UAE’s New Era of Tax Transparency: A Deep Dive into Cabinet Decision No. 209 of 2025
Cabinet Decision 209: The Moment Tax Transparency Became Operational in the UAE
There was no big announcement. No slogans. Just an official notice.
On 10 February 2026, the Ministry of Finance announced the issuance of Cabinet Decision No. 209 of 2025 on the Exchange of Information upon Request for Tax Purposes.
The Decision was adopted by the Cabinet on 22 December 2025 and came into force on 30 January 2026.
For the first time, the UAE now has a single, comprehensive legislative framework governing the Exchange of Information on Request. Not scattered guidance. Not references buried in treaties. A domestic rulebook that sets out how tax information is requested, reviewed, and exchanged.
Until now, information exchange obligations existed largely through international instruments, supported by administrative practice. What was missing was a clear, unified framework anchored in domestic law.
This is not a sharp change; it is an evolution.
The UAE has been part of the OECD Global Forum since 2010 and has built a network of more than 140 Double Taxation Agreements. Information exchange has long been part of that architecture. What was missing was a single framework at home.
Cabinet Decision 209 fills that gap.
The signal is quiet but clear: transparency is no longer something the UAE relies on through treaties or international memberships alone. It is now embedded in domestic law and designed to be enforceable.
The Core Framework: One Rulebook, Finally
Until now, information exchange in the UAE worked—but it wasn’t tidy.
Previously, EOIR obligations were spread across treaties, internal procedures, and regulatory practice rather than one consolidated rulebook. The outcome was broadly consistent, but the path to get there often wasn’t.
Cabinet Decision No. 209 changes that.
It moves the system toward one standard, applied across the board. Mainland entities and free zone entities are no longer operating in parallel lanes. The expectations are aligned. The language is aligned. The process is aligned.
That matters more than it sounds.
The Decision also draws clearer lines between government bodies. Who collects what? Who verifies it? And how that information ultimately reaches the Ministry of Finance.
Before, coordination existed, but it relied heavily on practice. Now it is written down.
This reduces friction. It also reduces ambiguity. And ambiguity is usually where problems start.
There is a broader angle here as well.
As the UAE enters the 2026 fiscal reset, corporate tax maturing, data systems tightening, and electronic reporting becoming standard, international scrutiny naturally increases. Investors, treaty partners, and tax authorities look less at promises and more at systems.
A unified EOIR framework sends a simple signal.
The system is controlled. The data flow is understood. And requests are handled consistently, not selectively.
That consistency is part of what underpins confidence in the so-called Falcon Economy. Not speed alone. Not ambition. But order.
And in tax, order travels far.
Mandatory Record-Keeping: The Three Pillars That Matter
There is no headline change here.
But the expectations are clearer now.
Cabinet Decision No. 209 makes one thing explicit. If information is requested, it must already exist, and it must be usable.
At the centre of the framework are three categories of records. Not optional. Not theoretical.
First: ownership and identity.
Businesses are expected to maintain accurate records of legal persons and legal arrangements. That includes beneficial ownership. Not just names on paper, but information that can be verified and traced. Gaps here tend to attract attention quickly. And they are hard to explain away after the fact.
Second: banking and financial data.
The Decision reinforces the requirement for banking information to be retrievable. Account details, transaction history, linkages between accounts and entities. This is not about volume; it is about clarity. If funds moved, the trail should be readable.
Third: accounting records.
This is where many businesses underestimate the shift. Cabinet Decision 209 gives a clear legislative footing to accounting record-keeping as part of tax transparency. Not “good practice”. A legal expectation.
Records must support the numbers, and the numbers must stand up to international standards.
Taken together, these three pillars form the practical test.
Not whether a business intends to comply. But whether it is ready when a request arrives.
That distinction is new. And it changes behaviour.
Enforcement and the Cost of Getting It Wrong
The Decision avoids dramatic language. It doesn’t need to spell things out loudly. The mechanics are enough.
Cabinet Decision No. 209 gives authorities the power to apply what it calls “proportionate administrative measures.” In practice, that means responses are meant to match the failure. Missing information, late information, incomplete or misleading information. Each is treated differently, and nothing is ignored.
This is not a criminal framework. But it is not symbolic either.
From 2026 onward, failure to provide requested information or providing information that is false or manipulated can trigger financial penalties. The standard range sits between AED 20,000 and AED 100,000 for transparency-related violations. That bracket is already familiar to businesses that have dealt with compliance breaches elsewhere in the tax system.
What changes here is frequency.
The Decision introduces a clear doubling rule. If the same violation is repeated within twelve months, the penalty is doubled. Not reviewed or renegotiated. Doubled.
That matters because repeated failures are no longer treated as administrative noise. They signal behaviour. And behaviour attracts escalation.
The message is straightforward.
Occasional errors may be managed. Patterns will not be.
Fairness in Focus: When the System Gets It Wrong
Transparency cuts both ways, and the decision acknowledges that.
Buried between technical obligations and enforcement powers is something easy to overlook: a formal right to challenge the system itself.
Cabinet Decision No. 209 does not assume perfection. It builds in friction. On purpose.
The framework explicitly provides grievance and review procedures. If a business believes an information request, administrative action, or penalty is incorrect, it is not expected to absorb it quietly. There is a process. A defined one.
That matters.
Under the Decision, taxpayers are given a route to contest actions through structured review mechanisms administered by the Ministry of Finance. This is not an informal appeal. It is an administrative process with timelines, documentation, and oversight.
In other words, enforcement is no longer one-directional.
This balances the broader framework. As transparency obligations tighten, procedural fairness is pulled into the same legislative space. Businesses are required to cooperate, and the authorities are required to justify.
That symmetry is deliberate.
For companies operating at scale, especially those with cross-border exposure, the presence of a clear review channel changes the tone of compliance. It turns it from submission into a process.
And in a system built on information, process is protection.
Where ADEPTS Fits In
This is the point where theory meets execution.
ADEPTS is a firm of audit, tax, and advisory professionals. Nothing abstract about that. We work with systems, records, filings, and decisions that have real consequences when they fail.
We are an FTA-approved tax agency with more than fifteen years of operating history. Over that time, the work has changed, the expectations have tightened, and data has become central.
Our response has been practical rather than cosmetic; investing in digital capability while staying close to how regulators actually think and operate.
Cabinet Decision No. 209 is a good example of where that balance matters.
On paper, it is about information exchange. In practice, it tests whether a business has its records, controls, and governance aligned well enough to respond under pressure
That is rarely solved by last-minute fixes.
Our role is straightforward.
We help organisations understand what a decision like this really requires, assess where exposure sits, and put structure around compliance before scrutiny arrives.
No dramatics. No over-engineering. Just clarity.
For those planning for 2026, more detail is available at taxadepts.com.
Looking Ahead: Reading the Direction of Travel
Cabinet Decision No. 209 is not an isolated reform. It doesn’t sit on its own.
It signals something bigger. The UAE is no longer positioning itself only as an efficient place to do business. It is making a case for credibility, systems, predictability and transparency that holds up under scrutiny.
That shift matters in 2026.
With major institutions such as the World Bank forecasting around 5% real GDP growth for the UAE in 2026, the focus is no longer just growth. It is durability, capital that stays, structures that last and relationships with treaty partners that remain stable over time. None of that works if information exchange is treated as an afterthought.
The direction is clear.
International standards are not optional add-ons. They are now part of the operating environment.
For businesses, the implication is practical rather than philosophical. Waiting for a request is the wrong trigger. By the time information is asked for, the test has already begun.
The safer approach is quieter. Review ownership records, check banking trails, stress-test accounting files and make sure they are complete, coherent, and retrievable — not eventually, but now.
In the 2026 regulatory landscape, compliance is no longer about reacting well. It is about being ready before anyone asks.
References
- Abdou, Mahmoud. ‘Ministry of Finance Announces Issuance of Cabinet Decision on Exchange of Information upon Request for Tax Purposes’. Ministry of Finance – United Arab Emirates, 10 Feb. 2026,
https://mof.gov.ae/en/news/ministry-of-finance-announces-issuance-of-cabinet-decision-on-exchange-of-information-upon-request-for-tax-purposes/.
- ‘Double Taxation Agreements (DTAs)’. Ministry of Finance – United Arab Emirates,
https://mof.gov.ae/en/public-finance/international-relations/double-taxation-agreements/.
- Global Forum on Transparency and Exchange of Information for Tax Purposes.
https://www.oecd.org/en/networks/global-forum-tax-transparency.html.
- The Falcon Economy. 24 May 2024,
https://www.adgm.com/initiatives/falcon-economy.
- World Bank: UAE Economy to Grow 5% in 2026; 5.1% in 2027.
https://www.wam.ae/en/article/by7hcd7-world-bank-uae-economy-grow-2026-51-2027.
