Attest Know-how

Decision 13 inside your SAP: from requirement to a specification your team can build

A knowledge partnership for the procure-to-pay process of the UAE entities: discovery, functional gap assessment, a specification development kit with test cases, and a conformance review.

Prepared for the Group Finance leadership of RAK Ceramics, UAE entities
1 November 2026 · Confidential, for RAK Ceramics
Attest, a platform by TCA, powered by Suntech
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.

Contents

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From 1 October 2026 the group must be able to show that each supplier and each supply was verified before input tax is deducted

1 The law

Decision 13 of 2026

  • Applies to taxable persons, to supplies received, before input tax is deducted (Art. 2)
  • In force from 1 October 2026 (Art. 7)
2 The duty

Verify, document, keep

  • Verify the supplier (Art. 3) and each supply (Art. 4)
  • At first dealing, and again if not verified in the previous 12 months (Art. 5(1))
  • Document the steps and keep the records (Art. 5(3)); keep a written policy (Art. 5(4))
3 The consequence

VAT Decree-Law Art. 54(bis)

  • Added by Federal Decree-Law No. 16 of 2025
  • The Authority may reject a deduction where the person should have been aware that the supply was part of a tax-evasion chain
  • A person who did not verify as the Authority prescribes is treated as required to be aware (54(bis)(3))
We say what the law says. What the Authority decides in a given case is for the Authority; our aim is that your claims rest on verification and records you can show.
Sources: FTA Decision No. 13 of 2026, Arts. 2, 5, 7; VAT Decree-Law No. 8 of 2017, Art. 54(bis) (added by Federal Decree-Law No. 16 of 2025). Unofficial English translation; the Arabic Gazette text controls.
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Your SAP already records every purchase; it does not, by default, record that the supplier and the supply were verified

Recorded in SAP todayDecision 13 asks for
Orders, receipts, invoices and paymentsProof that the supplier is genuine: identity, place of business, risk, and more for large suppliers
Approvals and release codes on purchase ordersProof that each supply is genuine: commercial reason, payment terms, price, activity, goods, intermediary
Vendor master data and bank detailsWho verified, when, and on what evidence, at every step
Change documents on master data and ordersA file you can hand over for each input tax claim
Attached documents on vendors, orders and invoicesA written policy naming the persons in charge
The gap is knowledge: which checks, at which step, by whom, with what proof.
Reading of standard SAP ECC 6.0 functionality (verified reference) against Decision 13, Arts. 3 to 5. What is switched on in your landscape is learned in discovery.
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One question frames the work: what would you show the Federal Tax Authority today for one input VAT claim?

Take one input VAT claim from last month. From the supplier to the payment, what is in the file today, and how long would it take to assemble?

If you can produce a clean file in a day

Decision 13 is largely a policy and routine question for you. We help confirm that, and close the few gaps.

If it takes longer, or parts are missing

The gaps are what we find in discovery and the functional gap assessment, and close with a specification your team builds.

Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended.
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Scope: the UAE entities of the group, each supplier and each supply

In scope

  • The UAE entities of the group that are taxable persons and deduct input tax
  • Purchases of goods and services, from existing and new suppliers
  • The procure-to-pay process in SAP ECC 6.0 and the systems around it

Outside this work

  • Entities outside the UAE, including projects and plants abroad
  • The sales side and customer systems
  • Corporate tax and other regimes

Confirmed in discovery

  • The exact list of entities and company codes
  • Which entities share suppliers
  • How thresholds are counted across entities (see Appendix A.3)
Scope set by the client relationship manager; entity list to be confirmed in discovery.
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Decision 13 has five operative articles and 27 obligations: the supplier, the supply, the procedure and the exceptions

ArticleWhat it coversObligations
Art. 2Scope: taxable persons, supplies received, before input tax is deductedFrame
Art. 3Verification of the supplier: identity, place of business, risk level, enhanced verification of large suppliers13
Art. 4Verification of the supply: general assessment, payment conditions, circumstances of the supply8
Art. 5Procedures: when to verify, each supply, document and keep records, written policy4
Art. 6Exceptions: small supplies, and when the exception does not apply2
Art. 7In force from 1 October 2026Date
Counted from the Decision text, which we checked word by word against the FTA publication: 13 + 8 + 4 + 2 = 27 obligations.
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended. Unofficial English translation; the Arabic Gazette text controls.
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We group the 27 obligations into nine checks, and every clause sits on at least one

L01 Identity
Art. 3(1)
Is the supplier who it says it is? Individual: ID, and met before the supply. Company: incorporation and representative ID.
L02 Place of business
Art. 3(2)
Is there an actual place of business, confirmed electronically or by a visit, and does it fit the supplier's activity?
L03 Risk indicators
Art. 3(3)
Any red flag in 12 months: address or key people changed more than twice, or disproportionate transactions? If so, an explanation is kept.
L04 Enhanced check
Art. 3(4)
Above AED 375,000 in the past 12 months or expected in the next 12: bank confirmation, and public reviews with no sign of tax evasion?
L05 General assessment and payment terms
Art. 4(1), 4(2)(a)
Is there a genuine commercial reason, and are the payment terms justified, including any third party or foreign account?
L06 Payment method
Art. 4(2)(b)
Is payment electronic? Cash only with a documented reason, within legal limits, and easily verifiable.
L07 Circumstances of supply
Art. 4(3)
Do price, licensed activity, origin and ownership of goods, and any intermediary role stand up?
L08 Timing, records and policy
Art. 5
Verified at first dealing or within 12 months, each supply checked, records kept, and a written policy in place?
L09 Small-supply exception (optional)
Art. 6
Under AED 10,000 excluding VAT, unless the supplier total is or will be above AED 100,000 in 12 months.
Nine is Attest's grouping of Articles 3 to 6. Maker and checker is our control design; the Decision asks for a written policy naming the persons in charge (Art. 5(4)).
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Supplier checks (Art. 3): who the supplier is, where it operates, and what risk it carries

ClauseRequirementTypical evidence
3(1)(a)(1)Individual: copy of a valid Emirates ID or passportID copy with expiry date
3(1)(a)(2)Individual: meet the supplier, in person or virtually, before the supplyMeeting record: date, mode, attendees
3(1)(b)(1)Company: verify incorporation through official databases or the certificate; details identical to name, address and employeesRegistry extract or certificate, comparison
3(1)(b)(2)Company: identity of the authorised director, agent or employeeID copy, authority
3(2)(a), (b)Actual place of business, by electronic means or a visit; compatible with the activityVisit note or electronic evidence
3(3)(a)No more than two address changes, and no more than two changes of key people, in 12 months; transactions not disproportionate or unexpectedAddress and contact history, volume comparison
3(3)(b)If an indicator applies: a clear, justified explanation, retained and given to the Authority on requestWritten explanation with its facts
3(4)Above AED 375,000 over the previous 12 months, or expected over the next 12: bank account and client recommendations where availableTrigger calculation
3(4)(a), (b)Bank confirmation from an authorised bank in the State; review of reliable public reviews and mediaBank letter; dated search record
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended.
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Supply checks (Art. 4): whether this purchase makes commercial sense and is paid properly

ClauseRequirementTypical evidence
4(1)(a), (b)General assessment of the supply's conditions; the supplier's engagement rests on genuine commercial reasonsReason recorded on the purchase order
4(2)(a)Payment method and conditions justifiable; a third party in the payment, or an account outside the supplier's country of incorporation, needs a reasonable commercial explanationBank-detail history; explanation
4(2)(b)Pay by electronic means; cash only with a documented commercial reason, within the thresholds in applicable tax legislation, and easily verifiablePayment record; cash justification
4(3)(a)Prices or margin not commercially unjustifiable or significantly different from market without a clear reasonBenchmark or quotations
4(3)(b)Supply within the supplier's ordinary activity and licensed activitiesLicence activities against category
4(3)(c)Authenticity and origin of the goods received; the supplier's ownership or right to dispose of themDelivery note, origin and ownership documents
4(3)(d)If the supplier is an intermediary: a clear, justifiable commercial explanation for its roleWritten explanation
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended. The cash thresholds are in 'applicable tax legislation'; the Decision does not name them (see Appendix A.3).
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Procedure and records (Art. 5): when to verify, for what, and how to prove it

First dealingVerify the supplier (5(1))
Each supplyVerify the supply (5(2))
Within 12 monthsVerify again if not verified in the previous 12 (5(1))
DocumentSteps, documents, records (5(3))
PolicyPersons in charge, powers (5(4))

What this means in practice

  • A supplier verification has a date, and the date expires
  • Each supply carries its own verification, even for a verified supplier
  • The records must let the Authority verify that the steps were implemented correctly

What the Decision does not say

  • How long the records must be kept
  • How totals are counted when several entities buy from one supplier
  • These are agreed with your tax owner (Appendix A.3)
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended.
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Three thresholds decide how much verification a supplier needs

Art. 6(1)

AED 10,000 per supply

A supply with consideration, excluding VAT, below AED 10,000 may be disregarded. The word is 'may': using the exception is a choice of policy.

Art. 6(2)

AED 100,000 per supplier

The exception does not apply if the total from the supplier exceeds AED 100,000 over the previous 12 months, or is expected to exceed it over the next 12.

Art. 3(4)

AED 375,000 per supplier

Above AED 375,000 over the previous 12 months, or expected over the next 12: verify a bank account (letter from an authorised bank in the State) and review reliable public reviews and media.

SAP must therefore be able to tell, for each supplier, the rolling 12-month total and the expected next-12-month value. That is a reporting and data question, not a screen.
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended. How totals are counted across entities, and what evidence of 'expected' is enough, are open points (Appendix A.3).
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What the text leaves to interpretation, and how we handle it

PointOur method
How supplier totals are counted across entities and company codesState the reading, cite the article, agree it with your tax owner, record the decision
What evidence of 'expected to exceed' is enoughUse contract values and open orders as evidence, agree the rule with your tax owner
Which legislation sets the cash thresholds referred to in Art. 4(2)(b)Identify the instrument with your tax adviser before the rule is built
How long records must be keptAlign with the retention rules your tax owner confirms; do not archive earlier
Overseas suppliers and imports; group and related suppliersApply the same checks; record the position agreed with your tax owner
Interpretation points are not settled by the text. Decisions are the taxable person's, with its tax adviser. See Appendix A.3.
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Decision 13 is a VAT rule that applies now; e-invoicing is a separate programme that reaches businesses in phases

Decision 13 (VAT)

  • In force from 1 October 2026
  • Applies to the taxable person's own deduction of input tax
  • Verification and records, whatever the invoice format

E-invoicing

  • Phased under the Ministerial Decisions; dates per the archived texts
  • Your service provider delivers the invoice; it does not decide your deduction
  • The two work together; the regimes are kept separate
Sources: FTA Decision No. 13 of 2026; Ministerial Decisions on e-invoicing (archived texts; phase dates to be checked at the time of use).
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3

The SAP ECC 6.0 P2P cycle

Where in our SAP flow does Decision 13 bite?

3.1The cycle on one page: 30 steps, 20 touched by Decision 13, 10 not3.2Supplier discovery: Decision 13 starts the day you first deal with a supplier3.3Onboarding documents: the evidence for the supplier checks is collected here3.4Master data governance is the right gate for 'verified before activated'3.5Vendor creation in ECC: where the supplier becomes usable, and where the controls that stay are placed3.6Contracts: the forward-looking value is the evidence for 'expected to exceed'3.7No direct impact: requisition, sourcing and info records, with one watch point3.8Purchase order creation: where the commercial reason and the price are recorded3.9PO release: the natural place for finance and tax concurrence3.10No direct impact: budget check, PO output, supplier confirmation and advance shipping notice3.11PO amendment: a change after approval is re-checked, not waved through3.12Goods receipt: where the genuineness of the goods is evidenced3.13Services: acceptance evidence plays the role of the goods receipt3.14Invoice capture: automated paths must follow the same rules3.15Invoice verification, the three-way match, is the gate before the liability is posted3.16Liability and input tax posting: the claim begins here3.17Blocks and release: a Decision 13 reason joins the block reasons you already use3.18Payment run: bank data and payment method are checked before money moves3.19Manual payments and cash: the exception path3.20The VAT return: only claims with a complete verification file are deducted3.21Evidence storage and archiving: nothing is archived away before its time3.22No direct impact: remittance, GR/IR clearing, period-end, and closure of orders and contracts3.23One claim traced through the cycle: what SAP holds, and the Decision 13 evidence that sits beside it3.24Companion systems around ECC: where each sits and what Decision 13 asks of it3.25The 30 steps with their Decision 13 impact
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The cycle on one page: 30 steps, 20 touched by Decision 13, 10 not

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

7 steps where Decision 13 adds a control

Master data governance, vendor creation, PO release, invoice verification, blocks and release, the VAT return, evidence storage.

13 steps where it adapts what you do

Discovery, onboarding documents, contract, PO creation and amendment, receipts, invoice capture, tax posting, payments, archiving.

10 steps with no direct impact

Requisition, sourcing, info records, budget check, PO output, confirmation, remittance, clearing, period-end, closure. You know these as they are.

Click any box to go to its slide. Each step slide shows what happens in standard SAP, what Decision 13 impacts, and what changes, for new and for existing suppliers.
Standard SAP ECC 6.0 procure-to-pay (verified reference), read against Decision 13. Companion systems (supplier portal, master data governance, GRC) are shown 'if present in your landscape'.
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Supplier discovery: Decision 13 starts the day you first deal with a supplier

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Discovery and registration happen in the supplier portal when one is used: SRM (Registration of Suppliers) or Ariba
  • The approved vendor is then created in ECC
  • Without a portal, procurement requests the vendor directly
Who: Procurement, the supplier

What Decision 13 impacts

  • Verification is due at first dealing with the supplier
  • The identity, address, licence and activities the supplier declares become the starting evidence
Art. 5(1)L01L02L07

What changes

  • Capture at registration the data Decision 13 needs: supplier type, legal name, licence, address, authorised person, activities, bank country
  • Record the date of first dealing
  • Route the supplier to verification before creation
New suppliers Registration is the entry point; no purchase before verification.
Existing suppliers Not applicable here; existing suppliers enter the verification waves (slide 4.3).
SAP: standard supplier registration (SRM, Ariba) per the verified reference; 'if present in your landscape'. Law: Decision 13, Art. 5(1).
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Onboarding documents: the evidence for the supplier checks is collected here

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Questionnaire and KYC documents (certificates, bank letter) are collected in the portal, or attached to the vendor object (LFA1) through Generic Object Services (GOS), stored in SOOD, SOFM, SRGBTBREL and SOFFCONT1
  • Or kept in an external document system through ArchiveLink (TOA01 to TOA03)
Who: Procurement, master data team

What Decision 13 impacts

  • Identity documents for individuals and companies
  • Proof of an actual place of business
  • Risk explanation where an indicator applies
  • Bank confirmation and public-review record above AED 375,000
Art. 3(1)Art. 3(2)Art. 3(3)(b)Art. 3(4)

What changes

  • A document checklist by supplier type: individual, company, large supplier
  • Each document linked to the vendor, with date, source and who checked it
  • Expiry dates tracked so re-verification is not missed
New suppliers Checklist completed before the vendor is activated.
Existing suppliers Documents already held are mapped to the checklist; gaps are listed per supplier.
SAP: GOS and ArchiveLink per the verified reference. Law: Decision 13, Art. 3.
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Master data governance is the right gate for 'verified before activated'

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Master Data Governance for suppliers (MDG-S), where present, runs create and change as a workflow: request, approve, activate
  • Duplicate checks and data-quality rules; clean masters replicate to ECC
  • Onboarding checklists often run here, before the vendor number exists in ECC
Who: Master data team, procurement, finance

What Decision 13 impacts

  • Do not activate a new supplier for purchasing until the supplier verification is complete
  • Address and key-person changes feed the 12-month risk indicators
Art. 5(1)Art. 3(3)(a)L01 to L04

What changes

  • Add verification status, date and supplier class to the request
  • Activation rule: only when verification is complete or explained
  • Change requests on address, bank and contacts trigger a re-check
New suppliers Activation depends on completed verification.
Existing suppliers Change workflow applies to every later change of address, bank or contacts.
SAP: MDG-S per the verified reference, 'if present in your landscape'; whether you use it is learned in discovery. Law: Decision 13, Arts. 3 and 5.
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Vendor creation in ECC: where the supplier becomes usable, and where the controls that stay are placed

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Vendor master created with XK01 and changed with XK02
  • Tables: LFA1 (general), LFB1 (company code), LFM1 (purchasing organisation), LFBK (bank details), WYT3 (partner functions), LFB5, LFBW
  • Duplicate check by configuration; reference vendor in LFB1-REPRF
Who: Master data team

What Decision 13 impacts

  • Address and key-person changes counted over 12 months; change documents (CDHDR, CDPOS) record who changed what
  • Bank account, payee and account country
  • Date of last verification
Art. 3(3)(a)(1), (2)Art. 3(4)(a)Art. 4(2)(a)Art. 5(1)

What changes

  • Verification status, date, supplier type and threshold class held with the vendor (a field or a linked record)
  • A change-tracking report for address, bank and contacts
  • Payment block until the supplier is verified
New suppliers Created only after verification; status and date set at creation.
Existing suppliers Status and date are loaded for each existing vendor as the waves complete; unverified vendors carry the block.
SAP: vendor master transactions and tables per the verified reference. Law: Decision 13, Arts. 3, 4 and 5.
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Contracts: the forward-looking value is the evidence for 'expected to exceed'

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Outline agreement (contract) created with ME31K: EKKO header (document category K), EKPO items, conditions through KNUMV to KONV
  • Release orders against the contract: ME21N with contract reference; consumption tracked in EKAB
Who: Procurement, contract owner

What Decision 13 impacts

  • 'Expected to exceed' AED 375,000 or AED 100,000 over the next 12 months
  • Genuine commercial reasons
  • Any intermediary role
Art. 3(4)Art. 6(2)Art. 4(1)Art. 4(3)(d)

What changes

  • The contract target value feeds the expected-spend view per supplier (our reading of 'expected', to be agreed with your tax owner)
  • Contract approval records the commercial reason
  • Review when releases or target value move a supplier into a higher class
New suppliers Expected value known from the start of the relationship.
Existing suppliers Existing contracts are read once to set each supplier's expected-spend class.
SAP: ME31K and tables per the verified reference. Law: Decision 13, Arts. 3(4), 4, 6(2).
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No direct impact: requisition, sourcing and info records, with one watch point

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Purchase requisition ME51N (EBAN, EBKN); release strategy ME54N and ME55 (T16FS, T16FC, T16FV, T16FW, CEBAN)
  • RFQ ME41; quotations ME47 and ME49; convert to PO with ME21N
  • Info record ME11 (EINA, EINE); vendor classification with XK02
Who: Requesters, procurement

What Decision 13 impacts

No direct impact.

Watch point: A supplier chosen in sourcing who is not yet verified must go to verification before the purchase order (Art. 5(1)).

What changes

None.

New suppliers Informational warning at source selection if the supplier is unverified.
Existing suppliers No change for verified suppliers.
SAP: verified reference. Law: Decision 13, Art. 5(1).
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Purchase order creation: where the commercial reason and the price are recorded

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • PO created with ME21N: EKKO, EKPO, EKKN (account assignment), EKET, EKPA; pricing through KONV
  • Tax code per item (EKPO-MWSKZ) from FTXP and T007A; GL determination T030K
Who: Buyer

What Decision 13 impacts

  • Genuine commercial reasons
  • Price or margin against market
  • Supplier's licensed activity
  • Supplier class by threshold
  • Supplier verified and in date
Art. 4(1)Art. 4(3)(a), (b)Art. 6Art. 5(1)

What changes

  • Verification and threshold check when the PO is created: a warning or a block, as set with you in design
  • Reason and price benchmark captured on the PO
  • Only verified, in-date suppliers can be chosen for new POs
New suppliers Standard path from the first PO, with the check built in.
Existing suppliers Suppliers verified in a wave are selectable; others see the warning until verified.
SAP: ME21N and tables per the verified reference. Law: Decision 13, Arts. 4, 5, 6.
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PO release: the natural place for finance and tax concurrence

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Release strategy: classification-based approval by value, document type, purchasing group and material group, into multi-level release codes; a finance release code assigned to an FI role through role resolution
  • Tables T16FG, T16FC, T16FV, T16FS, T16FW; status in EKKO (FRGGR, FRGSX, FRGKE, FRGZU); classification CABN, CAWN, AUSP; every approval logged in CDHDR and CDPOS
Who: Finance, tax, budget owner

What Decision 13 impacts

  • Flagged items need documented concurrence: a disproportionate transaction, an intermediary, an activity mismatch
  • Who may concur is a written policy
Art. 4(1), 4(3)Art. 3(3)(a)(3)Art. 5(4)

What changes

  • A Decision 13 release step, triggered by flags
  • A tax concurrence role in the release strategy
  • A record of who concurred, when, and why
New suppliers The release step applies from the first PO.
Existing suppliers Open POs at the date of change are released under the existing strategy; new releases follow the new step.
SAP: release strategy per the verified reference. Law: Decision 13, Arts. 3(3), 4, 5(4).
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No direct impact: budget check, PO output, supplier confirmation and advance shipping notice

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Commitment and budget check: CO (COSS, COSP) or Funds Management (FMIOI; budgets BPJA, BPGE)
  • PO output ME9F through output control (NAST) or EDI IDoc ORDERS05 (EDIDC, EDID4); PDF through output type NEU, spooled in TSP01 and attached to BUS2012
  • Order confirmation (ME22N confirmation control) or inbound EDI DESADV (EKES); inbound delivery LIKP, LIPS (VL31N)
Who: Budget owner, buyer, supplier

What Decision 13 impacts

No direct impact.

Watch point: Keep the PO output as part of the evidence file (Art. 5(3)).

What changes

None.

New suppliers No change.
Existing suppliers No change.
SAP: verified reference. Law: Decision 13, Art. 5(3).
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PO amendment: a change after approval is re-checked, not waved through

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Changes through ME22N: price, quantity, terms; change documents in CDHDR and CDPOS
  • Re-release where the change moves the order outside its release strategy
Who: Buyer, approvers

What Decision 13 impacts

  • A change of supplier, bank or payee
  • A rising value that moves the supplier into a higher class
  • A changed commercial reason
Art. 4(2)(a)Art. 6Art. 4(1)

What changes

  • Re-release when supplier, bank, value or payment terms change
  • Reason for the change recorded
New suppliers Same rule from the first PO.
Existing suppliers Same rule on existing open orders when they are next amended.
SAP: ME22N per the verified reference. Law: Decision 13, Arts. 4 and 6.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›28 / 83

Goods receipt: where the genuineness of the goods is evidenced

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • MIGO, movement type 101; material document MKPF and MSEG; accounting BKPF and BSEG: debit inventory (BSX), credit GR/IR (WRX)
  • Stock MARD, MBEW, MCHB, MCHA; PO history EKBE (record type WE)
  • Quality: inspection lot QALS; results QE51N or QA32 (QAMR, QASE, QAMV); usage decision QA11 (QAVE); stock moves with movement 321; rejects to blocked stock or return movement 122
Who: Receiving team, quality, warehouse

What Decision 13 impacts

  • Authenticity and origin of the goods
  • The supplier's right to dispose of them
  • Goods within the supplier's activity
Art. 4(3)(c)Art. 4(3)(b)

What changes

  • Receipt linked to the delivery note and origin evidence for flagged items
  • Quality result kept as evidence
  • Receiving team records exceptions: wrong goods, unexpected origin
New suppliers Evidence captured at the first receipt.
Existing suppliers Same rule for receipts from existing suppliers, by flag.
SAP: MIGO and quality per the verified reference. Law: Decision 13, Art. 4(3).
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Services: acceptance evidence plays the role of the goods receipt

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Service purchase orders use item category D with overall and expected limits (ESUH header, ESLL lines)
  • The service entry sheet (ESSR, ESLL) records the work accepted; unplanned services are allowed within limits
Who: Service requester, procurement

What Decision 13 impacts

  • Service within the supplier's licensed activity
  • Commercial reason
  • Evidence that the service was rendered
Art. 4(3)(b)Art. 4(1)Art. 5(3)

What changes

  • Acceptance evidence required for flagged services
  • Service entry linked to the verification record
New suppliers Evidence captured at the first acceptance.
Existing suppliers Same rule for services from existing suppliers, by flag.
SAP: service procurement per the verified reference. Law: Decision 13, Arts. 4 and 5(3).
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›30 / 83

Invoice capture: automated paths must follow the same rules

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Invoices arrive by scan or OCR, email, EDI or RPA
  • Parking with MIR7, then workflow approval and posting
  • The image is linked to the invoice object (BUS2081) through ArchiveLink (TOA01 to TOA03), by early or late archiving
Who: Accounts payable, shared service

What Decision 13 impacts

  • The invoice image is linked to the verification record
  • Every entry path passes the same gate; an automated path must not bypass it
Art. 5(3)Art. 5(2)

What changes

  • The same Decision 13 status check on every entry path: manual, parked, RPA, EDI
  • Invoice image linked to the verification record
New suppliers Gate applies on every path from day one.
Existing suppliers Existing automation is checked in discovery so the gate is not bypassed.
SAP: invoice capture and ArchiveLink per the verified reference. Law: Decision 13, Art. 5.
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Invoice verification, the three-way match, is the gate before the liability is posted

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • MIRO: invoice document RBKP and RSEG
  • Three-way match: PO price and quantity (EKKO, EKPO) against goods receipt (EKBE, MSEG) against the invoice (RSEG), with tolerance keys (T169G)
  • Duplicate invoice check (T169P); reversal MR8M
Who: Accounts payable

What Decision 13 impacts

  • Each supply must be verified; the match proves quantity and price, not Decision 13 verification
Art. 5(2)

What changes

  • Add a Decision 13 completeness check at MIRO: supplier verified and in date; supply checks complete or concurred
  • If not complete, the invoice is posted blocked, not rejected
New suppliers Gate applies from the first invoice.
Existing suppliers Existing suppliers pass the gate as their wave completes; until then invoices post blocked.
SAP: MIRO per the verified reference. Law: Decision 13, Art. 5(2).
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Liability and input tax posting: the claim begins here

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • MIRO posts: credit vendor (posting key 31), debit GR/IR (WRX), debit input tax (VST), price difference (PRD); tax lines in BSET
  • Tax code validated and recalculated against the PO (FTXP, T030K); input tax posts to tax accounts by account key VST or NAV
Who: Accounts payable, tax

What Decision 13 impacts

  • Deduction must follow verification; the posting itself is routine
VAT Law Art. 54(bis)(3)Art. 2

What changes

  • Tag each tax line with its verification status so the return can hold claims that are not complete
New suppliers Status on every tax line.
Existing suppliers Status on every tax line; historical lines are classified during the waves.
SAP: tax posting per the verified reference; the UAE VAT set-up in your system is confirmed in discovery. Law: VAT Decree-Law Art. 54(bis)(3); Decision 13, Art. 2.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›33 / 83

Blocks and release: a Decision 13 reason joins the block reasons you already use

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Automatic invoice block on variance (RSEG-SPGRS blocking reason); manual block (RBKP-ZLSPR)
  • Release with MRBR; GR-side corrections with MR11
Who: Accounts payable, tax

What Decision 13 impacts

  • An unresolved flag keeps the item blocked until an explanation is recorded
Art. 5(2)Art. 3(3)(b)

What changes

  • A new block reason, 'Decision 13 pending'
  • Release only by an authorised role, with reason and approver recorded
New suppliers Block only where verification or explanation is missing.
Existing suppliers Same; the block lifts as each supplier's verification completes.
SAP: invoice blocks per the verified reference. Law: Decision 13, Arts. 3(3)(b) and 5(2).
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Payment run: bank data and payment method are checked before money moves

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Payment terms from the vendor master or PO (T052, BSEG-ZTERM)
  • Automatic payment run F110: proposal, edit, run, output (REGUH, REGUP, REGUA, PAYR)
  • Bank determination and payment methods in FBZP (T012, T012K, T042, T042Z, T042E); payment block key BSEG-ZLSPR released through FBL1N or workflow
Who: Treasury, accounts payable

What Decision 13 impacts

  • A third party in the payment, an account in another country, changed bank details
  • Electronic payment
Art. 4(2)(a)Art. 4(2)(b)

What changes

  • The payment proposal excludes blocked items
  • A bank-detail change or a third-party payment triggers an explanation
  • Arrangements where a bank pays the supplier, such as supplier finance, are documented
New suppliers Bank details verified at onboarding; later changes re-checked.
Existing suppliers Existing bank details reviewed in the waves; changes after go-live re-checked.
SAP: payment run per the verified reference. Law: Decision 13, Art. 4(2).
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Manual payments and cash: the exception path

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Manual payments F-53; cheque F-58
  • The same payment tables (REGUH, REGUP) and PAYR
Who: Treasury

What Decision 13 impacts

  • Cash only with a documented commercial reason, within the thresholds in tax legislation, and easily verifiable
Art. 4(2)(b)

What changes

  • Tax concurrence for any cash payment
  • A record of the reason
New suppliers Same rule.
Existing suppliers Same rule.
SAP: manual payments per the verified reference. Law: Decision 13, Art. 4(2)(b).
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›36 / 83

The VAT return: only claims with a complete verification file are deducted

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Input tax is read from BSET, BKPF and BSEG; report S_ALR_87012357 (tax on sales and purchases)
  • Country advance-return programs such as RFUMSV00; withholding tax, where used, in T059*, WITH_ITEM and LFBW
  • To confirm in discovery: how the UAE VAT return is produced in your system
Who: Tax team

What Decision 13 impacts

  • A file for each claim
  • Deduct only where verification is complete
Art. 5(3)VAT Law Art. 54(bis)(3)

What changes

  • A return-period review: claims by status (complete, held, concurred)
  • An evidence file for each claim
  • Held claims carried forward when resolved
New suppliers Every claim has a file from the start.
Existing suppliers Claims from before the waves are reviewed and classified in the first return periods.
SAP: tax reporting per the verified reference (the UAE set-up is confirmed in discovery). Law: VAT Decree-Law Art. 54(bis)(3); Decision 13, Art. 5(3).
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Evidence storage and archiving: nothing is archived away before its time

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Attachments through GOS (SRGBTBREL, SOOD, SOFFCONT1) or ArchiveLink (TOA01 to TOA03) into a content server or document system
  • Document objects: vendor LFA1, PO BUS2012, contract BUS2014, goods receipt BUS2017, invoice BUS2081
  • Archiving with SARA: MM_EKKO, MM_MATBEL, MM_REBEL, FI_DOCUMNT; catalogue ADMI_FILES; read through SARE or ME82
Who: Basis, finance, records owner

What Decision 13 impacts

  • Retain records so the Authority can verify the steps; the Decision states no period
Art. 5(3)

What changes

  • Archiving rules aligned with the retention period your tax owner confirms
  • Links from verification records survive archiving
New suppliers Evidence stored with the transaction from the start.
Existing suppliers Evidence for existing suppliers is linked as each wave completes.
SAP: GOS, ArchiveLink and archiving per the verified reference. Law: Decision 13, Art. 5(3).
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No direct impact: remittance, GR/IR clearing, period-end, and closure of orders and contracts

Decision 13 adds a controlDecision 13 adapts a stepNo direct impact

In standard SAP ECC 6.0

  • Remittance advice: RFFOAVIS, or EDI REMADV, or e-mail (NAST, PAYR)
  • GR/IR clearing F.13; MR11 and MR11SHOW; period-end reclassification F.19
  • Closure flags ELIKZ (delivery completed), EREKZ (final invoice), LOEKZ (deletion or lock); mass closure MEMASSPO; contract closure ME32K, MEMASSCONTRACT; reports ME2M, ME2N, ME80FN, ME3M, ME3L, ME3N
Who: Accounts payable, finance, procurement

What Decision 13 impacts

No direct impact.

Watch point: Closure and archiving must not remove evidence early (see slide 3.21).

What changes

None.

New suppliers No change.
Existing suppliers No change.
SAP: verified reference.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›39 / 83

One claim traced through the cycle: what SAP holds, and the Decision 13 evidence that sits beside it

StageWhat SAP holdsDecision 13 evidence beside it
SupplierVendor 10001 (synthetic), company code, bank, address historyVerification record: type, date, identity, place of business, risk, large-supplier items
Purchase orderPO 4500001 (synthetic), release codes, tax codeReason, price benchmark, concurrence record
ReceiptMaterial document, quality resultDelivery note, origin evidence for flagged lines
InvoiceInvoice document, parked image, three-way matchCompleteness check passed or concurred
Tax lineBSET line, input tax accountVerification status on the line
PaymentPayment document, bank, methodBank-detail history, third-party or cash explanation
Evidence fileLinks through GOS and ArchiveLinkOne index, retrievable for this claim
Illustrative, synthetic data. No client data is used.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›40 / 83

Companion systems around ECC: where each sits and what Decision 13 asks of it

SystemRole in the cycleWhat Decision 13 asks of it
Supplier portal (SRM, Ariba)Discovery, registration, supplier self-serviceFirst dealing, documents, declared data
Master Data Governance (MDG-S)Workflow for supplier create and change; duplicate checksActivation gate; change re-checks
GRC Access ControlSegregation of duties, emergency access, role designWho may verify, concur, release or override (written policy)
Middleware (PI/PO)Connects SAP and other systemsNo new data flow for this work
Document system (ArchiveLink)Content for attachments and imagesEvidence storage and retention
Automation (RPA, EDI)Invoice and ASN processingThe same gate on every path
SAP: companion products per the verified reference, 'if present in your landscape'. What you run is learned in discovery.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›41 / 83

The 30 steps with their Decision 13 impact

#StepImpactSlide
1Discovery and registrationAdapts a step3.2
2Onboarding documentsAdapts a step3.3
3Master data governanceAdds a control3.4
4Vendor creationAdds a control3.5
5Info record, source listNo direct impact3.7
6ContractAdapts a step3.6
7Purchase requisitionNo direct impact3.7
8Sourcing and RFQNo direct impact3.7
9PO creationAdapts a step3.8
10PO releaseAdds a control3.9
11Budget checkNo direct impact3.10
12PO outputNo direct impact3.10
13Confirmation and ASNNo direct impact3.10
14PO amendmentAdapts a step3.11
15Goods receiptAdapts a step3.12
#StepImpactSlide
16Quality inspectionAdapts a step3.12
17Service entryAdapts a step3.13
18Invoice capture, parkingAdapts a step3.14
19Invoice verificationAdds a control3.15
20Liability and tax postingAdapts a step3.16
21Blocks and releaseAdds a control3.17
22Payment runAdapts a step3.18
23Manual payment, cashAdapts a step3.19
24Remittance adviceNo direct impact3.22
25GR/IR clearingNo direct impact3.22
26Period-endNo direct impact3.22
27VAT returnAdds a control3.20
28PO, contract closureNo direct impact3.22
29Evidence storageAdds a control3.21
30ArchivingAdapts a step3.21
Impact: adds a control, adapts a step, or no direct impact.
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Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›43 / 83

One rule, two starting points: new suppliers are verified before first dealing; existing suppliers when their last verification is more than 12 months old

New suppliers

Verify before the first dealing

  • Art. 5(1): verify when dealing with the supplier for the first time
  • The supplier is not usable for purchases until verification is complete
  • Verification date starts the 12-month cycle
Existing suppliers

Verify when not verified in the previous 12 months

  • Art. 5(1): on recurrent dealing, verify if not verified over the previous 12 months
  • The vendor master is classified and verified in waves
  • Verification dates are loaded as each wave completes
Both populations end in the same steady state: a verification date for every supplier, renewed within 12 months and re-checked when risk indicators arise.
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended. Art. 5(1).
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New suppliers: a defined path from request to first purchase order

StageWhoDecision 13 gateSAP touchpoint
Request and registrationProcurement, supplierData and documents collected (Art. 3)Supplier portal, if present; vendor request
VerificationMaster data team, procurement; field visit where neededIdentity, place of business, risk, large-supplier items (Art. 3)Documents in GOS or ArchiveLink
ConcurrenceTax, financeExplanations for risk flags (Art. 3(3)(b))Workflow or release step
ActivationMaster data teamOnly when complete or explained (Art. 5(1))MDG-S activation or XK01
First purchase orderBuyer, approversSupply checks (Art. 4)ME21N and release
Receipt, invoice, paymentReceiving, AP, treasuryEvidence, completeness, bank and payment checks (Art. 4, 5)MIGO, MIRO, F110
Evidence fileTax teamFile per claim (Art. 5(3))GOS, ArchiveLink
Our proposed journey; to be confirmed in discovery. 'If present' applies to companion systems.
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Existing suppliers: classify, triage by threshold, verify in waves, then keep verification current

StepWhat happensOutput
1 ClassifyClassify the vendor master: individual, company, large supplier; threshold class; active or dormantClassified list
2 TriageStart with suppliers above AED 375,000 and AED 100,000; then the rest by value and riskWave plan
3 Verify in wavesVerification as for a new supplier; dates loaded into the vendor master as waves completeVerification record per supplier
4 Open itemsOpen orders and invoices from unverified suppliers are routed through the gate; supplies already made since 1 October are assessed and documentedAssessment register
5 Steady state12-month renewal; re-check when address, bank or key people changeExpiry list; change alerts
Treatment of supplies already made since 1 October, and of individual suppliers who cannot be met before the supply, is agreed with your tax owner in discovery.
Our proposed wave plan; to be confirmed in discovery. Law: Decision 13, Art. 5(1).
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›46 / 83

What the business notices on day one: verified suppliers carry on as before

Verified supplierNot yet verified, expired or flagged
Purchase orderAs todayWarning or block, as set in design
ReceiptAs todayAs today; evidence captured for flagged items
InvoicePosts as todayPosts blocked with reason 'Decision 13 pending'
PaymentIn the payment runExcluded until released
ReturnDeductedHeld until complete
The new step appears only where verification is missing, expired or flagged. Everything else runs as it does today.
Design principle: no change to routine for verified suppliers.
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Handling exceptions without stopping the business

Small supplies (optional)

  • Art. 6(1) allows a supply below AED 10,000 to be disregarded, unless the supplier total exceeds or is expected to exceed AED 100,000
  • Whether to use the exception is your policy choice
  • If used, the rule is built once and applies automatically

Urgent purchases

  • A recorded emergency route with a reason, a named approver and a time limit
  • Reported to finance and tax
  • Cannot mark a check complete that was not performed

Disputed or unclear cases

  • Held, not rejected
  • Owner and deadline set
  • Escalation inside your existing workflow
Our proposed design; the Decision does not prescribe exception routes. Law: Decision 13, Art. 6.
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Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›49 / 83

The changes fall into eight areas of your SAP flow

AreaChangeLikely typeOwner
Vendor master and onboardingVerification status, date, class; document checklist; payment block until verifiedConfiguration and a small enhancementMaster data, procurement
Master data governanceActivation rule; change re-checksWorkflow configurationMaster data
PO creation and releaseThreshold and verification check; Decision 13 release step; concurrence roleConfiguration (release strategy) and a checkProcurement, finance, tax
Goods and service receiptEvidence for flagged itemsProcess and attachmentReceiving, quality
Invoice capture and verificationCompleteness check; new block reason; same gate on automated pathsConfiguration and an enhancementAccounts payable
Blocks and paymentPayment proposal excludes blocked items; bank change and third-party triggersConfiguration and a reportTreasury, AP
VAT return and reviewClaims by status; evidence file per claimReport and processTax
Evidence storage and archivingRetention rules; links survive archivingConfiguration and processBasis, finance
Likely types are confirmed in the specification once your configuration is known. No effort figures are given here.
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The evidence file per claim: what is in it and where each item is stored

Part of the fileWhat it holdsWhere it comes from
Supplier verification (Art. 3)Identity, place of business, risk and explanation, bank confirmation and public reviews for large suppliersVendor object: attachments, verification record
Supply verification (Art. 4)Commercial reason, payment terms, price, activity, goods origin, intermediary explanationPO, receipt, invoice and their attachments
Procedure record (Art. 5)Date of verification, each supply verified, who and whenVerification record, change documents
Payment recordMethod, bank, third-party or cash explanationPayment documents and tables
Policy (Art. 5(4))Persons in charge, powers, designated storage locationWritten policy, held once
One index per claim, assembled from what SAP already holds plus the Decision 13 records.
Our proposed file structure. Law: Decision 13, Art. 5(3) and 5(4).
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Screens people already use, with a Decision 13 section added

Vendor master
Verification statusVerified
Verified on12 Oct 2026
Valid until11 Oct 2027
Supplier classLarge (above AED 375,000)
PO release
Release stepTax concurrence
FlagIntermediary
Reason recordedYes
Concurred byTax reviewer
Invoice
Three-way matchPassed
Decision 13 checkPending
Block reasonDecision 13 pending
ActionObtain explanation
Payment run
Proposal142 items
Excluded (blocked)3 items
Bank change in 90 days1 item, explained
CashNone
Return-period review
Claims complete1,204
Held17
Concurred9
Evidence filesReady
Illustrative design intent with synthetic values. The final screens follow the capabilities and configuration confirmed in the specification.
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Monitoring: three lists the finance and tax teams will use

Verification expiring in 30 days
Supplier A (synthetic)9 days
Supplier B (synthetic)17 days
Supplier C (synthetic)26 days
Claims on hold
Awaiting explanation11
Awaiting bank letter4
Awaiting concurrence2
Threshold watch
Near AED 100,00023 suppliers
Near AED 375,0006 suppliers
Crossed this month2 suppliers
Illustrative design intent with synthetic values.
Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›53 / 83

Interfaces and roles: what touches the portal, the master data hub, automation and access control

TouchpointWhat we specifyWhy
Supplier portalData and documents captured at registrationStarts the first-dealing verification
Master data governanceActivation and change rulesGate before the vendor is usable
Automation (RPA, EDI)The same gate and status on every entry pathNo bypass
Access control (GRC, where present)Roles that verify, concur, release or override; segregation of dutiesWritten policy, Art. 5(4)
Document systemLinks and retentionArt. 5(3)
'If present in your landscape'; confirmed in discovery.
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Attest Know-how · Prepared for RAK Ceramics · Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); not legal advice; open interpretation points are listed separately.ContentsNext section ›55 / 83

Four services take you from 'what does Decision 13 mean for us' to 'it was built as specified'

1 DiscoveryHow your process really runs
2 Functional gap assessmentEach clause against what you have
3 Specification development kitEverything your IT team needs, with tests
4 Conformance reviewBuilt as specified, and passing

Each output feeds the next

The as-is map feeds the gap assessment; the gap assessment feeds the specification; the specification and tests feed the conformance review.

Your team builds

Your SAP team or partner builds inside your system. We interpret, specify, test and review. Nothing leaves your system.

Services of Attest Know-how. No dates or fees on this slide.
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Service 1, Discovery: we learn how your supplier-to-payment process really runs

What we do

  • Working sessions with tax, finance, procurement, the SAP owner, Basis and security
  • Read-only walk-through of the real screens: vendor, PO, receipt, invoice, payment
  • Existing and new supplier flows; companion systems; what is already switched on

What you get

  • The as-is map of the process and the systems
  • A list of unknowns and decisions needed
  • The wave plan inputs for existing suppliers

What we need from you

  • Time from the people above
  • A read-only walk-through
  • The documents you choose to share; nothing needs to leave your systems
Service description.
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Service 2, Functional gap assessment: each clause of Articles 3 to 6 is tested against what you have

Method

  • Compare the as-is map with the nine checks and the 27 clauses
  • A sample reviewed on your side only, or an extract you choose to give
  • Classify each gap: process, configuration, enhancement, policy

Output

  • The gap report, prioritised by risk and supplier class
  • The coverage table: clause, control, gap, priority
  • The decisions needed from tax and finance
ClauseControlAs-isGapPriority
3(1)(a)(2)Meeting before the supplyAfter discoveryAfter discoveryAfter discovery
4(2)(a)Third-party and foreign-account explanationAfter discoveryAfter discoveryAfter discovery
5(4)Written policyAfter discoveryAfter discoveryAfter discovery
Preview of the coverage table; cells are filled from discovery.
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Service 3, Specification development kit: everything your IT team needs to build it, with the tests

1

Requirements

By clause, with the open points and decisions recorded

2

Functional specification

Per control: rule, trigger, actor, concurrence, block or release, exception, proof

3

Technical specification

For your SAP ECC 6.0 landscape: objects, build steps, authorisations, transports

4

Screens

What each user sees, what blocks, which messages

5

Test pack

Positive and negative cases per control, with acceptance criteria

6

Rollout pack

Staged release, cut-over, hypercare, training notes, change control

7

Run pack

Return-period routine, evidence file format, updates when Decision 13 is clarified

Our SAP consultant confirms every SAP element before it is issued; we test on a test system first. Your team or partner builds.
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What a test case looks like: one control, from the legal clause to pass or fail

FieldExample (synthetic)
Legal basisDecision 13, Art. 5(1): verify the supplier at first dealing, and again if not verified in the previous 12 months
ControlA purchase order cannot be released for a supplier whose verification has expired
Positive caseSupplier verified 100 days ago: PO releases without a warning
Negative caseSupplier verified 400 days ago: warning or block, per the specification; PO does not release until re-verified
Evidence recordedDate of verification, user, document links
Pass or failCompared with the acceptance criterion in the specification
Illustrative, synthetic. Real test cases are written for your landscape.
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Service 4, Conformance review: were the controls built as specified, and do they pass the tests

Build completeYour team or partner
EvidenceConfiguration, test results
ReviewAgainst the specification
FindingsLogged and tracked
ClosureGaps closed, retested

What it is

Assurance that the controls are implemented as specified.

What it is not

An opinion on legal compliance, or on how the Authority will treat any claim. Interpretation stays with you and your tax adviser.

Service description.
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Who does what: your teams and ours

TeamContribution
Finance and TaxPolicy, concurrence rules, interpretation decisions, return process
ProcurementSupplier process, onboarding, buyer practices
SAP functional and BasisBuild, transports, configuration, testing support
Security and AccessRoles, segregation of duties, access control
Attest Know-howInterpretation of Decision 13, gap assessment, specifications, test cases, conformance review
Working model.
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Completeness is shown, not claimed: every clause links to a control, a specification item, a test and the evidence

ClauseControlSpecification itemTestEvidence
3(3)(b)Explanation for a risk flagAfter discoveryAfter discoveryAfter discovery
4(2)(a)Third-party payment explanationAfter discoveryAfter discoveryAfter discovery
4(3)(c)Origin and ownership of goodsAfter discoveryAfter discoveryAfter discovery
5(4)Written policyAfter discoveryAfter discoveryAfter discovery
A blank cell is a gap. Manual steps, such as a field visit, a bank confirmation or judging a commercial reason, become tracked tasks with an owner, a deadline and an escalation inside your workflow.
The coverage table covers all 27 clauses (Appendix A.1 and A.2).
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Designed to avoid disruption: staged release, test cases first, hypercare

Stage 1New suppliers and high-value POs
Stage 2Existing-supplier waves
Stage 3Full scope
HypercareSupport after each stage

Before each stage

  • Test cases passed on a test system
  • Users briefed
  • Rollback understood

Dates

Calendar dates are set with your team after discovery; none is promised here.

Proposed approach.
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Working inside your governance: transports, change control and security

Your landscape

  • Specifications are written for your development, quality and production systems
  • Your change process governs transports
  • Your Basis team controls what is built and when

Your security

  • Nothing leaves your systems
  • We work from walk-throughs and the documents you choose to share
  • No connector and no new application
Working model.
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Risks and assumptions we state up front

ItemHow we handle it
Decision 13 is new and may be clarified or amendedEverything is versioned with date and legal basis; change-impact notes on request
ECC support horizon and any plans for S/4HANAControl logic is written separately from the build steps, so it carries over
Interpretation points are openStated, agreed with your tax owner, recorded
Dependence on your teams' timePlan set with your team after discovery; no dates promised here
What is switched on in your landscapeLearned in discovery; the specification follows what you have
Working assumptions.
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Depth on the law: every clause mapped, every open point named

27 clauses, nine checks

Every operative clause of Articles 3 to 6 sits on at least one check, with its article cited.

Checked against the source

Our text of Decision 13 was compared word by word with the FTA publication.

Open points named

The interpretation points are listed and handled openly, not hidden.

Appendix A.1 to A.3.
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Depth on SAP: the standard cycle, step by step, with the companions around it

Verified standard reference

Our SAP ECC 6.0 procure-to-pay reference is verified by our SAP consultant: the full cycle with transactions, tables and document storage.

Our designs are confirmed too

Each Decision 13 control we place on an SAP mechanism is confirmed by the same consultant before we issue it.

Tested before issue

SAP-specific elements are tested on a test system before they go into a specification.

SAP: standard ECC 6.0 functionality; your configuration is learned in discovery.
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The team: UAE market experience, an accredited e-invoicing provider, and people who have done this work

Suntech

In the UAE market for more than 20 years

A brand the UAE market knows, with long experience of its businesses and of the tax environment they work in.

E-invoicing

An Accredited Service Provider

Suntech is an Accredited Service Provider (ASP) for e-invoicing.

Technology

Full-time CTO

Experience at Amazon in transfer pricing and e-invoicing.

Functional

Full-time functional consultant

  • Chartered Accountant, All India Rank 1
  • 10 years of SAP experience; oil and gas sector; GST taxation in India
  • Last 5 years in automation and digital transformation, leading transformation projects for SMEs in India
Team profiles are described without names.
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This engagement is a first step into Attest, the Compliance OS for the GCC

The aim

One platform for every obligation

Attest is being built to tell an organisation every obligation under every law that applies to it, who owns it, when it is due, and what proof is needed.

This engagement

Specifications and controls that stay yours

You keep the specification and the controls built in your SAP. The platform is a way to run the same obligations at scale, if and when it suits you.

Part of the platformWhat it doesStatus today
Knowledge HubLaws, jurisdictions, obligations and articles that the products readDemonstration
Attest MNC, SMC, ProfessionalCompliance operating system for groups, small and medium corporates, and tax practicesDemonstrations
Attest P2PDecision 13 control for purchases, for companies that need it as softwareDemonstration
Attest E-invoicingPhased UAE e-invoicing, through an accredited service providerManaged service
Attest MarketplaceTools and extensions for compliance teamsDemonstration, planned
Status labels are honest: shown as demonstrations unless stated. Know-how consulting, this engagement, is delivered now. Source: Attest platform vision.
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A method: specification, test, review, and updates when Decision 13 is clarified

InterpretDecision 13, article by article
SpecifyFor your landscape
TestCases before build
ReviewConformance to the specification
UpdateWhen the Decision is clarified

Change-impact notes

When Decision 13 is clarified or amended, we tell you what changes in the controls and the specification. Optional, on request.

Working model.
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Next step: a discovery kick-off with Finance, Tax, Procurement and the SAP and Basis teams

Who we need in the room

  • Group finance and tax leadership
  • Procurement
  • SAP owner, functional and Basis
  • Security and access, as needed

What we will walk through

  • Vendor creation, purchase order and release, receipt, invoice verification, payment run
  • Existing and new supplier flows
  • What is already switched on

What stays with you

  • Your data, in your systems
  • A sample reviewed on your side
  • The documents you choose to share
No fees, dates or commitments on this slide.
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Decisions we ask of the group

DecisionWhy it matters
Name the sponsor and the tax ownerInterpretation decisions and the policy under Art. 5(4)
Name the SAP owner and any implementation partnerWho builds, and who gives us access to walk-throughs
Confirm the scope of entitiesUAE entities and company codes
Confirm confidentiality termsFor anything you share with us
No fees or commercial terms on this slide.
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Article-by-article coverage matrix: Article 3 (13 obligations)

ClauseRequirementCheckControlSpecification itemTestEvidence
3(1)(a)(1)Individual: valid ID copyL01C-L01aAfter discoveryAfter discoveryAfter discovery
3(1)(a)(2)Individual: met before the supplyL01C-L01bAfter discoveryAfter discoveryAfter discovery
3(1)(b)(1)Company: incorporation verified, details identicalL01C-L01cAfter discoveryAfter discoveryAfter discovery
3(1)(b)(2)Company: ID of the authorised representativeL01C-L01dAfter discoveryAfter discoveryAfter discovery
3(2)(a)Actual place of businessL02C-L02aAfter discoveryAfter discoveryAfter discovery
3(2)(b)Place compatible with activityL02C-L02bAfter discoveryAfter discoveryAfter discovery
3(3)(a)(1)Address changed more than twice in 12 monthsL03C-L03aAfter discoveryAfter discoveryAfter discovery
3(3)(a)(2)Key people changed more than twice in 12 monthsL03C-L03bAfter discoveryAfter discoveryAfter discovery
3(3)(a)(3)Disproportionate or unexpected transactionsL03C-L03cAfter discoveryAfter discoveryAfter discovery
3(3)(b)Justified explanation kept; given on requestL03C-L03dAfter discoveryAfter discoveryAfter discovery
3(4)Above AED 375,000 (past or expected): bank account, recommendationsL04C-L04aAfter discoveryAfter discoveryAfter discovery
3(4)(a)Bank confirmation, authorised bank in the StateL04C-L04bAfter discoveryAfter discoveryAfter discovery
3(4)(b)Public reviews and media; no sign of tax evasionL04C-L04cAfter discoveryAfter discoveryAfter discovery
Decision 13, Art. 3. Cells marked 'after discovery' are completed in the engagement.
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Article-by-article coverage matrix: Articles 4, 5 and 6 (14 obligations)

ClauseRequirementCheckControlSpecification itemTestEvidence
4(1)(a)General assessment of the supply's conditionsL05C-L05aAfter discoveryAfter discoveryAfter discovery
4(1)(b)Genuine commercial reasonsL05C-L05aAfter discoveryAfter discoveryAfter discovery
4(2)(a)Payment terms; third party; foreign accountL05C-L05bAfter discoveryAfter discoveryAfter discovery
4(2)(b)Electronic payment; cash conditionsL06C-L06After discoveryAfter discoveryAfter discovery
4(3)(a)Price or margin against marketL07C-L07aAfter discoveryAfter discoveryAfter discovery
4(3)(b)Within ordinary and licensed activityL07C-L07bAfter discoveryAfter discoveryAfter discovery
4(3)(c)Origin and authenticity of goods; right to disposeL07C-L07cAfter discoveryAfter discoveryAfter discovery
4(3)(d)Intermediary: reason for its roleL07C-L07dAfter discoveryAfter discoveryAfter discovery
5(1)First dealing; again if not verified in 12 monthsL08C-L08aAfter discoveryAfter discoveryAfter discovery
5(2)Each taxable supply verifiedL08C-L08bAfter discoveryAfter discoveryAfter discovery
5(3)Document steps; retain recordsL08C-L08cAfter discoveryAfter discoveryAfter discovery
5(4)Written policy; persons in chargeL08C-L08dAfter discoveryAfter discoveryAfter discovery
6(1)Below AED 10,000 may be disregardedL09C-L09After discoveryAfter discoveryAfter discovery
6(2)Not if supplier total above AED 100,000 (past or expected)L09C-L09After discoveryAfter discoveryAfter discovery
Decision 13, Arts. 4, 5, 6. Cells marked 'after discovery' are completed in the engagement.
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Open interpretation points

PointArticleStatus
How supplier totals are counted across entities and company codes3(4), 6Agree with tax owner
What evidence of 'expected to exceed' over the next 12 months is enough3(4), 6(2)Agree with tax owner
Which legislation sets the cash thresholds4(2)(b)Identify the instrument
Retention period for records5(3)Confirm with tax owner
Overseas suppliers and imports1, 3(4)(a)Confirm treatment
Group and related suppliers3, 4Same checks; confirm
Meeting an individual supplier before the supply; supplies already made since 1 October3(1)(a)(2), 5(1)Agree with tax owner in discovery
Decisions are the taxable person's, with its tax adviser.
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Glossary

TermMeaning
Taxable personA person registered or required to register for VAT (Decision 13, Art. 1)
Input taxTax paid or due on goods and services supplied to the person, or on imports (Art. 1)
Release strategySAP approval procedure for purchase orders by value, type and group
GR/IRGoods receipt and invoice receipt clearing account
Three-way matchComparison of PO, goods receipt and invoice at invoice verification
GOS, ArchiveLinkSAP attachment service; interface to external document systems
MDG, SRM, Ariba, GRCMaster data governance; supplier relationship management; supplier network; governance, risk and compliance
Decision 13, Art. 1; verified SAP reference.
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Sources and basis

  • FTA Decision No. 13 of 2026, in force 1 October 2026. Unofficial English translation; the Arabic text in the Official Gazette controls
  • Federal Decree-Law No. 8 of 2017 on VAT and amendments, Art. 54(bis) (added by Federal Decree-Law No. 16 of 2025)
  • SAP ECC 6.0 procure-to-pay reference, verified by our SAP consultant
  • This deck is not legal advice; interpretation points are listed in Appendix A.3
Based on FTA Decision No. 13 of 2026 (in force 1 October 2026); VAT Decree-Law No. 8 of 2017 as amended.
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Standard transactions and tables used in Section 3, by stage

StageTransactionsMain tables
Vendor and onboardingXK01, XK02, ME11LFA1, LFB1, LFM1, LFBK, WYT3, EINA, EINE; GOS: SRGBTBREL, SOOD, SOFFCONT1; ArchiveLink: TOA01 to TOA03
Contract, requisition, sourcingME31K, ME51N, ME54N, ME41, ME47, ME49EKKO, EKPO, EKAB, EBAN, EBKN, KONV
Purchase orderME21N, ME22N, ME9FEKKO, EKPO, EKKN, EKET, EKPA, EKES, T16FG to T16FW, CDHDR, CDPOS, NAST
Receipt and qualityMIGO (101), QE51N, QA32, QA11MKPF, MSEG, MARD, MBEW, EKBE, QALS, QAMR, QAVE
Invoice and taxMIR7, MIRO, MRBR, MR11, MR8MRBKP, RSEG, BKPF, BSEG, BSET, T169G, T169P
PaymentF110, F-53, F-58, FBZP, FBL1NREGUH, REGUP, REGUA, PAYR, T012, T042
Period-end, closure, archivingF.13, F.19, MEMASSPO, ME32K, SARAELIKZ, EREKZ, LOEKZ; MM_EKKO, MM_MATBEL, MM_REBEL, FI_DOCUMNT
Source: verified SAP ECC 6.0 procure-to-pay reference. Your configuration is learned in discovery.
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