Establish what is outstanding
Start with the actual account position. Was no application submitted, was an application returned for information, or was registration completed but a later obligation missed? Keep the distinction clear because the next action differs.
Retrieve the relevant licence, incorporation documents, first financial statements and FTA correspondence. Prepare a timeline showing the applicable registration date, submissions and any outstanding request. Do not backdate information or change the financial year merely to make the account look timely.
Complete registration and reporting work together
If registration remains outstanding, prepare an accurate application and allocate responsibility for follow-up. At the same time, identify the first tax period and the work needed for its return. Registering late should not lead to a second avoidable delay in preparing the underlying accounts.
Reconcile the trial balance, review transactions needing tax adjustments and gather supporting records. Where the records are incomplete, show what is missing and how it will be resolved rather than submitting unsupported figures.
Review the current penalty-waiver conditions
The FTA's published late-registration waiver initiative requires a taxable person to submit the first return within seven months of the end of the first tax period. For relevant exempt persons, the published condition concerns the annual declaration within seven months of the first financial year end.
This is a conditional initiative, not a general statement that late registration has no consequences. Check the current FTA wording and the person's account before deciding whether a waiver applies. Do not confuse submitting financial statements with filing the required return or declaration.
Keep an evidence file
- The registration assessment and relevant dates.
- Application references and correspondence.
- The first-period accounts and tax computation.
- Return or declaration submission evidence.
- Account statements, penalty entries and follow-up actions.
If the result appears inconsistent with the evidence, use the relevant FTA procedure and applicable time limit. Advice should distinguish account enquiries, waiver eligibility and any separate review or dispute route.
Prevent the problem from recurring
Create a compliance calendar with a preparation owner and reviewer. Maintain a monitored contact address and a process for changes to the licence, ownership, signatory or reporting period. Review completion evidence, not just reminders marked as done.
Sources and further reading
Official references checked during the 24 October 2026 refresh. Application details and requirements can change; use the current source for the relevant entity and period.
