How to Contest an FTA Penalty: Reconsideration Requests, Deadlines and Appeals

A reconsideration request asks the Federal Tax Authority (FTA) to review its own decision about you, a penalty included, and Article 29 of the Tax Procedures Law gives you 40 business days from being notified to file it with your reasons, then gives the FTA 40 business days to decide and 5 business days to tell you. As of October 2026, the FTA's reconsideration service page tells applicants to allow up to 45 business days for an answer and says the FTA may extend that period.

Start by finding the date you were notified, because the deadline to file counts from it. If the FTA turns the request down, the dispute moves to the Tax Disputes Resolution Committee and, for larger amounts, the courts. A penalty waiver or an instalment plan is a separate route you can take instead of disputing, and an instalment request can run alongside a reconsideration request.

How to File an FTA Reconsideration Request Step by Step

Work through these steps in order. Steps 1 to 5 are the reconsideration request itself; steps 6 and 7 apply only if the FTA rejects it or leaves it undecided.

1. Note the date you were notified. Who: you. Where: the FTA's decision notice. Fee: none. Time: Article 29 of the Tax Procedures Law gives you 40 business days from that date to file, so count them out before anything else.

2. Check whether you need to file at all. Who: you or your tax agent. Fee: none. Time: early, inside the same 40 business days. If the decision is the corporate tax late registration penalty and your first tax return was filed within seven months of the end of your first tax period, the FTA waives it automatically with no request; if it is a tax assessment with related penalties, a tax assessment review may fit better, because the two routes cannot run on the same assessment at once.

3. Gather your evidence. Who: you or your tax agent. Fee: no FTA fee. Time: before you file. The FTA asks for documentary proof of the factual and legal grounds of your request and any relevant tax advice you received, in Word, Excel, PDF, JPG, PNG or JPEG files of up to 5 MB each, and it may accept English documents and ask for an approved Arabic translation.

4. File the request on EmaraTax. Who: you, your appointed tax agent or your appointed legal representative, and a tax group files through its representative member. Where: EmaraTax, under the Taxable Person profile, Other Services, Reconsiderations, New Request. Fee: free, as of October 2026, according to the FTA's reconsideration service page. Time: the service is open at all hours, but a saved draft is cancelled automatically once the legal deadline passes, so submit it rather than leaving it saved.

5. Wait for the FTA's decision. Who: the FTA. Fee: none. Time: the law gives the FTA 40 business days from receiving the request to decide, with reasons, and 5 business days to tell you; the FTA's service page says to allow up to 45 business days, and Article 25 of the Executive Regulation, as published, lets the FTA extend by 20 business days where it needs to.

6. Object to the Tax Disputes Resolution Committee if the FTA says no. Who: you or your tax agent. Fee: not set out in the sources this guide relies on, so confirm any fee and how to submit before you file. Time: within 40 business days of being notified of the FTA's decision, with the tax connected to the objection paid in full; the Committee then has 20 business days to decide and 5 business days to tell both sides.

7. Appeal to the competent court only where the tax and penalties in dispute total more than AED 100,000. Who: you or the FTA. Fee: court fees are outside the sources used here, so confirm them first. Time: within 40 business days of being notified of the Committee's decision, with proof that the full tax and at least 50% of the administrative penalties are settled, in cash or by an approved bank guarantee.

Why Older Guides Quote Different Deadlines

The rules above come from the consolidated Tax Procedures Law, Federal Decree-Law No. 28 of 2022 as amended most recently by Federal Decree-Law No. 17 of 2025, in force from 1 January 2026. The Ministry of Finance's summary of that amendment centres on refunds of credit balances and limitation periods, and the consolidated text still sets reconsideration in Article 29. If a guide quotes a different article number or filing window, follow the consolidated text on the FTA's website.

Which Route Fits Your FTA Penalty

Four routes can change what you owe after an FTA decision, and they differ in what they cover, when they close and what you must pay before you use them. The table sets them side by side, as of October 2026, from the Tax Procedures Law and Cabinet Decision No. 105 of 2021.

As of October 2026, from Federal Decree-Law No. 28 of 2022 as amended, its Executive Regulation and Cabinet Decision No. 105 of 2021.

Which FTA Decisions You Can Ask to Reconsider

Any official decision the FTA has issued about you can be reconsidered, in whole or in part, and an administrative penalty is one of them. General enquiries, complaints and requests for clarification are not decisions, so the FTA's service page says they cannot be reconsidered.

Penalties, Assessments and Other Decisions

Penalties are the decisions this page is mostly about. Their amounts sit in our guides to corporate tax penalties and VAT penalties; this page covers what to do once one has been imposed. Because Article 29 covers part of a decision as well as the whole, you can limit your request to the part you disagree with.

Reconsideration Request or Tax Assessment Review

If the FTA has issued a tax assessment with penalties attached, you can ask for a tax assessment review under Article 28 before you ask for reconsideration; for any other decision, reconsideration is the route. A review request is filed within 40 business days of notification of the assessment and its penalties, and the FTA decides within 40 business days and notifies you within 5. You can then ask for reconsideration of the review decision within 40 business days of being notified of it, or of the FTA's time to decide running out.

Why You Cannot Run Both on One Assessment

The two routes cannot overlap. Article 28(5) bars filing or continuing a review once a reconsideration request covers the same assessment, and Article 29(3) bars a reconsideration request while a review of that assessment is pending, until the FTA decides or its time to decide runs out. Starting with a review keeps reconsideration open as a second step at the FTA; starting with reconsideration closes the review route for that assessment. Either way, the first request is due within 40 business days of the notice, so choose early.

If You Missed the Reconsideration Deadline

You can ask the FTA to extend the deadline, but only for a case listed in FTA Decision No. 1 of 2025, and only with documentary evidence of it. Article 35(2) of the Tax Procedures Law lets the FTA grant an extension at your request for reasons set in the Executive Regulation, and FTA Decision No. 1 of 2025, issued 17 February 2025 and in effect from 1 March 2025, lists the cases it accepts for tax assessment review and reconsideration requests.

Cases the FTA Accepts

Article 1 of the Decision lets the FTA approve an extension where the deadline was missed because of one of these cases.

1. An accident or a serious illness of the authorised signatory.

2. The death of the authorised signatory, including the legal representative, or of a first or second degree family member.

3. A temporary business disruption beyond your control.

4. Damage to records in a disaster.

5. A general malfunction in the FTA's systems.

6. A sudden stop of the business or its records because a new computer system is being installed.

7. The FTA asking for more documents that you can prove you could not obtain within the deadline.

8. Force majeure, at the FTA's discretion.

Cases the FTA Refuses

Article 2 tells the FTA to reject an extension in these four cases.

1. You were unaware of your obligations.

2. The delay was caused by the negligence of someone you relied on, such as your tax agent or legal representative.

3. The subject of the request was too complex to file on time.

4. You were busy running the business.

So "my tax agent missed it" and "we were too busy" both fail. If neither the deadline nor an extension is open to you, look at whether a waiver or an instalment plan, covered below, fits your situation. For a late objection to the Committee, the same Article 35(2) lets the Committee grant an extension for the reasons set in the Executive Regulation.

What to Put in a Reconsideration Request

A request the FTA can act on names the decision, says which part of it you dispute, and ties each reason to the facts and to the provision of law it relies on, with a document that proves it. Article 29 requires the request to specify its reasons, so write each one out in full rather than relying on the decision notice to speak for you.

Grounds and Evidence

The FTA's service page asks for documentary proof of the factual and legal grounds your request rests on, plus any tax advice you received that is relevant to it. Build the request one point at a time. If you say a return or payment was made on time, attach the submission or payment confirmation. If you say the FTA's system failed, attach screenshots showing the error and the date. If the penalty rests on a figure you say is wrong, attach the ledger, invoice or contract that shows the correct one. A general statement that a penalty is unfair gives the FTA nothing to review; a dated document that contradicts the decision does.

File Types, Size and Language

Upload Word, Excel, PDF, JPG, PNG or JPEG files of up to 5 MB each. The Tax Procedures Law asks for documents in Arabic, but Article 5 of the Executive Regulation lets the FTA accept them in English and, at its discretion, ask for an approved Arabic translation of some or all of them.

Who Can File

You can file yourself, and the FTA also accepts a request from your appointed tax agent or your appointed legal representative. A member of a tax group files through the group's representative member. A tax adviser who is not registered as a tax agent cannot file a reconsideration request on your behalf. You do not need to be registered for tax, or to have a tax agent, to file one.

If the FTA Rejects Your Reconsideration Request

If the FTA rejects your request, or does not decide it in time, the next step is an objection to the Tax Disputes Resolution Committee, and only after that can the dispute reach a court.

Objecting to the Tax Disputes Resolution Committee

File the objection within 40 business days of being notified of the FTA's decision. Article 32 of the Tax Procedures Law says the Committee will not accept an objection if no reconsideration request was filed first, if the tax connected with the objection has not been paid in full, or if it is late. The Committee is chaired by a member of the judicial authority and has two expert members; it decides within 20 business days of receiving the objection and notifies both sides within 5, and Article 25 of the Executive Regulation, as published, lets it extend that by 60 business days where needed.

The law's wording names the tax connected with the objection, not the penalties. Whether a penalty must also be settled before the Committee accepts an objection is not settled in the sources this guide relies on, so confirm it with the Committee before you file. If the FTA has not decided your request at all, Article 31 lets the Committee hear it, but the law counts the objection deadline from notification of a decision, so confirm with the Committee when your window starts.

Appealing to the Courts

Under Article 33, as of October 2026, the Committee's decision is final where the tax and administrative penalties in dispute total AED 100,000 or less. Above that amount, you or the FTA can appeal to the competent court within 40 business days of being notified of the decision, and a decision nobody appeals in that time becomes enforceable. No tax dispute reaches the court without an objection to the Committee first. The court will not hear your appeal unless you show that the full tax is settled and that at least 50% of the administrative penalties set by the Committee's decision are paid in cash to the FTA or covered by an approved bank guarantee in its favour.

Asking for a Penalty Waiver or Instalments

Separately from disputing a penalty, you can ask for it to be waived or paid in instalments under Cabinet Decision No. 105 of 2021, and a pending reconsideration request does not stop you asking for instalments.

When a Penalty Can Be Waived

A waiver needs three things: the violation is not connected to a tax evasion crime, the request is made within the period the committee specifies, and your situation falls within one of the cases Article 4 of the Decision lists.

1. The death or illness of the registered natural person or sole owner.

2. The death, illness or resignation of a key employee.

3. Government restrictions or precautionary procedures.

4. A general malfunction in the FTA's systems, payment gateways or the telecommunication services used.

5. A custodial sentence.

6. Tax obligations carried out through another registered person's account.

7. Insolvency or bankruptcy.

8. Any other case the committee assesses.

The request must include your undertaking that you have corrected the violation and will not repeat it, and only one request can be under review for the same penalties at a time. Before asking for a waiver and a reconsideration on the same penalty, confirm with the FTA how the two will be handled.

Paying in Instalments

An instalment plan covers unsettled penalties only, of at least AED 50,000 as of October 2026 under Article 3 of the Decision, and you must owe no payable tax for the tax period concerned. The penalties cannot be under dispute before the Tax Disputes Resolution Committee or the courts, but the Decision makes an exception for the reconsideration mechanism, so you can ask the FTA to reconsider a penalty and request instalments on it at the same time. An objection to the Committee, by contrast, takes those penalties outside the instalment route.

How Long a Waiver or Instalment Request Takes

Both requests are made on EmaraTax, under Penalty waiver or Penalty Installment Plan. The FTA passes a request to the committee within 40 business days of receiving it, and the committee decides within 60 business days; no answer in that time counts as a rejection, and the committee's decision is final. The FTA's service page for these requests tells applicants to allow up to 110 business days in total.

The Late Corporate Tax Registration Penalty

The penalty for registering late for corporate tax is AED 10,000, as of October 2026, according to the Ministry of Finance. It is also the one penalty you may not need to contest at all.

The Automatic Waiver

Under the FTA's corporate tax late registration penalty waiver initiative, the penalty is waived automatically, with no reconsideration or waiver request, when you file the tax return or annual declaration for your first tax period within seven months of the end of that period, instead of the nine months otherwise allowed. The initiative covers the first tax period only. If you have already paid the penalty, the FTA adds a credit equal to it to your EmaraTax account automatically, and you can use that credit to settle other tax liabilities or claim it back with a refund application. If the first return went in later than seven months after the period ended, the penalty stands, and the reconsideration and waiver routes above are the ones to weigh.

Staying Ahead of the Next Deadline

Many penalties start with a missed date. Our UAE business compliance checklist sets out the recurring deadlines that trigger them, and our guide to filing your first corporate tax return walks through the return the automatic waiver depends on.

An FTA decision gives you 40 business days, and most of the work is reading the decision against your records and building the grounds before that time runs out. Zola's accounting, tax and compliance team can review an FTA decision against your records and prepare the reconsideration request with you on time. Create your Zola account to get started with accounting, tax and compliance support.