operators approaching or already past the AED 100 million e-commerce threshold.
What is the AED 100 million rule?
Once a business's e-commerce supplies exceed AED 100 million in a calendar year, it becomes a qualifying registrant and must report those supplies by the Emirate where each supply is received, rather than at its own establishment's Emirate, under the amended VAT Executive Regulation and VATP033.
Does it affect small e-tailers?
No. Businesses below AED 100 million continue reporting all supplies at their establishment's Emirate, exactly as before. There is no partial or reduced version of the obligation below the threshold.
When did the rule start applying?
For qualifying registrants, from tax periods on or after 1 July 2023 — the reporting change applies to businesses once they cross the threshold, not retroactively before it.
Does the AED 100m rule change how much VAT I pay?
No. It changes how the same VAT is reported — split by the Emirate where the supply is received — not the total VAT liability. It is a reporting-granularity rule, not a rate or scope change.
What data do we need to capture?
The Emirate in which each supply is actually received by the customer — generally the delivery address — rather than the billing address or your own business location. Most platforms need this captured at the point of sale.
Is this the same as the AED 375,000 registration threshold?
No. AED 375,000 is the registration threshold every business tests, online or offline. AED 100 million is a separate, much higher threshold that only changes how an already-registered e-commerce business reports its supplies.
Can Exiloz set up Emirate reporting for us?
Yes. We assess your position against the AED 100m threshold, map delivery data to the correct Emirate, and build the reporting process into your VAT return cycle.
What happens if we cross AED 100m mid-year and are not ready to report by Emirate?
The obligation applies from the tax period after the threshold is crossed regardless of whether the systems are ready, so the safest approach is to start building the delivery-address data capture well before you expect to reach AED 100m rather than reacting after the fact. A late or incomplete Emirate split is still a reporting error the FTA can query.
Scaling past AED 100 million?
Exiloz sets up Emirate-by-Emirate VAT reporting and the data capture behind it for large e-commerce operators.