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Briefing document & Podcast: E-Invoicing & E-Reporting in Argentina

4 weeks ago
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SUMMARY

Executive Summary:

Argentina has a mature and comprehensive electronic invoicing (e-invoicing) system that is mandatory for virtually all VAT-related transactions. The system requires real-time clearance of invoices through the tax authority (now ARCA, formerly AFIP), and includes electronic reporting and record-keeping obligations. The mandate has expanded over time, culminating in full nationwide adoption in 2019. The system encompasses B2B, B2C, and B2G transactions, as well as exports. Recent developments include the introduction of QR codes on invoices and the implementation of a “Simplified VAT” (IVA Simple) system with pre-filled VAT returns, leveraging e-invoicing data to streamline compliance. Non-compliance is met with strict penalties, including business closures and fines.

Key Themes and Information:

Mandate and Scope:

  • E-invoicing is mandatory for all VAT-registered persons in Argentina, including standard VAT taxpayers, small taxpayers under the Monotributo simplified regime, and VAT-exempt entities.
  • “Since April 1, 2019, every business or person in Argentina that is registered for VAT or in the simplified tax regime is required to issue electronic invoices for all sales of goods and services. This date marks the full nationwide adoption of e-invoicing (with no categories of VAT-registered taxpayers excluded).”
  • Covers domestic B2B, B2C, and B2G transactions, as well as export sales (“Factura E”).
  • Imports are not subject to the e-invoicing mandate.
  • Foreign entities VAT-registered in Argentina must comply.

Implementation Timeline:

  • Phased rollout began in 2002, becoming gradually mandatory for certain sectors.
  • July 1, 2015: E-invoicing became compulsory for all registered VAT payers. “From this point, any business registered for VAT had to issue electronic invoices (or use authorized fiscal cash registers in certain cases) for their transactions.”
  • April 1, 2019: Extended to all taxpayers, including small taxpayers and freelancers. “Since April 1, 2019, every business or person in Argentina that is registered for VAT or in the simplified tax regime is required to issue electronic invoices for all sales of goods and services.”
  • 2019-2021: Introduction of electronic receipts (e-receipts) for small sellers and mandatory QR codes on e-invoices.
  • 2024-2025: Introduction of new requirements for tax transparency (GR 5614/2024) and updated e-invoicing systems (GR 5616/2024), mandating itemized VAT and foreign currency exchange rates on invoices.

Grace Periods and Phasing:

  • Compliance dates have been phased by taxpayer size or system.
  • “However, there is generally no extended grace period for enforcement beyond the official effective dates. Taxpayers must adhere to the mandate from the stipulated start date, or they risk non-compliance penalties.”
  • Once e-invoicing became mandatory for a given category, paper invoices not validated by AFIP/ARCA ceased to be accepted for VAT purposes.

Transactions Covered:

  • Domestic B2B (“Factura A”), B2C (“Factura B”), and B2G transactions.
  • Exports (“Factura E”).
  • Credit and debit notes must also be electronic.
  • Special e-documents exist for certain sectors (e.g., “Electronic Credit Invoice (Factura de Crédito Electrónica MIPYME)”).
  • “Only transactions entirely outside the Argentine VAT system (like imports or very minor operations by unregistered individuals) are exempt. This broad scope has been in full effect since 2019.”

Taxable Persons in Scope:

  • Companies and individuals registered for VAT (“Responsables Inscriptos”).
  • Taxpayers under the Simplified Regime (Monotributo).
  • VAT-Exempt persons or entities.
  • Exporters.
  • Foreign companies with Argentine VAT registration.

E-Invoice Format and Data Requirements:

  • Electronic invoices are generated in XML format, conforming to AFIP/ARCA’s prescribed schema.
  • Clearance system: Each invoice requires a CAE (Código de Autorización Electrónico) from AFIP/ARCA for validation. “The CAE is effectively a digital signature/validation from the tax authority; an invoice lacking a CAE is not fiscally valid.”
  • Mandatory fields include seller and buyer identification (CUIT, DNI/passport), invoice details (date, number, point-of-sale code, invoice type), line item details, net and tax amounts, total amount, currency, and exchange rate (if applicable).
  • Must include the buyer’s VAT condition on the invoice
  • Electronic signature required using a digital tax certificate.
  • QR code required on printed or PDF copies of invoices, containing key invoice metadata and the CAE. This allows for easy verification against ARCA records.
  • Different invoice types exist (A, B, C, E, M) based on the transaction and taxpayer status.

Transmission Process (Real-time Clearance):

  • Invoice data is transmitted to the tax authority at the time of issuance for approval.
  • “The invoice must be authorized by AFIP before or at the moment it is issued to the customer.”
  • Methods include web service (SOAP API) integration, AFIP’s online portal (“Comprobantes en Línea”), or a mobile invoicing app.
  • The AFIP/ARCA system validates the data and assigns a CAE (authorization code) if approved.
  • The issued invoice (with CAE and QR code) is then delivered to the buyer.
  • Storage of invoice data is required by both parties.
  • Contingency procedures exist for system downtime, requiring later reporting of provisional invoices.

Recurring E-Reporting (Post-Invoice Reporting Obligations):

  • Taxpayers are required to keep electronic VAT ledgers (“Libro IVA Digital”).
  • Monthly submission of sales and purchase invoices to AFIP’s system. “The e-reporting of invoices is done on a monthly basis via AFIP’s system.”
  • The monthly e-report (Digital VAT Book) includes key aggregated information – listing of each invoice (date, number, amount, tax) and totals.

Penalties for Non-Compliance:

  • Strict penalties for failing to comply with e-invoicing obligations.
  • “Taxpayers who do not issue invoices or keep the mandated records correctly can be punished with the temporary closure of their establishment for 2 to 6 days.”
  • Monetary fines.
  • Rejection of VAT credit for buyers if an invoice is not electronically issued.

Archiving and Retention Requirements:

  • “Taxpayers must securely retain all issued and received invoices for 10 years.”
  • Invoices must be stored in their original electronic format (XML) along with metadata.
  • Data should be stored on servers located in Argentina or accessible to the tax authority. “Argentina does not generally allow archiving tax documents abroad unless a special authorization is obtained, so companies either keep records on local servers or in cloud services with data centers in Argentina. Archiving abroad is not permitted by default.”
  • Archived e-invoices must maintain integrity and be available for inspection.
  • The electronic archive of the invoice is legally equivalent to a paper original.

Pre-Filled VAT Returns (IVA Simple):

  • A new system called “IVA Simple” (Simplified VAT) was introduced in mid-2025 to streamline VAT compliance via pre-filled returns.
  • “Under the IVA Simple system, the data from taxpayers’ digital VAT books (sales and purchase e-invoice data) will be used to pre-complete the monthly VAT return.”
  • Taxpayers can then review and confirm or correct the pre-filled amounts.

Key Regulations and Official Resources:

  • Numerous General Resolutions (RG) issued by AFIP/ARCA. Examples include:
  • RG 3749/2015 (mandatory e-invoicing for VAT taxpayers from 2015)
  • RG 4290/2018 (expansion to all taxpayers by 2019)
  • RG 4892/2020 (QR code requirement)
  • RG 5616/2024 (updated technical conditions for 2025)
  • RG 5705/2025 (IVA Simple pre-filled return system)
  • AFIP website is the main portal for e-invoicing administration and compliance information.

Conclusion:

Argentina’s e-invoicing and e-reporting system is a mature and strictly enforced system. It provides the tax authority with comprehensive real-time visibility into transactions, and now is being leveraged to simplify VAT compliance through pre-filled returns. Businesses operating in Argentina must adhere to these regulations to avoid significant penalties.

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INDEPTH ANALYSIS

Argentina has a comprehensive electronic invoicing (Factura Electrónica) regime that is mandatory for virtually all VAT-related transactions, with electronic reporting and record-keeping obligations to match. Below is an up-to-date overview covering the implementation timeline, scope, technical specifics, transmission requirements, compliance deadlines (including any grace periods), and related obligations (penalties, archiving, and VAT returns), supported by recent regulations and official sources:

  • Mandate and Scope: Electronic invoicing is mandatory in Argentina for all VAT-registered persons (including standard VAT taxpayers, small taxpayers under the Monotributo simplified regime, and VAT-exempt entities) and covers all domestic B2B, B2C, and B2G transactions as well as export sales. In practice, any invoice or equivalent receipt issued in Argentina must be electronic and cleared through the tax authority’s system. (Notably, imports – inbound transactions where foreign suppliers issue invoices – are not subject to Argentina’s e-invoicing mandate.) This requirement applies to both companies and individuals (self-employed professionals) who are registered for Argentine VAT. Non-resident companies without an Argentine tax registration are generally outside the scope, but any foreign entity that is VAT-registered in Argentina must comply with the e-invoicing rules as if it were a local taxpayer. [fonoa.com] [complyance.io], [fonoa.com]
  • Implementation Timeline: Argentina was an early adopter of e-invoicing, rolling it out in stages over many years. Key milestones include:
    • 2002–2005: The legal framework for e-invoicing began in 2002 (General Resolution 1361), introducing electronic invoices on a voluntary basis as a duplicate of paper receipts. In 2005, AFIP (the Federal Administration of Public Revenues) established an e-invoice issuance and storage system via General Resolution 1956. [sovos.com], [blog.groupseres.com] [blog.groupseres.com]
    • 2006–2009: From 2006, e-invoicing became gradually mandatory for certain sectors. General Resolution 2177 (2006) required electronic invoicing for specific industries (e.g. telecom providers, internet/cable TV, utilities, prepaid medical, security and cleaning services). This was expanded in 2008 (GR 2485) and by January 2009 to more sectors like highway tolls, IT services, advertising, and professional services above a revenue threshold. These phased mandates were early steps toward broader adoption. [blog.groupseres.com]
    • 2013–2015: The mandate steadily expanded. In 2014, many mid-sized and small businesses were brought in, and General Resolution 3749/2015 was issued in March 2015 to generalize mandatory e-invoicing for all VAT-registered taxpayers. By July 1, 2015, **electronic invoicing became compulsory for all registered VAT payers in Argentina, effectively phasing out paper invoices for those taxpayers. From this point, any business registered for VAT had to issue electronic invoices (or use authorized fiscal cash registers in certain cases) for their transactions. [sovos.com] [blog.groupseres.com], [sovos.com]
    • 2018–2019: The scope was finalized. General Resolution 4290/2018 (effective April 2019) extended the e-invoicing obligation to absolutely all taxpayers, including small taxpayers and freelancers who may not have been fully covered by earlier rules. Since April 1, 2019, every business or person in Argentina that is registered for VAT or in the simplified tax regime is required to issue electronic invoices for all sales of goods and services. This date marks the full nationwide adoption of e-invoicing (with no categories of VAT-registered taxpayers excluded). [sovos.com], [fonoa.com] [fonoa.com]
    • 2019–2021: Electronic receipts and QR codes. In parallel with the 2019 expansion, Argentina introduced digital tools for small sellers and additional data requirements. Taxpayers below a low annual revenue threshold (e.g. under ARS 2 million) were allowed to issue electronic receipts (e-receipts) for certain in-person sales (a simplified form of e-invoice). Moreover, General Resolution 4892/2020 mandated that all e-invoices include a QR code containing key invoice data for verification. This QR code requirement was phased in and became fully effective by 2021 for all electronic invoices. (The QR must encode details like the invoice ID, dates, amounts, parties’ tax IDs, and the CAE authorization code – see details below.) [storecove.com], [storecove.com] [blog.groupseres.com] [complyance.io], [blog.groupseres.com]
    • 2024–2025: Latest updates (Tax transparency and new systems). The Argentine tax authority (which has been rebranded as ARCA – Agencia de Recaudación y Control Aduanero, formerly AFIP) continues to refine the e-invoicing regime. In December 2024, ARCA issued General Resolutions 5614/2024 and 5616/2024 introducing new requirements and an updated rollout schedule. GR 5614/2024 (the “Consumer Tax Transparency Regime”) requires that invoices to final consumers clearly itemize the VAT and any other indirect taxes in the price – this took effect for large companies on January 1, 2025, and for all other taxpayers by April 1, 2025. GR 5616/2024 imposes additional data for invoices issued in foreign currency (such as specifying the exchange rate used) and set a timeline to upgrade e-invoicing systems. According to this resolution, the official technical specifications for new web service interfaces were published on January 15, 2025, and the use of the updated e-invoicing system (WebService, online portal, and mobile app) becomes mandatory from April 15, 2025 onwards. In other words, as of April 2025 all taxpayers must use ARCA’s revised electronic invoice schema and tools (the online vouchers portal, “Comprobantes en Línea,” new mobile billing app, or their own software via the updated Web Service) ensuring invoices include the newly required information. No general “grace period” beyond these staggered effective dates is provided – taxpayers are expected to comply by the deadlines (large companies by Jan/Mar 2025 for certain features, and all others by April 2025). [edicomgroup.com], [edicomgroup.com] [edicomgroup.com] [blog.groupseres.com], [blog.groupseres.com] [edicomgroup.com], [blog.groupseres.com]
  • Grace Periods and Phasing: In Argentina’s rollout, compliance dates have often been phased by taxpayer size or system, but once a deadline passes the requirement is enforceable. For example, smaller taxpayers were given until 2019 to implement e-invoicing after larger firms adopted it in 2015, and the 2025 changes stagger implementation between January and April 2025 as noted. However, there is generally no extended grace period for enforcement beyond the official effective dates. Taxpayers must adhere to the mandate from the stipulated start date, or they risk non-compliance penalties. (Argentina’s tax authority tends to require compliance by the deadline, rather than offering open-ended leniency. Only the built-in phase-in schedules serve as a form of grace period for certain groups.) In practice, once e-invoicing became mandatory for a given category, paper invoices not validated by AFIP/ARCA ceased to be accepted for VAT purposes. Taxpayers were expected to switch to the electronic system by the due date, with no “no-penalty” grace window thereafter. Contingency procedures do exist (e.g. if the electronic system is down, a taxpayer might issue a provisional invoice and then report it electronically within a short time frame), but these are exceptions rather than any broad grace period. [fonoa.com] [edicomgroup.com] [blog.groupseres.com]
  • Transactions Covered: The e-invoicing mandate covers virtually all types of transactions that require an invoice under Argentine law:
    • Domestic B2B (business-to-business) sales and services must be e-invoiced. When a VAT-registered supplier sells to a VAT-registered customer, a “Factura A” (Invoice A) is issued electronically. These B2B invoices include VAT and allow the buyer to claim input tax credit. [sovos.com]
    • Domestic B2C (business-to-consumer) transactions are also in scope – when a registered business sells to a final consumer or a VAT-exempt customer, an electronic “Factura B” is used. Even small retail sales to consumers are often documented by electronic receipts or invoices transmitted to AFIP. (As noted, small merchants with low turnover can use a certified fiscal cash register to issue receipts, which are then reported electronically – effectively a form of e-invoicing. But outright paper hand-written receipts are no longer permitted for registered taxpayers.) [sovos.com]
    • B2G (business-to-government): Argentina requires electronic invoicing for all sales to public sector entities as well. These follow the same clearance process as B2B/B2C. In other words, any supplier issuing an invoice to a government agency must do so electronically via AFIP/ARCA and obtain the authorization code, just as with private-sector invoices. [sovos.com]
    • Cross-Border: Export transactions are included – exporters must issue electronic export invoices (“Factura E”) for goods or services shipped abroad. This ensures export sales (which are generally VAT-zero-rated or exempt) are recorded in the system. Import transactions, however, are not subject to e-invoicing: when Argentine companies import goods or services, the foreign supplier’s invoice is outside Argentina’s domestic system, so no Argentine e-invoice is generated for imports. (Imports are instead handled via customs documentation and self-assessment of import VAT.) [sovos.com] [fonoa.com]
    • Credit/Debit Notes: All credit notes or debit notes issued to adjust invoices (for returns, discounts, corrections, etc.) must also be electronic, following the same type (A, B, C, or E) as the original invoice type. These are considered fiscal documents and fall under the e-invoicing mandate. [edicomgroup.com], [fonoa.com]
    • Special sectors: Argentina has some specific e-documents for certain sectors (e.g. a special “Electronic Credit Invoice (Factura de Crédito Electrónica MIPYME)” for financing small supplier invoices, electronic bill of lading for livestock, etc.), which are all integrated into the overall electronic system. For instance, small and medium enterprises can issue an Electronic Credit Invoice (which is basically an invoice that can be accepted by a large customer and turned into a negotiable instrument); this is also done through the electronic platform. [edicomgroup.com], [edicomgroup.com]
    • Summary: In sum, domestic sales of all kinds (to companies, consumers, and government) and exports are subject to e-invoicing. Only transactions entirely outside the Argentine VAT system (like imports or very minor operations by unregistered individuals) are exempt. This broad scope has been in full effect since 2019. [fonoa.com]
  • Taxable Persons in Scope: All Argentine taxpayers that are required to issue invoices are in scope of the e-invoice mandate. This includes:
    • Companies and individuals registered for VAT, regardless of size. From large corporations down to sole proprietors and freelancers, if they are VAT-registered (“Responsables Inscriptos”), they must use electronic invoices for their transactions. [complyance.io]
    • Taxpayers under the Simplified Regime (Monotributo): even though very small businesses under Monotributo pay a flat tax and don’t charge VAT, since 2019 they are also obliged to issue electronic invoices or receipts for their sales. The tax authority extended the e-invoicing requirement to Monotributistas to improve compliance monitoring. [fonoa.com]
    • VAT-Exempt persons or entities – entities that are not liable to VAT (for example, certain nonprofits or exempt sectors) must also issue electronic invoices when they sell goods or services, even though their invoices might show VAT as “0” due to exemption. This ensures all formal invoices, even without VAT, are captured. [complyance.io]
    • Exporters – any taxpayer performing exports must register and use electronic export invoices (as mentioned above). [edicomgroup.com]
    • Non-established entities: A foreign company without a local Argentine tax registration generally cannot issue an Argentine electronic invoice (and is not expected to). However, if a foreign or non-resident business registers for Argentine VAT (e.g. via a local branch or a tax representative), then it falls under the same rules as domestic taxpayers. For example, a foreign digital service provider that registers in Argentina to charge VAT would have to issue Argentine e-receipts or invoices to its customers. (Argentina in practice handles B2C digital services from abroad via VAT withholding by credit card companies, so fully non-established companies usually do not issue Argentinian invoices.) In summary, the e-invoicing obligations primarily concern established taxpayers – all those enrolled in Argentinian tax regimes. [complyance.io]
    • Use of fiscal controllers: The only alternative to e-invoices allowed is the use of authorized “fiscal controllers” (cash register machines that print fiscal receipts and automatically report data to AFIP). Certain smaller retailers or specific situations can use these devices instead of issuing an e-invoice for each sale. In either case, the tax authority receives the data electronically. Notably, as of 2019 the regime even permits previously-exempt small taxpayers to opt for full e-invoicing in lieu of fiscal cash registers, so increasingly the trend is toward pure e-invoicing. The latest regulations (GR 5616) explicitly allow issuing electronic invoices without using a fiscal controller for all taxpayers, solidifying e-invoicing as the standard across the board. [edicomgroup.com] [blog.groupseres.com], [blog.groupseres.com]
  • E-Invoice Format and Data Requirements: Argentina uses a standardized electronic invoice format and content, defined by the tax authority:
    • Format: Electronic invoices (also called “comprobantes electrónicos”) are generated in XML format and must conform to AFIP/ARCA’s prescribed schema. There isn’t a generic global standard like UBL; instead, AFIP provides its own XML structure and web service definitions. Each invoice type (A, B, C, E, etc.) has specific fields but all are transmitted as XML data to the government platform. [complyance.io]
    • Clearance and CAE: Argentina’s model is a “clearance” system – each invoice’s data must be sent to the tax authority, which validates it and issues an approval code in real time. Specifically, the issuer must obtain a CAE (Código de Autorización Electrónico), which is a unique electronic authorization code generated by AFIP/ARCA for that invoice. The CAE is effectively a digital signature/validation from the tax authority; an invoice lacking a CAE is not fiscally valid. The CAE comes with an expiry date (usually a short window in which the invoice must be delivered to the customer – often 10 days) and is included on the invoice. [complyance.io], [basware.com] [basware.com] [fonoa.com], [storecove.com]
    • Mandatory Fields: An Argentine e-invoice must contain all the information required by law for an invoice, encoded in the XML. Key data fields include: identification of the seller and buyer (name, address, and tax ID – the CUIT for businesses, or DNI/passport for individuals); invoice details (the date of issue, a unique invoice number and the point-of-sale code, which together form the invoice’s ID, and the invoice type: A, B, C, E, etc.); line item details describing the goods or services, their quantities, unit prices; net amounts and tax amounts (VAT must be broken out at the applicable rate, and any other taxes or fees if applicable); the total amount in the invoice currency; and if in foreign currency, the currency code and exchange rate used. The invoice also indicates the buyer’s tax status (e.g. whether the buyer is a registered VAT payer, final consumer, exempt, etc., which determines the type A or B) – per the new 2024 rules, including the buyer’s VAT condition on the invoice is explicitly required. [storecove.com], [blog.groupseres.com] [blog.groupseres.com] [sovos.com] [origentech.com], [storecove.com] [origentech.com]
    • Electronic signature: The XML invoice is digitally signed by the issuer’s digital certificate to ensure authenticity and integrity during transmission. This digital signature (along with the later-added CAE from AFIP) guarantees that the invoice data has not been altered and confirms the identities. To facilitate this, each taxpayer must obtain a valid digital tax certificate (certificado fiscal digital) from AFIP for signing their electronic invoices. [storecove.com]
    • Approval info on the invoice: Once approved, the invoice’s CAE (authorization code) and its expiration date are included in the electronic invoice data and also typically printed on the invoice copy given to the customer. All Argentine e-invoices must also incorporate a QR code on any printed or PDF representation given to the customer. The QR code contains key invoice metadata (issuer CUIT, invoice type/number, date, total, VAT breakdown, etc.) and the CAE, allowing the customer or tax inspectors to scan and verify the invoice directly against AFIP’s records. This makes verification easy – a buyer can scan the QR and be taken to AFIP’s website to see if that invoice was truly authorized. [fonoa.com] [basware.com] [basware.com], [blog.groupseres.com]
    • Invoice Types: As noted, the format accommodates multiple invoice types: Type “A” for sales to VAT taxpayers, “B” for sales to consumers or exempt parties, “C” for use by small exempt taxpayers, “E” for exports, “M” for certain high-risk taxpayers requiring VAT withholding, etc.. These labels are part of the data. Each electronic invoice includes a field for the type code and the point-of-sale terminal number that issued it. Argentina’s system also issues other electronic documents like credit notes, debit notes, receipt vouchers, etc., which share the core format and clearance process. [sovos.com] [sovos.com], [edicomgroup.com]
    • Technical Documentation: The tax authority provides detailed technical documentation (in Spanish) for software developers, including Web Service APIs (SOAP XML services) for submitting batches of invoices and retrieving CAEs, and definitions of the XML structure (XSD schemas). These are updated with any new requirements (for example, ARCA’s “WebService V2” technical manual updated in 2025 to account for the new fields). Larger companies typically integrate their ERP or billing systems directly with these web services to automatically send each invoice to AFIP and receive the CAE in seconds. [blog.groupseres.com], [blog.groupseres.com]
  • Transmission Process (Real-time Clearance): Argentina’s e-invoicing works on a real-time clearance model: invoice data is transmitted to the tax authority at the time of issuance for approval. Summarized steps to issue a compliant e-invoice:
    1. Preparation: The seller gathers required information (buyer’s details, transaction details) and uses an approved system to generate the invoice in the correct XML format. The issuer’s system must authenticate with AFIP – typically using a digital certificate or token associated with their tax account. [storecove.com]
    2. Submission to AFIP/ARCA: The XML invoice is sent via web service or uploaded via AFIP’s online portal (or entered manually on the portal) to the tax authority’s centralized invoicing system. Most medium and large taxpayers use the Web Service SOAP API integration (often through an authorized service provider’s platform) to submit invoices directly from their billing software. Smaller businesses or individuals may use the AFIP online platform (“Comprobantes en Línea”) by logging in through the website and keying in invoice data, or use the mobile invoicing app provided by AFIP for on-the-go issuance. In all cases, the data goes to the central system. [edicomgroup.com], [storecove.com] [storecove.com] [blog.groupseres.com]
    3. Clearance by Authority: The AFIP/ARCA system automatically validates the invoice data. It checks that the format is correct, the CUITs are valid and active, the invoice number is in sequence for that point of sale, etc. If everything is in order, AFIP assigns a CAE (authorization code) and timestamp to the invoice. This approval is typically instantaneous or within seconds for online submissions. (If the invoice is rejected due to an error – e.g., missing field or out-of-sequence number – an error message is returned and the issuer must correct and re-submit.) [sovos.com]
    4. Invoice Issuance: Upon receiving the CAE, the invoice is considered approved and issued. The issuer can now deliver the invoice to the buyer – usually by providing a PDF or printed copy that contains all invoice details along with the CAE and QR code. The buyer, by law, must receive an electronic or printed copy of the e-invoice. For business customers, the seller will often send a PDF via email or provide electronic XML; for consumers, often a printed ticket or PDF receipt is given, but it’s still backed by an e-invoice in the system. [sovos.com], [fonoa.com]
    5. Storage: Both parties must archive the invoice (discussed below). The tax authority already has the invoice data in its database from clearance, so filing the invoice with the government is already accomplished in this process.
    This entire workflow occurs at the time of transaction. There is no allowance for sending invoice data days after issuance – the invoice **must be authorized by AFIP before or at the moment it is issued to the customer. In practice, this means a business cannot legally issue an invoice at midnight and only upload it the next day; it needs to obtain the CAE first (unless using a contingency mechanism). The system is effectively real-time. The only exceptions are contingency scenarios: if the online system is unavailable (e.g., system downtime or connectivity issues), AFIP has established contingency procedures (such as using pre-authorized ranges or issuing paper to be reported later). In such cases, taxpayers must transmit the data as soon as possible once the system is back, and obtain the CAE retrospectively for those invoices. These are special cases – under normal conditions, invoices are transmitted and cleared immediately. [sovos.com]
  • Recurring E-Reporting (Post-Invoice Reporting Obligations): In addition to the per-invoice clearance, Argentina historically imposed periodic reporting requirements to ensure all invoices are accounted for:
    • Monthly Sales and Purchase Ledgers: Taxpayers have been required to keep electronic VAT ledgers (“Libro IVA Digital” or formerly “Registro de comprobantes”) which list all sales invoices issued and purchase invoices received in a period. Until 2020, many taxpayers submitted a monthly VAT Sales and Purchases report (informatively known as RC IVA) to AFIP, either via an upload of details or via an online form. This effectively served as an electronic reporting (“e-reporting”) of all invoices on a summary level. Since e-invoices are already in AFIP’s system, these reports function as a reconciliation and to capture any transactions not issued electronically (e.g. import purchases, or invoices issued via fiscal controllers). [complyance.io], [complyance.io]
    • Monthly submission: The e-reporting of invoices is done on a monthly basis via AFIP’s system. Generally, by the 20th of each month (deadlines can vary slightly by taxpayer CUIT number), taxpayers must submit their digital VAT books for the previous month. This submission includes a summary of all CAE-authorized sales invoices issued in that month and typically the detail of purchase invoices (for input VAT credit). Because AFIP already has the sales, the Libro IVA system often pre-lists them, and the taxpayer confirms or adjusts the data (for example, to add any invoices issued under contingency or to exclude canceled documents). Any discrepancies or changes (such as canceled invoices, credit notes adjusting sales, etc.) must be reported as well. [complyance.io] [complyance.io], [complyance.io]
    • Data transmitted: The monthly e-report (Digital VAT Book) includes key aggregated information – essentially the listing of each invoice (date, number, amount, tax) and totals. It serves to pre-fill parts of the VAT return (sales totals) and provide audit trail. In the new “IVA Simple” system (2025), this monthly digital book is directly integrated into a simplified VAT return (discussed later), reducing the separate reporting burden. [kpmg.com], [kpmg.com]
    • Objective: This e-reporting obligation ensures that even transactions that might not individually flow through e-invoicing (like certain simplified documents or import invoices) are captured for VAT control. However, since essentially all sales invoices are now electronic, the monthly report for sales is often just an extract of the same data. It also helps catch discrepancies (for instance, if an invoice was voided after getting a CAE, it would show up and can be accounted for).
    • Other reports: Beyond the invoice ledger, Argentina does not require a SAF-T (Standard Audit File for Tax) or similar comprehensive electronic accounting submission on a regular basis. The focus is on invoice-by-invoice clearance plus the monthly summary. There are sector-specific reports in some cases (e.g., regimes for stock movements in certain industries), but no generic additional e-report like some countries have. [fonoa.com]
  • Penalties for Non-Compliance: Argentina enforces its e-invoicing mandate with strict penalties, as tax compliance is taken seriously. Failure to comply with e-invoicing obligations – for example, not issuing required e-invoices, or not maintaining proper records – can result in significant sanctions. Notably:
    • Administrative sanctions (Business closures): The tax law provides that taxpayers who **do not issue invoices or keep the mandated records correctly can be punished with the temporary closure of their establishment for 2 to 6 days. This is a direct penalty AFIP can apply (essentially sealing the business premises) and is indeed used in practice for serious invoicing violations. For instance, if a company were found to be bypassing the e-invoice system (issuing sales off-the-books or on paper), AFIP can order the premises closed for a number of days as a punitive measure. [sovos.com], [fonoa.com]
    • Fines: In addition to or instead of closure, monetary fines may be imposed. While the exact amounts can depend on the infraction and are set in Argentine tax law, non-compliance with invoicing rules generally carries fines of several thousand pesos per violation. (For example, not issuing an invoice or failing to report it might trigger a fine under the VAT law or procedural tax law, often proportional to the unreported tax.) Because the question explicitly asks for all penalties related to e-invoicing/e-reporting, it’s important to note that specific penalty amounts can change with legislation and inflation – but the closure sanction (2–6 days) is uniquely severe and has been a cornerstone of enforcement. There are also penalties for late submission of the monthly reports or VAT returns, and potentially suspension of a taxpayer’s ability to transact if non-compliance continues. [fonoa.com]
    • Other consequences: If an invoice is not electronically issued (and thus lacks a CAE), the sale may not be allowed as a VAT credit for the buyer, and the seller is technically issuing an invalid invoice. This can lead to the tax authority rejecting input credits and assessing the seller for failing to remit VAT. Moreover, chronic non-compliance can get a taxpayer flagged for audits. In summary, Argentina’s enforcement is strict: businesses must use the electronic system or face business disruption and financial penalties. There has been no blanket “grace period” of leniency on penalties after the mandates; once effective, AFIP is empowered to enforce fully. Businesses therefore have had to ensure timely compliance with each new requirement (like adding QR codes by 2021, or the new data by 2025) to avoid sanctions. [fonoa.com]
  • Archiving and Retention Requirements: Electronic invoices in Argentina come with rigorous archival obligations for audit and legal purposes:
    • Retention Period: **Taxpayers must securely retain all issued and received invoices for 10 years. This 10-year period aligns with the statute of limitations for tax audits (which is generally 5 years from the filing date, extendable in cases of evasion, leading effectively up to ~10 or more years total). In practice, AFIP requires a decade of records to be accessible. Both the issuer and the recipient of an invoice are required to keep a copy for that duration. (This means even buyers can be asked to produce purchase invoices they received, in electronic format, years later.) [edicomgroup.com], [complyance.io]
    • Format of Archival: Electronic invoices should be stored in their original electronic format (XML) along with any associated metadata. Electronic storage is allowed and encouraged – keeping only paper printouts is insufficient since the authenticity lies in the digital format. Companies typically store the XML files and perhaps PDF representations in an archive system. [basware.com]
    • Domestic storage: According to regulations, the data should be stored on servers located in Argentina (or otherwise accessible to the tax authority on demand). Argentina does not generally allow archiving tax documents abroad unless a special authorization is obtained, so companies either keep records on local servers or in cloud services with data centers in Argentina. Archiving abroad is not permitted by default. [basware.com] [fonoa.com]
    • Integrity and access: Archived e-invoices must maintain integrity (unaltered original XML with its digital signature and CAE) and be available for inspection by AFIP/ARCA upon request. Businesses should also archive the proof of authorization (the CAE confirmation, which is embedded in the XML) and any audit logs or acknowledgments related to the invoice. In other words, the archive should show that the invoice was indeed cleared by AFIP. Many companies keep the approval response from AFIP as part of the record. [basware.com]
    • Recipient validation: As a best practice, customers who receive an e-invoice will verify that it’s valid (using AFIP’s online verification or the QR code), and then store that invoice. The regulation explicitly states both sender and receiver must preserve the document for 10 years in a readable format. This implies that if you’re an Argentine company, you need to keep not just your sales invoices, but also all the electronic purchase invoices from your suppliers, for the 10-year period. [edicomgroup.com]
    • Legal equivalence: The electronic archive of the invoice is legally equivalent to a paper original. Since 2015, digital invoices are considered the “original” invoices for legal and fiscal purposes, and electronic storage fulfills bookkeeping requirements. (GR 3749/2015 explicitly established a regime for electronic issuance and storage of original invoices, replacing the old requirement of physical invoice books.) Thus, proper e-archiving is not just a technical need but a legal one – failing to produce an invoice on request (within that 10-year window) could be penalized as failure to keep records. [argentina.gob.ar]
    • Audit trail: Companies should ensure that their archiving system keeps an audit trail of any actions (like if an invoice was canceled, there should be a record of the cancellation and the replacement document, etc.). The archive should include the digitally signed XML, the CAE code, the timestamp of clearance, and if applicable, the cancellation or credit note referencing it. All this information may be needed in a tax audit. [basware.com]
  • E-Invoice Format Details (Summary): To summarize the technical format — Argentina’s e-invoice (often referred to as CFE: Comprobante Fiscal Electrónico) is an XML file containing: the seller’s and buyer’s tax identification, date/time, invoice number and type, line item details of the sale, tax breakdown, totals, and digital signatures. It is signed by the issuer then cleared by the authority, which appends the CAE (as a number plus an expiration date). A QRCode encoding key fields and the AFIP verification URL is included on the human-readable version. These requirements (XML format, CAE, QR, 10-year storage) have been consistently enforced since the mid-2010s and continue under ARCA’s latest regulations. [storecove.com], [storecove.com] [basware.com] [complyance.io], [basware.com]
  • Are Pre-Filled VAT Returns Available? Until recently, Argentina did not provide pre-completed VAT returns to taxpayers, despite the rich data collected from e-invoices. Taxpayers still had to manually compile their sales and purchase totals each month to file the VAT return (Form 2002 or 731) on AFIP’s system. However, this is now changing as the tax authority moves to leverage digital records for return preparation:
    • In mid-2025, Argentina announced a new system called “IVA Simple” (Simplified VAT) aimed at streamlining VAT compliance via pre-filled returns. The change was formalized by General Resolution 5705/2025, with effect from November 2025. [kpmg.com]
    • Under the IVA Simple system, the data from taxpayers’ digital VAT books (sales and purchase e-invoice data) will be used to pre-complete the monthly VAT return. Essentially, the information that a taxpayer normally reports across multiple forms is consolidated into a single online form (Form F. 2051), where much of the information is already filled in based on the e-invoices and credit/debit notes reported. The taxpayer can then review the pre-filled amounts (e.g. total sales, total input VAT) and either confirm them or make corrections if needed. This integrated digital VAT book and return aims to reduce errors and administrative work. [kpmg.com], [kpmg.com] [kpmg.com]
    • The IVA Simple regime initially targets small and medium taxpayers to simplify their filings, but it represents a move toward pre-populated VAT returns for Argentina. By having all invoices electronically, AFIP/ARCA can compute what a taxpayer’s VAT payable should be (sales VAT minus purchase VAT) and offer that as a starting point. Taxpayers will still need to ensure all invoices (including any that might not have been auto-captured) are accounted for. The new system replaces four old VAT forms with one unified form, which suggests a significant simplification. It also likely uses the monthly e-reporting data – since Argentina’s “digital VAT book” becomes the basis of the return, the distinction between mere reporting and actual filing blurs. [kpmg.com]
    • Pre-filled vs. Old System: Prior to IVA Simple, Argentina’s system (called “MIS Aplicaciones WEB – IVA” and digital purchases/sales books) provided some cross-checks but not a fully pre-filled return. Taxpayers had to manually enter totals or upload details. With IVA Simple, at least for those eligible, the government essentially prepares a draft return. This is analogous to trends in other countries that use e-invoice data to draft VAT returns for the taxpayer.
    • As of the latest information, IVA Simple is rolling out from November 2025. Taxpayers will need to confirm or adjust the pre-loaded data. Over time, this could become standard for all taxpayers, meaning Argentina would have pre-filled VAT returns based on e-invoicing data (in effect, making VAT compliance semi-automated). It’s a recent development and part of Argentina’s ongoing tax digitalization and modernization effort to reduce bureaucracy and improve accuracy. [kpmg.com]
    • Conclusion on pre-filled returns: Therefore, yes, Argentina is introducing pre-filled VAT returns (through IVA Simple), but this is a new initiative. Historically, no pre-populated returns were provided – taxpayers relied on their own records – but with the full visibility that e-invoicing gives the tax authority, the groundwork was laid for this innovation. The integration of e-invoicing (and e-reporting) with return preparation marks the next phase of Argentina’s digital tax enforcement. [kpmg.com]
References to Key Regulations and Official Resources:
The framework described above is backed by numerous General Resolutions (RG) issued by AFIP/ARCA, which are the binding legal norms. For instance, RG 3749/2015 established the broad mandatory e-invoicing regime for VAT-registered taxpayers; RG 4290/2018 (and 4291) expanded it to all taxpayers including small ones; RG 4892/2020 introduced the QR code requirement; and RG 5616/2024 updated technical conditions for 2025. The new IVA Simple system was introduced by RG 5705/2025 in mid-2025. The Argentine government’s official gazette (Boletín Oficial) and the AFIP website publish these texts (for example, the Ministry of Economy’s site on Argentina.gov.ar hosts the text of RG 3749/2015 and notes its later updates). The AFIP website is the main portal where taxpayers administer their e-invoicing (via the Comprobantes en Línea application) and find information on compliance. Additionally, detailed technical guides and manuals (in Spanish) are available on AFIP’s site, guiding how to use web services and the online portal for electronic invoicing. [sovos.com] [blog.groupseres.com] [edicomgroup.com] [kpmg.com] [argentina.gob.ar] [fonoa.com], [fonoa.com]
In summary, Argentina’s e-invoicing and e-reporting system is highly developed and stringent: all invoices are electronic and cleared in real time through the tax authority’s platform; virtually no significant transactions escape this digital control. There was a multi-year timeline of implementation culminating in full coverage by 2019, and continuous improvements (like QR codes and data enhancements) up to 2025. No broad grace periods exist once mandates kick in – compliance is expected by the deadline. The system covers domestic and export transactions, for all types of taxpayers (established businesses, SMEs, sole traders, etc.), while foreign-sourced transactions are excluded. Technical requirements (XML format, digital certificate, CAE code, specific fields, QR code) ensure each invoice contains all necessary data and is authenticated. Data transmission is typically instantaneous via web services or online tools, with monthly aggregate reporting to reconcile the invoices. Penalties for not complying – including business closures – underscore the importance of adhering to the rules. Archiving for 10 years in electronic form is mandatory to allow audits and cross-checks. And now, with the advent of pre-filled VAT returns (IVA Simple), Argentina is leveraging the wealth of e-invoice data to simplify compliance further by offering taxpayers an official draft of their VAT filings. All these measures make Argentina’s VAT administration one of the more digitally advanced, aiming to reduce evasion and increase efficiency. [kpmg.com] [complyance.io]
Sources:
  • AFIP/ARCA regulations and release information – e.g., AFIP General Resolution 3749/2015 (mandatory e-invoicing for VAT taxpayers from 2015) and its successors; AFIP General Resolution 4290/2018 (expansion to all taxpayers by 2019); General Resolution 4892/2020 (QR code requirement); General Resolutions 5614 and 5616 of 2024 (new 2025 requirements); General Resolution 5705/2025 (IVA Simple pre-filled return system). [sovos.com] [blog.groupseres.com] [edicomgroup.com] [kpmg.com]
  • Fonoa (Mar 2023) – Argentina E-invoicing Guide: confirms mandatory scope (all VAT taxpayers, B2B/B2C/B2G, exports) and key features of the system, as well as penalties and archiving obligations. [fonoa.com], [fonoa.com], [fonoa.com] [fonoa.com], [fonoa.com]
  • Sovos (2023) – Argentina e-Invoicing Overview: provides a timeline of adoption (from 2002 to 2021) and details on compliance processes and penalties. [sovos.com], [sovos.com]
  • Complyance.io (2023) – Argentina E-Invoicing Overview: summarizes Argentina’s clearance model (XML/CAE through AFIP), monthly reporting requirements, archiving period, and regulatory references. [complyance.io], [complyance.io], [complyance.io]
  • EDICOM (Feb 2025) – How Electronic Invoicing Works in Argentina: discusses who must use e-invoicing, types of fiscal receipts, how to issue (web service, portal), requirements like CAE and QR, and new ARCA regulations in 2025. [edicomgroup.com], [edicomgroup.com], [edicomgroup.com]
  • Grupo Seres (Dec 2024) – Current status of e-invoicing in Argentina: recounts the history (2002 onward) and highlights the new timelines from GR 5616/2024 (web service mandatory April 2025); also reiterates 10-year storage and core invoice data elements. [blog.groupseres.com], [blog.groupseres.com]
  • Basware (2022) – Argentina E-Invoicing & Archiving Rules: emphasizes that all Argentine taxpayers must issue e-invoices with CAE and QR via AFIP, and that both suppliers and buyers must archive invoices for 10 years locally. [basware.com], [basware.com], [basware.com]
  • Storecove (Feb 2023) – E-invoicing in Argentina – Everything You Should Know: details the process of compliance (digital certificate, XML invoice contents, validation via AFIP, steps to send and store, etc.). [storecove.com], [storecove.com], [storecove.com]
  • KPMG TaxNewsFlash (Aug 25, 2025) – Argentina: Simplified pre-filled VAT return system introduced: announces the IVA Simple regime and how it integrates digital VAT books into a new single form with pre-filled information. [kpmg.com], [kpmg.com]
  • VATCalc / VATupdate (2025) – notes on “Simple VAT” and pre-filled return initiative by ARCA (providing background on the aim to reduce bureaucracy and offer pre-populated returns).
Each of these sources provides insight into Argentina’s e-invoicing/e-reporting system, and official Argentine government publications provide the legal basis, ensuring the information above is both recent (reflecting 2024–2025 changes) and grounded in the actual regulations and practices. [complyance.io], [kpmg.com]

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