UAE VAT Refund Deadline: Claim 2018 to 2021 VAT Credits Before 31 December 2026

The UAE VAT refund deadline for older credit balances is 31 December 2026. VAT credits from tax periods ending between 2018 and 2021 must be claimed as a refund, or used to settle tax liabilities, by that date. After it, the right to recover them is lost.

What changed in 2026

Two laws took effect on 1 January 2026: Federal Decree-Law No. 17 of 2025, which changes the Tax Procedures Law, and Federal Decree-Law No. 16 of 2025, which changes the VAT Law. Together they give taxpayers five years, counted from the close of each tax period, to request a refund of the credit balance or offset it against tax due. Before 2026, excess VAT credits could be carried forward with no fixed end date.

Why the UAE VAT refund deadline is 31 December 2026

A transitional rule covers balances whose five-year window closed before 1 January 2026 or closes during 2026. Those balances can still be claimed, but only until 31 December 2026. In practice, that captures credits from tax periods ending between 2018 and 2021. Credits from 2022 onwards run on the normal five-year clock, period by period.

Excise Tax credit balances are covered by the same five-year framework and the same transitional deadline.

Who should check now

Any business carrying VAT credits from earlier years should review them, especially exporters and others regularly in a refund position, groups with several VAT registrations, and businesses that have been through a restructuring or a change to a VAT group.

What to do before the deadline

• Reconcile the credit balance in your FTA account with your VAT returns and ledgers.
• Map each balance to its tax period and the date it expires.
• Check the tax invoices and records behind each claim. The FTA can audit refund requests filed in the final year of the window even after the normal limitation period ends.
• Decide whether to claim a refund or use the balance against liabilities, and file well before December to allow time for FTA review and any information requests.

How nAlyze helps

nAlyze helps businesses meet the UAE VAT refund deadline. We identify historic VAT credit balances, map their expiry dates, check the supporting records, and prepare and submit refund applications through EmaraTax, managing FTA queries through to payment. Explore our VAT refund services or see if you’re a fit.

Source: Ministry of Finance announcement on WAM

Related: How to claim a VAT refund in the UAE