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UAE VAT credits from 2018 to 2021 are lost unless a refund request reaches the FTA by 31 December 2026. Which periods expire, and how to claim.
UAE VAT credits (excess recoverable tax) from tax periods that ended between 2018 and 31 December 2021 are lost unless you submit a refund request to the FTA by 31 December 2026. Since 1 January 2026, every VAT credit must be used or reclaimed within five years of the end of the tax period it came from, and a one-year transitional window lets businesses claim older balances. You file the request on EmaraTax using form VAT311.
If your EmaraTax account has shown a credit balance for years, this is the year to deal with it. A VAT refund in the UAE is not complicated, but old periods bring old records, staff turnover and reconciliation gaps. Starting in December is how money gets left on the table. Here is what expires, how to claim and what slows the FTA down.
Which VAT credits expire on 31 December 2026
A VAT credit is excess recoverable tax: input VAT that was more than output VAT in a return, left sitting in your FTA account. UAE VAT started on 1 January 2018, so the oldest credits are now eight years old.
Tax periods that ended | When the five years end | Last day to act |
|---|---|---|
2018, 2019 or 2020 | Already ended before 1 January 2026 | Refund request by 31 December 2026 (transitional window) |
1 January to 31 December 2021 | During 2026 | Refund request by 31 December 2026 |
2022 | Five years from the end of each period | e.g. quarter ending 31 March 2022 lapses on 31 March 2027 |
2023 onwards | Rolling five years from the end of each period | Five years after each period ends |
This is our reading of the Ministry of Finance wording, so check each period's balance in EmaraTax rather than relying on a single total.
Credits usually build up in businesses whose input VAT regularly exceeds output VAT:
Exporters, whose sales are mostly zero-rated
Businesses with mainly zero-rated supplies, such as some international transport or education providers
Companies in a start-up or heavy spending phase, fitting out offices or buying equipment before revenue arrives
This is not the tourist refund scheme. It concerns VAT-registered businesses only.
The five-year rule, and the one-year window to claim older credits
The rule sits in Article 74(3) of the VAT Decree-Law (Federal Decree-Law 8 of 2017), as amended by Federal Decree-Law 16 of 2025, in force from 1 January 2026 and explained in FTA public clarification VATP046. Excess recoverable tax is limited to five years from the end of the tax period in which it arose. Within that time it can settle payable tax or administrative penalties, or be refunded. Any unused remainder lapses at the end of the five years, even if part of the credit was used.
The FTA's own example: a credit from a tax period ending 31 January 2026 must be used or reclaimed by 31 January 2031.
The Tax Procedures Law side matters too. Federal Decree-Law 17 of 2025, also in force from 1 January 2026, set the same five-year limit for credit balances held with the FTA generally, so check credits under other taxes as well. The Ministry of Finance announcement of 29 November 2025 added the transitional window: where the five years expired before 1 January 2026, or will expire within one year of that date, you can submit a refund request within one year from 1 January 2026, so by 31 December 2026.
Two further points, in specific cases:
Extra time to request a refund where the credit arises after the five years have passed or within the last 90 days of them
Audit after the limitation period, for example where a refund request is filed in the final year
That second point means a late-window claim is not a free pass. Expect scrutiny.
How to claim a VAT refund on EmaraTax, step by step
Knowing how to claim a VAT refund in the UAE for a business mostly comes down to preparation. The filing itself takes minutes.
Map your credits. List every tax period with a credit and the balance now in your EmaraTax account. Reconcile it to your VAT returns and ledgers.
Gather evidence. Pull the output and input tax report, plus the tax invoices and supporting documents for the claim.
File form VAT311. Log in to EmaraTax, open the VAT tab and complete the refund request. Our EmaraTax guide covers the screens.
Submit. There is no FTA fee.
Answer queries fast. The FTA aims to decide within 25 business days of a complete application, up to 55 working days if it goes to audit review, and may take a further 25 business days after you supply extra information.
Our advice, not a legal deadline: file by the end of November 2026. A query landing in mid-December with records still in storage is the scenario you want to avoid.
What the FTA checks before it pays
The FTA wants invoices and reports that support each period claimed. Old periods mean old records, and the minimum VAT record retention is five years (15 for real estate). Records for 2018 to 2021 may already be past the minimum, so do not throw away anything that supports a claim. Our note on UAE bookkeeping and record-keeping rules sets out what to keep.
Refunds are commonly delayed because:
The balance does not reconcile between EmaraTax, filed returns and your ledger
Invoices are missing, or are not valid tax invoices
A supplier was not VAT-registered, so the input tax should never have been claimed
Bank details are wrong, often an outdated or mismatched IBAN letter
Credits you are building now face tighter rules. Since 1 January 2026 the FTA can reject input tax where a supply was part of a chain linked to tax evasion and you knew or should have known (new Article 54 bis, explained in VATP046). FTA Decision 13 of 2026 sets the supplier checks expected from 1 October 2026, so document your supplier due diligence.
Errors in old returns: voluntary disclosure inside the window
Reviewing 2018 to 2021 returns often turns up mistakes: an invoice claimed twice, a zero-rated sale that should have been standard-rated, or input tax nobody claimed at all. The transitional rules allow a voluntary disclosure related to the refund request within two years of filing it, provided the FTA has not yet decided the request.
The direction matters. Under-declared output tax or over-claimed input tax lowers the credit, and so the refund. Unclaimed input tax raises it. Either way, correcting the figure before the FTA finds it is far better than having an audit do it for you.
For the process and the penalties that may apply, see our guide to UAE VAT voluntary disclosure and reconsideration.
Who can file for you, and where Cosmos fits
You can file the request yourself on EmaraTax, or use a tax agent listed in the FTA tax agent register on tax.gov.ae. If you are unsure what that role involves, read what an FTA-registered tax agent does.
Cosmos keeps the books and files UAE corporate tax and VAT returns through an FTA-registered tax agent. For this deadline, Cosmos can review your VAT credit history and prepare the refund request, filed through that FTA-registered tax agent. Cosmos also offers fractional CFO support if the review exposes wider finance gaps. Cosmos is not an audit firm. Whoever you use, check them in the FTA register.
Frequently asked questions
Can I still claim VAT credits from 2018 to 2020? Yes, but only under the transitional window. Submit the refund request by 31 December 2026, or the credit lapses.
Do 2021 credits also have to be claimed by 31 December 2026? On our reading of the Ministry of Finance wording, yes. Their five years end during 2026, which places them inside the window.
What happens to credits from 2022? They follow the normal rule: five years from the end of each period. A quarter ending 31 March 2022 lapses on 31 March 2027.
Can I keep carrying an old credit forward instead of asking for a refund? Only within the five years. You can use it against payable tax or penalties, but any unused remainder lapses at the end, so very old credits need a refund request now.
How long does an FTA VAT refund take? The FTA aims for 25 business days from a complete application, up to 55 working days with audit review. Add up to 25 business days after you send extra information.
Is there a fee for a VAT refund request? No. Form VAT311 is free to submit.
Does the five-year limit apply to other taxes as well? Yes. The Tax Procedures Law change covers credit balances held with the FTA generally, so review credits under other taxes too.
I have deregistered for VAT: can I still claim? The five-year limit still applies. Check your position with the FTA or a tax agent, and see our guide to deregistering for UAE corporate tax and VAT.
Old credits are money the FTA already owes you, but only until the clock runs out. Reconcile your balances this quarter, file by the end of November and keep the evidence that proves every dirham.
