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Dominican Republic

Briefing Document & Podcast: E-Invoicing and E-Reporting in Dominican Republic

4 weeks ago
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SUMMARY

1. Executive Summary:

The Dominican Republic is implementing a mandatory electronic invoicing system (“Comprobante Fiscal Electrónico” or e-CF) across all taxable transactions nationwide. Governed by Law No. 32-23 (Electronic Invoicing Law, effective May 16, 2023) and its regulations (Decree 587-24), this initiative is a phased rollout aimed at modernizing the tax system and improving compliance. The mandate applies to domestic and cross-border transactions involving entities operating within the Dominican Republic. The system uses an XML format for e-invoices, requires digital signatures, and involves real-time reporting to the tax authority (DGII) at the moment of invoice issuance. While taxpayers still must file VAT returns, the system allows the DGII to verify returns and possibly in the future facilitate VAT compliance. Failure to comply results in monetary fines and the inability to issue valid tax invoices.

2. Background and Timeline:

  • Pilot Program: A voluntary pilot program began in 2019 with select large companies.
  • Law Enactment: The Electronic Invoicing Law 32-23 was passed and published on May 17, 2023, and became effective on May 18, 2023. This law mandates e-invoicing for all sales of goods and services.
  • Phased Rollout: The mandate is being implemented in three phases:
  • Phase 1 (2024): Large Taxpayers (“Grandes Contribuyentes Nacionales”). Deadlines were January 15, March 15, and May 15, 2024. “By May 15, 2024 (12 months from the law’s effect), all National Large Taxpayers were required to have fully implemented e-CF invoicing.”
  • Phase 2 (2025): Medium and Large Local Taxpayers. The original deadline of May 15, 2025, was extended to November 15, 2025, via Notice 12-25, but only for companies that had already begun the e-invoicing onboarding process by the original date. After this date, full enforcement applies.
  • Phase 3 (2026): Small and Micro Businesses, Unclassified Taxpayers, and remaining public-sector entities. Deadline is May 15, 2026. The DGII has confirmed that May 15, 2026 is the ultimate deadline for all remaining businesses.

3. Scope of Transactions:

The e-invoicing mandate is comprehensive:

  • Domestic Sales: All B2B and B2C sales within the Dominican Republic must be invoiced electronically. Different e-CF types are used depending on the type of transaction (e.g., “Electronic Tax Credit Invoice” for B2B, “Electronic Consumer Invoice” for retail).
  • Cross-Border Transactions: “Exports from the Dominican Republic are covered by the mandate – exporters must issue an Electronic Export Receipt for goods/services sold abroad.” Payments from foreign clients can be documented with an “Electronic Receipt for Foreign Payments.” Imports are not directly issued as e-CFs by the foreign seller but handled through customs documentation. The scope is essentially all in-country taxable transactions.

4. Taxpayers in Scope:

  • All persons or entities “operating in the country” are subject to the mandate, including individual entrepreneurs, companies of all sizes, public sector bodies, and entities without separate legal personality, if domiciled in the Dominican Republic. “In effect, any taxpayer registered in the National Taxpayers Registry (RNC) that issues invoices must transition to e-CF.”
  • Local subsidiaries or branches of foreign companies operating in the DR are treated as local taxpayers.
  • Non-established businesses (with no tax registration or permanent establishment in the DR) are not directly obligated.

5. E-Invoice Format and Data Requirements:

  • XML Structure: Invoices must be transmitted as XML files using a standardized schema defined by the DGII.
  • Unique Invoice Identifier (e-NCF): Each e-invoice must include an electronic fiscal number (e-NCF) issued by the DGII. “When an invoice is generated, it carries a unique e-NCF code that identifies it for tax purposes. This ensures authenticity and uniqueness of each invoice within the national system.”
  • Digital Signature: Every e-CF must be digitally signed using a valid certificate from an INDOTEL-authorized certification authority. “The digital signature guarantees the integrity of the invoice and the identity of the issuer.”
  • DGII Validation Data (Track ID): The DGII validates the invoice upon submission and generates a unique “TrackID” or acknowledgment code.
  • Required Content: The e-CF must mirror all content of a traditional invoice (RNC, buyer information, date/time, description of goods/services, gross amounts, ITBIS, etc.) plus any additional fields required for electronic tracking.

6. Transmission Process (E-Invoicing & “E-Reporting”):

  • Real-Time Submission: “At the moment of invoice issuance, a digital copy must be sent to the DGII. The law explicitly requires that electronic invoices be sent to the tax authority and the customer at the same time.” There is no lengthy lag permitted – the data is effectively reported in real time. This fulfills the “e-reporting” function.
  • Transmission Channels: Taxpayers can send invoices to DGII through web services/APIs. The DGII provides a platform, and it also certifies third-party Service Providers (PSFEs).
  • Validation and Response: The DGII system validates the invoice, and if valid, registers it and returns a confirmation with the assigned TrackID. “Notably, because this is a post-clearance model, the DGII’s validation happens essentially in parallel; there’s no need to wait for an approval code before delivering the invoice to the buyer.”
  • Reporting Timeline: Invoice reporting is instantaneous with issuance. Only in exceptional cases (system outages or contingencies) would delays be acceptable.

7. Grace Periods and Transitional Measures:

  • Voluntary Adoption & Incentives: Tax incentives were offered for early adopters. The DGII also provided free invoicing software.
  • Extension (Grace Period for Phase 2): A 6-month grace extension was granted for large-local and medium taxpayers in 2025, formalized by Notice 12-25, if they initiated compliance steps by the original deadline.
  • No Further General Extensions Announced: As of late 2025, no further extensions were announced for the Phase 3 deadline in 2026.

8. Penalties for Non-Compliance:

  • Monetary Fines: “The law prescribes fines (financial penalties) for not implementing e-CF on time…often tied to multiples of the official minimum wage.”
  • Business Consequences: “After the mandated dates, paper or non-electronic invoices are not recognized for tax purposes…companies who do not adopt the electronic system on time “will not be able to facturar” – meaning they legally cannot issue fiscal receipts.”

9. Invoice Format & Transmission Details:

  • Standard Format (XML + PDF): The invoice must be generated in the XML e-CF format and submitted electronically. A human-readable “Printed Representation” (PDF or printed copy) can be generated for customers who are not using electronic means.
  • Transmission Protocol: Communication with DGII’s system is via web service endpoints (REST APIs).
  • Service Providers: Certified Electronic Invoicing Service Providers can handle the integration.

10. Data to Be Reported (Content of E-Invoicing/E-Reporting):

Includes all details for VAT administration: identification of seller and buyer, invoice date and number, line-item details, taxable amounts and tax breakdown, totals, and references if it’s an adjustment. “Because the e-reporting is inherent to the e-invoice, there is no additional separate dataset to send – the invoice itself is the data report.”

11. Archiving and Retention Requirements:

  • Retention Period: “10 years from the date of issuance is the minimum retention period.”
  • Format and Integrity: Invoices must be kept in their original electronic format (XML) with their digital signatures intact.

12. Pre-Filled VAT Returns (VAT Declaration Integration):

  • Current Situation: Businesses still prepare and submit their own VAT returns. “There is no system of automatically pre-populated tax returns by the DGII at this time.”
  • Future Outlook: While not currently implemented, the comprehensive e-invoicing data greatly enhances the DGII’s ability to cross-check and eventually could enable pre-filled returns.

13. Key Official Resources:

  • Law 32-23 (Ley de Facturación Electrónica)
  • Decree 587-24 (implementing regulations)
  • DGII Notices and General Norms (available on the DGII’s official website)

INDEPTH ANALYSIS

E-Invoicing Mandate & Timeline (Dominican Republic) – The Dominican Republic’s e-invoicing mandate is governed by Law No. 32-23 (Electronic Invoicing Law, effective May 16, 2023) and its regulations (Decree 587-24). It introduces a phased rollout of mandatory electronic invoicing (“Comprobante Fiscal Electrónico” or e-CF) for all taxable transactions nationwide. Key dates and phases include: [edicomgroup.com], [complyance.io]

  • Pilot & Law Enactment: A voluntary pilot started in 2019 with select large companies. The Electronic Invoicing Law 32-23 was passed and published on May 17, 2023, coming into effect on May 18, 2023. This law makes e-invoicing the required method for documenting all sales of goods and services in the country, as part of a tax modernization effort. [sovos.com] [complyance.io]
  • Phase 1 – Large Taxpayers (2024): The first mandatory wave targets the largest businesses (“Grandes Contribuyentes Nacionales”). These were divided into groups with deadlines of January 15, 2024, March 15, 2024, and May 15, 2024. By May 15, 2024 (12 months from the law’s effect), all National Large Taxpayers were required to have fully implemented e-CF invoicing. (Government entities classified as large taxpayers also fell in this phase.) [sovos.com]
  • Phase 2 – Medium & Local Large Taxpayers (2025): The next group includes “Large Local” taxpayers and medium-sized companies. The original deadline was May 15, 2025 (24 months from law effect). However, the tax authority (DGII) granted a 6-month grace extension via Notice 12-25: the new deadline for these taxpayers became November 15, 2025, but only for companies that had already begun the e-invoicing onboarding process by the original date. (Those who failed to start implementation by May 15, 2025 were not eligible for the extension.) This extension effectively served as a grace period to allow more time, with no penalties until the new November deadline. After Nov 15, 2025, large-local and medium taxpayers are fully subject to enforcement of the mandate. [sovos.com] [edicomgroup.com], [vatupdate.com] [vatupdate.com] [kpmg.com]
  • Phase 3 – Small & Micro Businesses (2026): The final phase covers micro, small, and unclassified taxpayers, as well as any remaining public-sector entities. They must adopt e-invoicing by May 15, 2026 (36 months from the law’s effect). The DGII has confirmed that May 15, 2026 is the ultimate deadline for all remaining businesses (including small firms and sole proprietors) to comply. As of late 2025, authorities were emphasizing this timeline and urging smaller taxpayers to prepare in time. Any further extensions for this group had not been announced as of the most recent updates. [morillosur…ogados.com], [sovos.com] [kpmg.com] [hoy.com.do], [hoy.com.do]
Scope of Transactions – Domestic and Cross-Border:
The e-invoicing mandate in the DR is comprehensive in scope. It applies to all transactions that require a fiscal invoice, across B2B, B2C, and B2G contexts. In practice, this means: [complyance.io], [complyance.io]
  • Domestic Sales: All sales of goods or services within the Dominican Republic, whether business-to-business or business-to-consumer, must be invoiced electronically (using an appropriate e-CF type). For example, standard B2B sales use an Electronic Tax Credit Invoice (for VAT credit purposes), while retail sales use an Electronic Consumer Invoice. Government procurement also requires electronic invoices (e.g. an Electronic Government Receipt for B2G transactions). [edicomgroup.com], [edicomgroup.com]
  • Cross-Border Transactions: The system accommodates exports and certain import-related documents through special e-CF types. Exports from the Dominican Republic are covered by the mandate – exporters must issue an Electronic Export Receipt for goods/services sold abroad. Likewise, payments from foreign clients can be documented with an Electronic Receipt for Foreign Payments. These electronic documents ensure that even zero-rated or outbound transactions are reported to DGII. Imports (purchases from foreign suppliers) are not directly issued as e-CFs by the foreign seller, so they fall outside the e-invoicing issuance mandate. Instead, imports continue to be handled via customs documentation and the existing tax credit reporting mechanisms. (In other words, non-established foreign suppliers without a Dominican tax registration are not required to issue Dominican e-invoices, but the local importer still must comply with normal import VAT procedures.) The e-invoicing law’s scope is essentially all in-country taxable transactions; it covers invoices issued by persons domiciled or registered in the DR for any transfer of goods, provision or lease of services, whether for consideration or free of charge. [edicomgroup.com] [sovos.com], [sovos.com]
Taxpayers in Scope (Established vs. Non-Established):
All persons or entities “operating in the country” are subject to the mandate, including: individual entrepreneurs, companies of all sizes, public sector bodies, and even entities without separate legal personality (e.g. partnerships, joint ventures, trusts) domiciled in the Dominican Republic. In effect, any taxpayer registered in the National Taxpayers Registry (RNC) that issues invoices must transition to e-CF. This includes local subsidiaries or branches of foreign companies operating in the DR – they are treated as local taxpayers and must comply just like domestic companies. By contrast, non-established businesses (with no tax registration or permanent establishment in the DR) are not directly obligated, since they generally cannot issue local fiscal receipts. The mandate does not extend to, for example, a foreign company simply selling into the DR from abroad without local registration. In summary, if a business is required to issue a Dominican fiscal invoice today, that requirement shifts to an electronic format under Law 32-23 – covering all resident taxpayers (both private sector and government), large or small. [sovos.com] [morillosur…ogados.com] [sovos.com], [complyance.io]
E-Invoice Format and Data Requirements: The standard electronic invoice in the DR is known as an e-CF (Electronic Tax Receipt), which must be issued in a specific XML format defined by the DGII. The technical specifications are established by DGII through the e-invoicing regulation (Decree 587-24) and associated norms. Key data and technical elements include: [sovos.com], [sovos.com]
  • XML Structure: Invoices are transmitted as XML files using a standardized schema. This structured format contains all the required invoice details (seller and buyer information, item descriptions, quantities, values, taxes, etc.) annotated with prescribed XML tags. The format aligns with international norms (the content requirements mirror a full VAT invoice) but is customized to DGII’s system. [sovos.com], [sovos.com]
  • Unique Invoice Identifier (e-NCF): Each e-invoice must include an electronic fiscal number (called e-NCF or electronic Comprobante Fiscal Number). The DGII issues ranges of these codes to each taxpayer (similar to the pre-printed NCF numbers in the old system). When an invoice is generated, it carries a unique e-NCF code that identifies it for tax purposes. This ensures authenticity and uniqueness of each invoice within the national system. [edicomgroup.com]
  • Digital Signature: Every e-CF must be digitally signed using a valid certificate. The certificate must be issued by a certification authority authorized by INDOTEL (the Dominican telecom regulator) for tax use. The digital signature guarantees the integrity of the invoice and the identity of the issuer. (Law 32-23 builds on the earlier e-signature law 126-02 to give e-invoices full legal equivalence to paper invoices.) [sovos.com], [complyance.io] [dgii.gov.do]
  • DGII Validation Data (Track ID): Upon submission, the DGII’s system validates the invoice and generates a unique “TrackID” or acknowledgment code for the document. This track ID, along with the e-NCF, is part of the electronic evidence that the invoice was received by the tax authority. In practice, an e-invoice file will contain or be associated with metadata like the TrackID and a timestamp of when DGII registered it. [complyance.io]
  • Required Content: The e-CF must effectively mirror all content of a traditional invoice plus any additional fields required for electronic tracking. This includes: the issuer’s RNC (tax ID), the buyer’s identification (RNC or cedula, if applicable), date/time of issuance, a description of goods/services, gross amounts, the ITBIS (VAT) amount or an indication if the transaction is exempt, and any other taxes or withholdings. It must also indicate the type of e-CF (e.g. whether it’s a credit note, consumer invoice, etc.). The DGII has predefined multiple e-CF document types to cover various scenarios, such as invoices, credit/debit notes, special purpose receipts, export receipts, etc., and the data structure may include fields specific to those uses. All this information is embedded in the XML and must meet DGII’s format rules so that the authority can parse and understand the data. [edicomgroup.com], [edicomgroup.com]
Transmission Process (E-Invoicing & “E-Reporting”): The Dominican Republic uses a clearance-style system with real-time electronic reporting of invoices to the tax authority. In practice, issuing an e-CF involves immediate submission to DGII for validation. This can be summarized as a “post-clearance” model: the supplier issues the invoice to the buyer and simultaneously submits it to DGII via electronic means. Key points about the transmission and timing: [orbitax.com], [sapeinvoice.com]
  • Real-Time Submission: At the moment of invoice issuance, a digital copy must be sent to the DGII. The law explicitly requires that electronic invoices be sent to the tax authority and the customer at the same time. There is no lengthy lag permitted – the data is effectively reported in real time (or near-real-time). This fulfills the “e-reporting” function automatically: each e-invoice transmitted doubles as a transaction report to the tax authority. There is no separate periodic invoice listing to submit, since every invoice is already in the DGII’s system upon issuance. [orbitax.com], [sapeinvoice.com] [complyance.io]
  • Transmission Channels: Taxpayers can send invoices to DGII through web services and APIs. The DGII provides a platform (and even a free invoicing web portal for small businesses), and it also certifies third-party Service Providers (PSFEs) that offer software integration. Larger companies typically integrate their ERP or billing systems with DGII’s APIs (REST/XML web services) to automatically transmit each invoice in XML format. Smaller businesses may use the DGII’s free online tool or authorized software to issue invoices one by one, which in the back-end still transmits the data to DGII. [sovos.com], [sovos.com]
  • Validation and Response: Upon receiving the invoice data, the DGII system performs validations (ensuring the XML is well-formed, the e-NCF number is in the range assigned to that taxpayer, the digital signature is valid, required fields are present, etc.). If valid, the DGII registers the invoice and typically returns a confirmation with the assigned TrackID. The invoice is then considered fiscally valid. The supplier can then provide the buyer with the invoice (electronically, e.g. via email, or even as a printed copy of a “representation” if the buyer isn’t on electronic reception). Notably, because this is a post-clearance model, the DGII’s validation happens essentially in parallel; there’s no need to wait for an approval code before delivering the invoice to the buyer, unlike some pre-clearance systems. However, since all invoices are reported immediately, the tax authority still gets “real-time” oversight. [complyance.io]
  • Reporting Timeline: Effectively, the due date to send invoice data is at the time of issuance. The expectation is that when you issue an invoice, you concurrently send it to DGII. There isn’t a separate grace period of X days after issuance for normal operation. In other words, invoice reporting is instantaneous with issuance – the same XML message is used to invoice the customer and to report to the tax authority. Only in exceptional cases (system outages or contingencies) would delays be acceptable. The e-invoicing regulation does include contingency mechanisms (e.g. if the DGII system or the taxpayer’s internet is down). In such cases, a business might be allowed to issue invoices in offline mode and transmit them as soon as possible once connectivity is restored. The specific grace period in contingency situations is defined by DGII’s rules (for instance, an invoice issued under contingency must be reported within 24 hours or a few days). But under normal conditions, no deferred reporting is allowed beyond the point of issuance. [orbitax.com] [edicomgroup.com]
  • “E-Reporting” for non-invoice data: Since all invoices, including export invoices, are covered as e-CFs, the Dominican Republic’s approach essentially merges e-invoicing and e-reporting into one process. Taxpayers do not have to send separate VAT summary reports for issued invoices – the DGII already has each invoice. (However, taxpayers must still file periodic tax returns – see below on VAT returns.) One area of “electronic reporting” to mention is that the DGII historically required buyers to submit purchase listings (Form 606) and other information returns. It is expected that with e-CF, such requirements may be simplified in the future, as DGII obtains both sides of each transaction in real time. As of the latest policies, no additional transactional report (“e-report”) is required aside from the e-CF itself – the XML invoice file serves as both the invoice and the immediate report to the authorities. [complyance.io]
Grace Periods and Transitional Measures: The Dominican Republic facilitated the transition with both voluntary adoption periods and deadline extensions as needed:
  • Voluntary Adoption & Incentives: During the rollout, taxpayers were encouraged to switch to e-invoicing before their mandatory date. Law 32-23 and its regulation include tax incentives for early adopters and made free tools available. From mid-2023 through 2024, many companies enrolled in the system voluntarily. This “soft launch” period allowed both the DGII and taxpayers to iron out technical issues. The DGII also provided a free invoicing software platform for those who didn’t have their own system, lowering the barrier to entry. [edicomgroup.com] [sapeinvoice.com]
  • Extension (Grace Period for Phase 2): As noted, the DGII gave a one-time 6-month grace extension in 2025 for large-local and medium taxpayers. Originally due by May 15, 2025, these taxpayers had until Nov 15, 2025 if they had initiated compliance steps. This was formalized by Notice 12-25. The extension was automatic upon application, effectively allowing more time without penalties. Companies that failed to even start the onboarding by the original date did not receive this grace and were technically in violation after May 15, 2025. The extension reflected the DGII’s acknowledgment of implementation challenges, helping to ensure a smoother uptake. [edicomgroup.com] [kpmg.com] [vatupdate.com]
  • No Further General Extensions Announced: For the final phase (small taxpayers) due in 2026, as of the latest information there is no indication of another formal extension. The DGII in late 2025 was actively reminding small and micro businesses of the approaching May 2026 deadline. That said, enforcement for this last group might still involve some flexibility in practice (to be seen in 2026). The law’s timeline of 36 months is written into the legislation, so any change would require official action. Businesses are expected to use the remaining lead time as a de facto grace period to get ready. [hoy.com.do] [morillosur…ogados.com]
  • What “Grace Period” Means: In summary, yes, a grace period was applied in the form of deadline extensions for certain groups. A grace period in this context means that the tax authority postponed the enforcement of mandatory e-invoicing, giving taxpayers extra time to comply without incurring penalties. For example, large/medium companies got an extra six months in 2025. It’s essentially a buffer period after the original requirement date, during which non-compliance is tolerated to a degree. Outside of such official extensions, companies that miss their phase deadline are considered non-compliant (see Penalties below). There is no indefinite grace – once the final dates pass, e-invoicing becomes fully obligatory. [edicomgroup.com]
Penalties for Non-Compliance: Failing to comply with the e-invoicing mandate by the required date can lead to sanctions, as per the Tax Code and the provisions of Law 32-23:
  • Monetary Fines: The law prescribes fines (financial penalties) for not implementing e-CF on time. According to the DGII, these fines are specified in the legislation and are often tied to multiples of the official minimum wage. (For instance, a certain number of salarios mínimos as a fine for each infraction or per month of delay – the exact amounts are detailed in the law’s sanction provisions.) These “multas pecuniarias” serve as a deterrent for continued non-compliance. [hoy.com.do]
  • Business Consequences: Beyond fines, the practical consequence of non-compliance is that a business will not be able to issue valid invoices. After the mandated dates, paper or non-electronic invoices are not recognized for tax purposes. The DGII has warned that companies who do not adopt the electronic system on time “will not be able to facturar” – meaning they legally cannot issue fiscal receipts. In a December 2025 statement, the DGII’s Director cautioned that once the deadlines have passed, any supplier not using e-CF cannot issue compliant invoices (NCFs), effectively barring them from conducting formal business. Moreover, government agencies will refuse transactions with suppliers who aren’t using e-invoices. This loss of ability to invoice can be even more damaging than a fine, since it halts normal operations with compliant customers. [hoy.com.do], [hoy.com.do] [hoy.com.do]
  • Legal Basis: All sanctions are grounded in Law 32-23 and the existing Tax Code (Law 11-92). Non-compliance with invoicing regulations is treated as a tax offense similar to failing to issue invoices or keeping improper records under prior law. After the grace periods, the DGII is empowered to enforce penalties immediately. For instance, after November 15, 2025, any large/medium taxpayer still not e-invoicing would be subject to penalties under Law 32-23 and could face fines as indicated in that law. Ultimately, persistent failure might lead to further actions (such as suspension of tax certificates or other enforcement measures), but primarily the focus is on fines and disallowance of non-e-invoiced transactions. [kpmg.com]
It’s worth noting that early reports of extremely harsh penalties (like imprisonment for informality) were misinterpretations – the law does not jail someone for not e-invoicing; it uses financial penalties and administrative sanctions. The DGII’s emphasis has been on cooperation and phased enforcement, but the expectation is clear: businesses must comply by their deadline or risk punitive measures.
Invoice Format & Transmission Details: (To ensure thoroughness, summarizing technical compliance requirements)
  • Standard Format (XML + PDF): The invoice must be generated in the XML e-CF format and submitted electronically. Additionally, a human-readable “Printed Representation” (Representación Impresa) can be generated for record or delivery to customers who are not using electronic means. This is basically a PDF or printed copy that includes a QR code or other reference to the e-CF, used in cases like consumers or small vendors who need a paper copy. However, the official tax validity lies in the XML sent to DGII. [sovos.com]
  • Transmission Protocol: Communication with DGII’s system is via web service endpoints (REST APIs), which accept the XML payloads and return responses. Businesses need internet connectivity and authorized access to use these services (through their software or the DGII portal). The environment is secured and requires authentication – only taxpayers authorized as electronic issuers can send e-CFs (they must have completed the registration and testing process with DGII in advance). [sovos.com], [sovos.com] [sovos.com]
  • Service Providers: Many companies use certified Electronic Invoicing Service Providers to handle the integration. These providers ensure the invoice format is correct and handle the communications with DGII. The DGII has a certification program for such providers (Norma General 10-21, etc. covers this). Alternatively, larger taxpayers might build their own integration, which requires DGII’s authorization and testing as well. [dgii.gov.do] [sovos.com]
  • Contingency and Deferred Delivery: Decree 587-24 allows for contingency scenarios – e.g., if the DGII platform is down or a company’s system is down, invoices can be issued and later batch-transmitted. There is also a concept of deferred e-CF delivery: in special cases, an invoice might be issued and given to the client, and the XML sent a short while later (though this is generally an exception). The law and regulations ensure that such situations are logged and that the invoice still gets to DGII within an acceptable short delay. [edicomgroup.com]
Data to Be Reported (Content of E-Invoicing/E-Reporting):
The data transmitted in the e-invoice covers everything needed for VAT administration. This includes: identification of seller and buyer, invoice date and number (e-NCF), line-item details (product/service description, quantity, unit price), taxable amounts and tax breakdown (ITBIS – VAT, and any other taxes or withholdings), totals, and references if it’s an adjustment (credit/debit note referencing original invoice), etc. In addition, the metadata specifically required by the e-invoicing system includes the digital signature info and timestamps. All these elements are part of the XML structure defined by DGII’s schema. Because the e-reporting is inherent to the e-invoice, there is no additional separate dataset to send – the invoice itself is the data report. The DGII thus receives all details of each transaction in a structured form, which it can aggregate for oversight. [sovos.com], [sovos.com]
Archiving and Retention Requirements: The law mandates that electronic invoices must be stored and accessible for a lengthy period for tax audit purposes. Taxpayers are required to archive all issued and received e-CFs for a minimum of 10 years in electronic form. This aligns with the general statute of limitations for tax in the DR. Key points: [edicomgroup.com], [complyance.io]
  • Retention Period: 10 years from the date of issuance is the minimum retention period. Taxpayers should not delete or lose access to the e-invoices during this time. This applies to both the supplier’s copies and the buyer’s copies (since buyers may need them to support VAT credit claims). The 10-year requirement was explicitly set to ensure that historical invoices are available for any audits or verification. [complyance.io]
  • Format and Integrity: Invoices must be kept in their original electronic format (XML) with their digital signatures intact. Businesses should implement secure storage (either in-house or via their service provider or DGII’s system) to guarantee the integrity and accessibility of these files. The law and regulations likely require that the electronic archive preserves the invoices in a way that they can be verified (e.g., the digital signature can be checked even years later to prove the invoice wasn’t altered). [edicomgroup.com]
  • Access by Tax Authority: The DGII itself receives all invoices, so it effectively has its own copy of the records. However, taxpayers are still obliged to maintain their archive. In case of system audits, the company might be asked to produce the invoices. Given the dual storage (company and DGII), the system bolsters the audit trail.
  • Paper Printouts: If a paper print of an e-CF is made (for business records or for customers without electronic means), those printouts are typically for reference only. The official record remains electronic. Nonetheless, companies often keep PDF/paper versions for convenience, but the legal requirement is to keep the digital version for 10 years.
The 10-year retention is longer than the standard 5 years in some jurisdictions, showing the emphasis on long-term data availability. Companies should ensure their backup systems are robust for this duration. [edicomgroup.com]
Pre-Filled VAT Returns (VAT Declaration Integration):
As of the most recent updates, the Dominican Republic has not introduced pre-filled VAT returns for taxpayers, even though it now collects detailed invoice data. Taxpayers must continue to file their periodic VAT declarations (the monthly ITBIS return, Form IT-1) in the normal way. There is no system of automatically pre-populated tax returns by the DGII at this time. However, the comprehensive e-invoicing data greatly enhances the DGII’s ability to cross-check and eventually could enable pre-filled returns. In summary:
  • Current Situation: Businesses still prepare and submit their own VAT returns (e.g. summarizing total sales, total ITBIS collected, input credits, etc.), and no official “pre-populated” return is provided by DGII. The e-invoicing law did not eliminate the need for the monthly VAT filing. It did, however, eliminate the need for certain annexes or detailed listings, since the DGII already has the invoice-by-invoice details. (For example, the DGII’s existing requirement for large taxpayers to submit detailed sales listings may be rendered redundant.)
  • Data Reconciliation: Because DGII receives all e-CFs, they can automatically tally a taxpayer’s sales and purchases. It’s expected that the authority will use this to cross-verify the self-reported VAT returns. Discrepancies between the sum of e-invoices and the figures on a return could trigger flags. In the long run, this system paves the way for the DGII to potentially offer pre-calculated VAT figures. At present, though, the taxpayer must still actively file their VAT return each period. The phrase from one source – “no separate VAT return required for each invoice” – simply means there isn’t an additional filing per invoice, not that the periodic return is generated for you. [complyance.io]
  • Future Outlook: Many tax administrations that implement e-invoicing eventually move toward utilizing that data for pre-filled returns (as seen, for instance, in some countries like Spain’s SII system or Italy’s pre-filled VAT ledgers). The DGII has not yet announced a formal pre-fill program for ITBIS, but it remains a possibility. For now, the taxpayer remains responsible for compiling their VAT return. There is also no indication of eliminating the return entirely – the likely scenario is that e-invoicing will simplify compliance (the data needed for the return is readily available) and improve accuracy. The DGII has the capability to implement pre-filled returns if they choose, given that “the tax administration possesses almost complete information of taxpayers’ transactions in real time”. Any move in this direction would be communicated in future DGII rules or public announcements. [dgii.gov.do]
Additional References & Official Resources:
The e-invoicing framework is backed by formal legislation and DGII publications. For detailed reference, see Law 32-23 (Ley de Facturación Electrónica, published in Official Gazette No. 11107 on 17 May 2023), and its implementing Decree 587-24 (effective 10 Oct 2024) which sets out technical regulations. The DGII has issued various notices, such as Notice 07-23 (which announced the law’s enactment and model), Notice 20-24 (detailing the decree and rules), and Notice 12-25 (granting the 2025 deadline extension). These documents (available on DGII’s official website) cover the legal basis, taxpayer obligations, and timeline in detail. Taxpayers and advisors also rely on DGII’s General Norms (like Norma General 01-2020, which was an earlier rule on e-CF) for specific guidance. [edicomgroup.com] [sapeinvoice.com] [orbitax.com] [kpmg.com] [dgii.gov.do]
Up-to-date information can be found in DGII’s releases and also through tax bulletins by firms (e.g. KPMG TaxNewsFlash, July 2025, EY global alert May 2025, etc.) and specialized providers’ summaries (EDICOM, Sovos, etc.), which track the implementation progress. [kpmg.com] [edicomgroup.com] [sovos.com]
In conclusion, the Dominican Republic’s e-invoicing/e-reporting mandate is a full-scope, phased rollout requiring electronic invoices for all domestic and export transactions by mid-2026. It operates on a near-real-time clearance model: invoices are electronically issued in XML, digitally signed, and transmitted to DGII at the time of issuance. There was a structured timeline with initial voluntary adoption, followed by mandatory deadlines for large taxpayers in 2024, medium in 2025 (with a brief grace extension), and all others in 2026. No separate “e-report” forms are required – the invoice data itself is the report to authorities. Transactions in scope include B2B, B2C, B2G, and cross-border sales (via specialized e-CF types), essentially covering the entire economy. Taxpayers in scope encompass all established businesses and entities (including public institutions and local branches of foreign companies) – non-established foreign entities are not directly required to issue e-CFs. Data requirements for each e-invoice are stringent (full invoice details, unique e-NCF code, digital signature, etc.), and the format is XML per DGII’s specs. Invoices must be reported instantly via DGII’s system (web service/API), with the DGII validating and acknowledging each invoice (post-issuance clearance). The law provided tax incentives for early compliance and the DGII offered a free platform to ease adoption. A notable grace period was given in 2025 (extending the medium/large deadline by 6 months), but overall the mandate is moving forward on schedule. Penalties for failing to comply after the deadlines include monetary fines (per the Tax Code/Law 32-23) and losing the ability to issue valid tax invoices, which can cripple a business’s operations. Lastly, there are robust **archiving requirements (10-year electronic retention)】 to ensure auditability, and while VAT returns are still taxpayer-filed (no automatic pre-filled returns) at this stage, the rich e-invoice data allows the DGII to verify and possibly in the future facilitate VAT compliance. All these measures – backed by official regulations and DGII oversight – aim to increase tax compliance, reduce evasion, and modernize the Dominican Republic’s VAT system in line with international best practices. [orbitax.com], [sovos.com] [sovos.com], [edicomgroup.com] [complyance.io] [edicomgroup.com], [edicomgroup.com] [sovos.com], [morillosur…ogados.com] [sapeinvoice.com], [complyance.io] [sapeinvoice.com] [edicomgroup.com] [hoy.com.do], [hoy.com.do] [openenvoy.com], [hoy.com.do]

 

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