Dubai Customs can audit declarations for five years after clearance. Under Customs Policy No. 58/2024, an importer that discloses its own errors before an audit notice pays the duty difference and may have fines reduced or waived. The duty must be paid within 30 days of the claim, or the disclosure lapses.
How far back can Dubai Customs audit?
Five years after clearance, and importers must keep records for that period (Kayrouz & Associates). The FTA can also look back five years on related VAT under the 2026 Tax Procedures changes (UAE Ministry of Finance).
What can be disclosed?
Undervaluation, wrong HS codes, invalid origin claims and unaccounted goods under suspension regimes (Kayrouz & Associates).
What are the conditions?
The disclosure must come before an audit notice and the duty must be paid within 30 days of the claim (Kayrouz & Associates).
Why check customs and VAT together?
Import VAT is calculated on the customs value, so a customs correction often changes VAT too. Fix both in one exercise.
Worked example: an undervalued shipment
An importer finds that a year of shipments was declared without freight costs, understating customs value by AED 400,000. At a 5% duty rate the duty shortfall is AED 20,000, and import VAT on the corrected value adds roughly another AED 21,000, usually recoverable if the importer is VAT registered. Disclosing before an audit notice means paying the AED 20,000 duty within 30 days, with fines potentially reduced or waived (Kayrouz & Associates).
Preparing the disclosure file
- List of affected declarations with dates and numbers.
- Commercial invoices, freight and insurance documents.
- The corrected values and the duty calculation.
- An explanation of the cause and the control now in place.
Our view
If you find a pattern of errors, disclose the whole pattern, not just the shipment you noticed. Partial disclosures invite the audit you were trying to avoid.
Frequently asked questions
Can I disclose after an audit notice?
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Not for the matters already under review.
Does disclosure remove all fines?
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Fines may be waived in full or in part.
Do free zone companies need to keep customs records?
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Yes, until the company is closed.
Does a customs disclosure also fix VAT?
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Import VAT must be corrected too; plan both together.
Sources
- Dubai Customs post-clearance audits and voluntary disclosure rules (Customs Policy No. 58/2024) — Kayrouz & Associates. Checked 17 October 2026.
- Ministry of Finance to implement amendments to the Tax Procedures Law starting early 2026 (Federal Decree-Law No. 17 of 2025) — UAE Ministry of Finance, 29 November 2025. Checked 16 October 2026.