UAE VAT Compliance
Starts with Knowing
Your Suppliers


 Don't just check the box. Know the Counterparty.

What to Know

 

From 1 October 2026, new UAE VAT verification requirements will increase the importance of understanding who you are doing business with - and being able to evidence the checks performed.

Under FTA Decision No. 13 of 2026, taxable persons seeking to deduct Input Tax must undertake prescribed verification procedures relating to the validity and integrity of supplies, document the verification steps performed and retain supporting records.

The Decision implements Article 54(bis) of the UAE VAT Law, under which Input Tax recovery may be denied where a supply forms part of a supply or supply chain connected with tax evasion and the taxable person knew — or should reasonably have known — of that connection.

The practical implication is significant: supplier and supply verification are becoming increasingly important VAT controls. 

A New VAT Requirement. A New supplier-risk Challenge 

 

For organisations with large, complex or rapidly changing supplier  populations, the challenge is not simply performing prescribed checks.

It is performing them consistently, identifying where further scrutiny may be warranted, responding proportionately to potential risk and maintaining evidence of the process.

Supplier circumstances can also change. Ownership, management, business activities and payment arrangements may evolve. New information may emerge. Transactions or supply-chain relationships may raise questions that were not apparent when a supplier was first onboarded.

While not every supplier requires the same level of scrutiny, organisations need a practical way to determine where additional diligence may be appropriate and how concerns should be escalated and resolved.

That turns supplier due diligence into an important component of the VAT control environment.

Is your Supplier Due Diligence Ready?

Effective 1 October 2026; Organisations should be considering:

1. Do we know who we are really doing business with?

2. Can we identify potential warning signs that warrant further review?

3.  Can we respond proportionately when supplier or transaction risk increases?

4. Can we demonstrate the verification and diligence behind our decisions?

A Practical Response:

Verify at Scale.

Investigate by Risk.

Evidence the Process. 

 

Mintz Group can help organisations operationalise supplier verification and integrity controls at scale.

By combining Mintz Group’s proprietary Verity AI platform and global investigative capabilities, organisations can establish a scalable, technology-enabled and risk-based supplier integrity programme that supports their wider VAT control environment. Together, Verity AI and Mintz Group investigators give organisations a practical way to move from basic supplier checks to a defensible supplier integrity programme: screen broadly, investigate selectively and preserve the evidence behind every decision.

Our approach follows the lifecycle of supplier risk:

The Result

Screen broadly   |   Investigate Selectively    |    Monitor proportionately   |   Evidence consistently

 For Tax, Finance, Procurement, Compliance and Third-Party Risk teams, the objective is the same: create a supplier verification process that is scalable, proportionate and defensible.

Don't just check the box. Know the Counterparty.

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Key Contacts

kelsey-froehlich-683x1024

Kelsey Froehlich

Partner, Global Co-Head, Corporate Risk & Due Diligence
Mohammad-Mono-2

Mohammad Malkawi

Managing Director, Head of MENA
Doug Chisholm

Doug Chisholm

Partner, Global Co-Head of Corporate Risk & Due Diligence
Yehia-mono

Yehia Mokhtar

Global Head of Product Strategy & Transformation

About Us

 

Mintz Group is an integrated risk advisory and disputes consultancy with a unified mission to keep its clients on the right side of history. For more than 30 years, Mintz Group has gathered and analyzed information for corporations, law firms, investment firms, charitable foundations, sovereign entities, and other organizations, to help them assess risks, protect reputations, and win disputes. Our approach to fact gathering is transparent, ethical, and practical, yielding information that will stand up to the toughest scrutiny in the boardroom or the courtroom.