How to Comply with Electronic Invoicing in Guatemala and the FEL System

Electronic invoicing in Guatemala operates under the Online Electronic Invoicing System (FEL), regulated by the Superintendence of Tax Administration (SAT). This system requires the issuance of Electronic Tax Documents (DTE), which must be generated, signed, and validated electronically. Its implementation aims to modernize tax management, streamline accounting processes, and ensure greater transparency in commercial transactions.

From FACE to FEL: The Evolution of Electronic Invoicing in Guatemala

Electronic invoicing in Guatemala has evolved over time, transitioning from the FACE system, implemented in 2011, to the Online Electronic Invoicing System (FEL). This change was established by SAT Board Agreement No. 13-2018 and its amendments, with the goal of making the issuance of electronic tax documents more efficient. Since 2019, the transition to FEL has been gradual, combining mandatory phases and voluntary adoption until its full implementation on July 1, 2023.

The FEL System introduces key changes compared to the FACE system:

• Elimination of invoice copies: Sending information to GFACE is no longer required.
• Mandatory electronic signature: Ensures the authenticity and integrity of Electronic Tax Documents (DTE).
• Centralized storage: SAT stores all electronic invoices, although issuers and recipients must also keep the XML file for the period specified in the Tax Code. Certifiers are also required to store certified DTEs and SAT acknowledgment receipts.

FEL System in Guatemala: Issuance, Certification, and Validation of Electronic Invoices

The Online Electronic Invoicing System (FEL) regulates the issuance, transmission, certification, and storage of Electronic Tax Documents (DTE), including invoices, credit and debit notes, receipts, and other authorized tax documents.

In this system, each DTE must be validated by a certifying entity—an independent third party authorized by the Superintendence of Tax Administration (SAT)—which ensures compliance with regulations and applies an advanced electronic signature. Certifying entities must obtain and renew their authorization annually to operate.

How is the electronic invoicing process carried out in Guatemala?

• DTE Generation: The issuing company extracts data from its ERP system and creates an XML file containing the transaction details.
• Validation and Certification: The certifying entity verifies that the document complies with FEL System regulations, applies an advanced electronic signature, and assigns an electronic authorization code.
• Submission to SAT: Once certified, the DTE is sent to SAT, which performs its own validations to ensure authenticity, integrity, and regulatory compliance.
• Acknowledgment of Receipt: SAT issues an acknowledgment to the certifier, indicating whether the document has been accepted or rejected.
• Delivery to the Recipient: The DTE is sent to the recipient in XML format, along with its graphical representation or PDF version.
• DTE Storage: Both issuers and recipients must store XML files for the period specified in the Tax Code. Certifying entities must also safeguard certified DTEs and SAT acknowledgment receipts.

Who is required to issue electronic invoices under the FEL System?

The Online Electronic Invoicing System (FEL) is mandatory for taxpayers designated by the Superintendence of Tax Administration (SAT). Designation is based on criteria such as the volume of issued invoices, gross billed income, economic affiliation, enrollment in special tax regimes, or other conditions established by the tax authority. Currently, the following taxpayers are required to issue Electronic Tax Documents (DTE) through the FEL System:

• Special taxpayers
• Large regional taxpayers
• Government suppliers, as per SAT Resolution 243-2019, in cases of bidding, quotations, open contracts, and reverse electronic auctions.
• Government suppliers, according to SAT Resolution 838-2019, when providing individual professional services.
• Taxpayers previously using the FACE electronic invoicing system, who were required to migrate to the FEL System.

Additionally, SAT continues to expand the scope of electronic invoicing in Guatemala, making it essential for taxpayers to regularly review current resolutions and ensure compliance with applicable regulations.

Types of Electronic Tax Documents (DTE) in Guatemala

Electronic Tax Documents (DTE) are digital tax receipts that support commercial transactions and ensure compliance with tax obligations under the Online Electronic Invoicing System (FEL). Each DTE must be electronically generated, certified, and validated before being submitted to the Superintendence of Tax Administration (SAT).

The FEL System includes various types of DTE, depending on the nature of the transaction:

• Invoice: The primary document for the sale of goods and services.
• Exchange Invoice: Similar to an invoice but with the legal effect of a negotiable instrument.
• Small Taxpayer Exchange Invoice: A version of the exchange invoice for small taxpayers.
• Small Taxpayer Invoice: Issued by those registered under the small taxpayer regime.
• Special Invoice: Used for purchases from suppliers who are not required to issue invoices.
• Credit Note: Records refunds or discounts applied to previous invoices.
• Debit Note: Adjusts amounts on previously issued invoices by increasing the amount owed.
• Credit Note: Corrects or cancels an invoice, either partially or entirely.
• Receipt: A payment acknowledgment for specific transactions.
• Donation Receipt: Certifies the delivery of donations.

Each of these documents must meet SAT’s requirements and processes for proper issuance and certification within the FEL System. Implementing DTEs not only improves tax management but also streamlines the handling of tax documents for businesses and taxpayers.

Requirements for Issuing Electronic Invoices in Guatemala

To operate within the Online Electronic Invoicing System (FEL) and issue Electronic Tax Documents (DTE) in Guatemala, taxpayers must meet a series of requirements established by the Superintendence of Tax Administration (SAT). These criteria ensure that electronic invoice issuers comply with current tax and technical regulations.

Taxpayers who wish to issue electronic invoices must meet the following conditions:

• Be registered for Value-Added Tax (VAT).
• Operate an active business registered with SAT.
• Have an active Virtual Agency account, the platform used to manage electronic tax procedures.
• Keep updated information in the Unified Tax Registry (RTU).
• Maintain a registered tax address with SAT.
• Obtain authorization as an issuer within the FEL System.
• Comply with the technical standards and requirements for issuing DTEs.
• Possess an electronic signature to validate the authenticity of documents.
• Be up to date with tax filings and payments.
• Hire an SAT-authorized certifying entity responsible for validating and certifying DTEs before sending them to the tax authority.

Obtaining authorization within the FEL System is essential to ensure the legality and validity of electronic invoices in Guatemala. Meeting these requirements allows taxpayers to operate within the system, streamlining their invoicing processes and facilitating compliance with tax obligations.

Add-ons in FEL Electronic Invoicing

Add-ons in electronic invoices are additional data incorporated into Electronic Tax Documents (DTE) to provide specific information about certain transactions. The Superintendence of Tax Administration (SAT) has introduced key changes to the export add-on and launched the Provisional Invoice (FACP), directly impacting exporters in Guatemala.

Changes to the Export Add-on

SAT has implemented changes to the export add-on, applicable to all exporters, regardless of whether they issue a provisional invoice. These modifications include two new conditional fields (LugarExpedición and PaísConsignatario) that must be included in Electronic Tax Documents (DTE). Additionally, for exporters required to issue a provisional invoice, four extra fields have been added: Número de Autorización Provisional (Provisional Authorization Number), Serie del Documento de Origen (Origin Document Series), Número del Documento de Origen (Origin Document Number), and Número de Declaración de Mercancías (Goods Declaration Number). These updates aim to enhance the traceability of foreign trade operations and strengthen tax control within the country.

Provisional Invoice Add-on (FACP)

The Provisional Invoice (FACP) is a document used by exporters to support transactions when the final export has not yet been completed. It allows for the formal registration of operations while the corresponding procedures are finalized. This is particularly relevant for industries that require swift shipments, such as perishable goods, where fast document processing is essential for international trade. While the FACP streamlines the export process, it does not replace the Export Invoice, which must be issued once the goods have been received by the foreign recipient, ensuring compliance with current tax and customs regulations.

EDICOM's Global Electronic Invoicing Platform

EDICOM is an international leader in electronic invoicing and tax compliance solutions, offering a global platform that enables companies to automate the issuance and receipt of Electronic Tax Documents (DTE) in accordance with each country’s regulations. In Guatemala, EDICOM’s solution facilitates the generation, certification, and submission of DTEs within the Online Electronic Invoicing System (FEL), ensuring compliance with the requirements established by the Superintendence of Tax Administration (SAT).

With advanced technology, EDICOM’s platform helps companies optimize their administrative processes by automating workflows, reducing manual errors, and ensuring seamless integration with ERP systems. It also offers secure electronic storage services, making it easy to preserve and retrieve DTEs within the legal timeframes mandated by Guatemalan regulations.

As a specialist in electronic invoicing, EDICOM provides a scalable solution adaptable to the tax regulations of multiple countries, allowing companies to operate efficiently and securely in international markets while ensuring traceability and compliance with their tax operations.