
Transitional mechanism for omitted e-invoicing: window to regularize without full penalty
DIAN enabled a transitional procedure to issue omitted e-invoices for prior periods. Conditions, deadlines, and effects on VAT, income tax, and exogenous reporting.
What is enabled
DIAN enabled a transitional mechanism for taxpayers who failed to issue e-invoices in prior periods to regularize within a defined window, accessing a more favorable penalty regime than the ordinary one.
Why it matters
Failure to issue e-invoices has cascading effects: rejection of costs and deductions for income tax, denial of input VAT for the buyer, inconsistencies in exogenous reporting, and standalone penalties. The transitional mechanism allows closing the risk at significantly lower cost.
T&C reading
We recommend (i) auditing invoicing traceability for the last three years, (ii) identifying unbilled operations or POS-issued invoices not migrated to electronic, (iii) evaluating regularization under the transitional mechanism before the deadline, and (iv) coordinating with clients on document replacement so they can recover input VAT and costs.
Official source
Administrative acts and technical guides published by DIAN in the Normograma.