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

• Domestic B2B and B2C: All domestic sales between businesses (B2B) and to final consumers (B2C) require electronic invoices under FEL. Paper invoices have been fully phased out and are no longer valid for tax credit or deduction purposes. Any sales of goods or provision of services within Guatemala’s VAT system must be documented by a DTE (e-invoice) at the time of the transaction (at delivery for goods or upon payment for services), ensuring immediate reporting to SAT. This real-time reporting means that every taxable sale is instantly registered with the tax authority. [voxelgroup.net] [lexology.com]
• Domestic B2G: Business-to-Government transactions are included in the mandate. Since 2019, suppliers to the Guatemalan government have been among the early groups required to use FEL. Specifically, government vendors for public procurements (bidding, contracts, etc.) and providers of professional services to government agencies were mandated to issue e-invoices by SAT resolutions in 2019. Today, any sales or services rendered to government bodies must be invoiced through the FEL system, ensuring transparency in public procurement. [edicomgroup.com]
• Cross-Border Transactions: Exports from Guatemala are within the e-invoicing scope, even though the buyer is abroad. Guatemalan exporters must issue a DTE for export sales (generally zero-rated for VAT) to document the transaction for SAT. SAT requires an “export complement” (add-on data fields) on these invoices to capture details like shipment location and destination country, improving the traceability of foreign trade operations. Additionally, if an export’s final details are not yet confirmed (such as quantity or value at the moment goods depart), exporters may issue a Provisional Invoice (FACP) DTE. The FACP allows formal registration of a pending export and is later followed by a final Export Invoice once the goods reach the foreign customer. This two-step process helps industries (e.g. perishable goods exporters) comply with tax and customs rules while still shipping rapidly. [edicomgroup.com] [edicomgroup.com], [edicomgroup.com]
  Imports into Guatemala, on the other hand, are not themselves subject to FEL e-invoicing because foreign suppliers cannot issue Guatemalan DTEs. Instead, imports are handled via customs import declarations and traditional VAT reporting (with import VAT paid to customs) rather than through the FEL platform. The cross-border B2B purchases from foreign suppliers are out of scope of FEL (foreign vendors are not in the system); however, Guatemalan importers still must account for import VAT through the customs process and maintain the import documentation for tax purposes.
• Intra-EU Transactions: Not applicable. Guatemala is not part of the European Union, so it has no concept of “intra-EU acquisitions or supplies.” Cross-border transactions with EU countries are treated as imports/exports (see above) rather than intra-EU trade.

• Self-Billing: Guatemala’s framework explicitly provides for certain self-billing scenarios. The “Specific Invoice” (Factura Específica, FEPE) is a special DTE type used when the seller is not obliged to issue invoices (e.g. purchases from unregistered small suppliers). In such cases, the buyer issues an invoice on behalf of the seller through the FEL system. These self-billed electronic invoices carry a mandatory 1.5% withholding tax on the invoice amount (withheld by the buyer) and must comply with all FEL certification and content rules. This mechanism ensures that even transactions with informal sector suppliers are captured in the electronic system and that tax is withheld appropriately. [edicomgroup.com]
• Triangulation & Chain Transactions: There are no specific exemptions or special processes for multi-party or chain transactions under FEL – each taxable transaction between two parties must be recorded with its own DTE. If goods or services are sold through intermediaries in a chain, each intermediate sale by a Guatemalan taxpayer (including any triangulation scenarios) requires a compliant e-invoice at the point of that sale. The legal requirement is to issue a DTE at the moment of the transfer of goods or the receipt of payment for services, so each link in a domestic supply chain must issue an electronic invoice as evidence of their sale. In practical terms, a typical multi-step supply chain (e.g. manufacturer to distributor to retailer) will result in multiple DTEs – one for each B2B sale in the chain. [lexology.com]
  Note: If any party in the chain is not a VAT-registered taxpayer (for instance, certain small agricultural producers historically were not in the system), the special self-billing invoice (FEPE) mentioned above is used by the purchaser to ensure the transaction is captured in FEL. Foreign parties involved in a chain (e.g. a drop shipment or cross-border triangulation) are outside Guatemala’s jurisdiction – Guatemalan taxpayers only need to issue FEL invoices for the portions of a transaction that constitute taxable supplies in Guatemala. [edicomgroup.com]
• Special VAT Regimes: Guatemala’s FEL mandate extends to taxpayers under special VAT regimes as well. The SAT uses the FEL system to accommodate various regimes rather than exempting them:
  • Small Taxpayer Regime: Taxpayers under the simplified “Pequeño Contribuyente” regime (who pay a flat percentage of gross sales in lieu of standard VAT accounting) were initially allowed to adopt FEL voluntarily with incentives (see Section 11), and as of 2023 they are fully required to use e-invoicing. These small taxpayers have their own DTE document types (e.g. “Small Taxpayer Invoice”) and must issue electronic invoices for their sales, even though they pay VAT at a simplified rate and do not generate input VAT credits for customers. [ivacalculator.com], [global.ecovis.com] [sovos.com], [sovos.com]
  • Primary/Agricultural Producers: In 2024, Guatemala passed Decree 31-2024 to integrate small agricultural and livestock producers into the formal tax system. This includes new special taxpayer regimes (with simplified tax on gross sales) and new DTE types for farmers and ranchers (e.g. Primary Regime Taxpayer Invoices FARP/FCRP and Livestock Regime Invoices FPEC/FCPC). These producers must use FEL for their sales, but their invoices carry special tax treatments (e.g. no VAT charged on these regimes’ sales). The FEL system ensures such invoices include proper indicators and mandatory phrases to reflect their special VAT status (e.g. noting that no VAT credit is granted to the buyer). [edicomgroup.com], [edicomgroup.com] [lexology.com] [lexology.com], [edicomgroup.com]
  • Other Special Cases: Guatemala does not have EU-style margin schemes (e.g. travel agency or second-hand goods margins) in its VAT law, so there are no unique e-invoice rules for those. However, the SAT has designated some special DTE categories for particular use-cases – for example, a “Special Invoice” (Factura Especial) DTE is used in certain regulated sectors like finance or insurance, and a “Dispatch Guide” (Guía de Despacho) is used as a transport document for goods in transit. These documents are less common but still part of the electronic system. All such special documents are subject to FEL rules and must be electronically certified and reported to SAT just like standard invoices. [ivacalculator.com], [ivacalculator.com]

2. Taxable Persons in Scope

• Resident Businesses: All companies established in Guatemala that are registered for Value Added Tax must issue 100% of their invoices electronically through FEL. This includes those under both the general VAT regime and the small taxpayers regime, as well as taxpayers in special sectors (agriculture, livestock, etc.) as noted above. [ivacalculator.com]
• Non-Resident Registrants: Foreign or non-established entities that are registered for VAT in Guatemala (e.g. through a local tax representative or branch) are likewise required to use the FEL system for any invoices they issue under their Guatemalan tax identification (NIT). The law does not exempt non-resident VAT registrants from the e-invoicing obligation – if they have a Guatemalan tax registration and need to issue tax-compliant invoices for domestic transactions, those invoices must be electronic and channeled through the FEL platform.
• Government Entities as Issuers: Government bodies themselves must use FEL when acting as suppliers in commercial transactions. If a government entity sells goods or provides chargeable services and is required to issue tax invoices, those too would be subject to the e-invoicing rules (the government primarily acts as a buyer in most cases, but when acting as a seller – e.g. state-owned enterprises or certain fee-based public services – FEL would apply).

• Truly Exempt Entities: Entities not required to register for VAT at all (for instance, some non-profits or very small informal businesses below registration thresholds) are outside the scope because they do not have a tax ID or obligation to issue tax invoices in the first place. However, if they conduct taxable transactions, they are expected to register and comply with FEL like any other taxpayer. Overall, there is no blanket exemption for small businesses or sectors – even small-scale traders and professionals are expected to use FEL once registered. (Prior to 2023, small taxpayers were allowed to remain on paper as a temporary measure, but that phase has ended – see Timeline below.) [ivacalculator.com]
• Voluntary Participation: During the roll-out period (2018–2022), taxpayers not yet mandated were permitted to opt in to FEL voluntarily. Many did so, especially after incentives were offered (e.g. a reduced VAT rate for early adopters in the small taxpayer regime). Now that FEL is universal for VAT taxpayers, voluntary participation mainly applies only to newly registered businesses: new VAT registrants must immediately start using FEL upon registration (there is no “grace period” of using paper invoices). [global.ecovis.com], [global.ecovis.com]
• Sector-Specific Rules: Certain sectors have tailored rules without granting full exemption from e-invoicing:
  • Small/Agricultural Producers: As described, Decree 31-2024 created simplified regimes for small agricultural producers, but these participants are still required to use FEL (with specialized invoice types and without charging VAT). [lexology.com]
  • Exporters: Must use FEL for exports; however, when goods are in the process of export and final confirmation is pending, exporters can issue a provisional e-invoice (FACP) to satisfy immediate compliance needs. [edicomgroup.com]
  • Unregistered Suppliers: As noted, when buying from individuals or entities not in the tax system, the registered buyer must issue a self-billed Special/Specific Invoice through FEL (with tax withholding) to document that purchase. [edicomgroup.com]

3. Implementation Timeline

• 2011–2018 — Early E-Invoicing Initiatives: Guatemala first experimented with electronic invoicing in 2011 via the FACE system (Factura Electrónica)*. This was an initial platform allowing voluntary e-invoices, but it was superseded by a more advanced system. In 2018, SAT introduced the Online Electronic Invoice Regime (FEL) as the new national e-invoicing model, via SAT Board Agreement No. 13-2018, effective May 23, 2018. This established the legal framework for FEL, aiming to modernize tax administration and phase out paper invoices. [en.portal.sat.gob.gt]
• 2019 — Gradual Rollout Began: Starting in 2019, SAT began migrating select taxpayer groups to FEL. During this period, certain large taxpayers and specific sectors were designated to implement e-invoicing on a mandatory basis, while others were encouraged to join voluntarily. For example, SAT issued Resolution 243-2019 (for government contractors in procurement processes) and Resolution 838-2019 (for individual professionals providing services to government) requiring those suppliers to use FEL. Many businesses opted in voluntarily due to the system’s benefits and incentives (including a temporary VAT rate reduction for small taxpayers, per Decree 7-2019). [edicomgroup.com], [global.ecovis.com] [edicomgroup.com] [global.ecovis.com]
• 2020–2021 — Expansion to Large Taxpayers: By 2020, the FEL system was scaling up. In 2021, SAT issued Resolution SAT-DSI-1240-2021 making e-invoicing compulsory for all taxpayers in the General VAT Regime by mid-2022. Large and medium-sized companies, as well as any remaining “special taxpayers” (a category of high-revenue taxpayers specially supervised by SAT), were required to switch to FEL. This period saw aggressive onboarding, with SAT reporting that by late 2022 about 98% of all VAT sales were already invoiced electronically. [lexology.com] [sovos.com]
• July 1, 2022 — Major Compliance Deadline: All standard (general regime) VAT-registered businesses were mandated to use FEL by July 1, 2022. After this date, any pre-authorized paper invoices or other non-FEL documents lost their validity for tax purposes. Businesses were instructed to cancel any unused paper invoice stock, as such documents could no longer be legally issued or used to support VAT credits or expense deductions. There was no additional “grace period” beyond this deadline for large/general taxpayers – failure to transition meant inability to legally issue invoices (effectively halting compliant trading). However, small taxpayers (small businesses under the simplified VAT regime) were temporarily exempted from this 2022 deadline; they were given additional time to join FEL (see below). [lexology.com] [lexology.com], [prensalibre.com] [prensalibre.com], [prensalibre.com]
• April 1, 2023 — Final Phase: Small Taxpayers’ Deadline: The last group to be incorporated were the “Pequeños Contribuyentes” (small taxpayers), which include many SMEs and micro-businesses. SAT’s Resolution SAT-DSI-1350-2022 required that all small taxpayers still using paper must migrate to FEL by April 1, 2023. This followed a short voluntary/transition period from July 2022 to March 31, 2023 during which small taxpayers could continue using old invoices while they adapted to the new system. By the end of March 2023, over 89% of small taxpayers had already registered on the FEL system, and the remainder were obliged to comply by the April deadline. From that point on, 100% of all VAT-registered taxpayers in Guatemala were issuing electronic invoices, and legacy paper invoices were fully retired. [lahora.gt], [lahora.gt] [global.ecovis.com], [lahora.gt] [lahora.gt]
• Post-2023 Developments: By mid-2023, Guatemala had effectively achieved universal e-invoicing coverage. Moving forward, the government has turned its focus to refinements and sector-specific enhancements rather than new phases of rollout. In May 2023, SAT reported successful full implementation of FEL, and attention shifted to improving the system. In November 2023, SAT proposed FEL 3.0 – a strategic plan to leverage the vast e-invoicing data for smarter compliance (including potential pre-filled returns; see Section 10). [bdo.global], [bdo.global]
• Late 2024 – Special Regimes Law: The Guatemalan Congress passed Decree 31-2024 (published Dec 9, 2024) to integrate primary sector producers into the tax system. This law took effect in February 2025 (60 days after publication). It introduced simplified tax regimes for small agricultural and livestock producers and mandated their use of FEL e-invoicing with new document types and rules (e.g. new FARP, FCRP, FPEC, FCPC DTEs, as noted in Section 1). This marked the final step in bringing essentially all significant economic activities in Guatemala – including previously informal rural producers – into the electronic invoicing net. [prensalibre.com], [prensalibre.com] [edicomgroup.com], [edicomgroup.com]
• 2025 and Beyond: With the legal framework largely in place, 2025 has been focused on consolidation and technical improvements. SAT has not announced any new taxpayer categories or transaction types to be added (as virtually all are already covered). Instead, enhancements like FEL 3.0 (applying AI for compliance and analytics) are being pursued. As of August 2025, SAT reported that 99% of all invoices in Guatemala are electronic, with over 1.3 million registered issuers and 7+ billion DTEs issued cumulatively. No new grace periods or extensions are expected, as the system is fully operational and enforcement has become stricter (see Penalties & Enforcement). [voxelgroup.net] [bdo.global]

4. Technical & Functional Requirements

• Content & Mandatory Data Elements: Every DTE (invoice or related document) must include a comprehensive set of data fields mandated by SAT. This includes standard invoice information (supplier and customer details, tax ID/NIT numbers, addresses, dates, description of goods/services, quantity, unit price, VAT amount, totals) as well as specific codes and references required by the FEL system. For instance, each electronic invoice is assigned a unique authorization code (UUID) upon certification. Sequential invoice numbering is managed through these electronic authorizations rather than pre-printed invoice numbers, ensuring uniqueness and traceability. Additional fields or “Add-ons” are required in particular scenarios, such as exports (as noted, fields for expedition place and consignee country) or references on credit notes (linking to the original invoice’s UUID). The technical specifications and validation rules for all data fields are published by SAT (e.g. allowable characters, field lengths, formats) in the official FEL technical documentation and schema definitions. If any required field is missing or fails validation, the invoice will be rejected by the certifier or SAT systems and considered not legally issued. [ivacalculator.com] [edicomgroup.com] [en.portal.sat.gob.gt], [en.portal.sat.gob.gt]
• Digital Signatures & Integrity: Each DTE must be digitally signed with an advanced electronic signature to guarantee its authenticity and integrity. The FEL system requires the use of government-authorized digital certificates. In practice, the certifying provider applies the digital signature to the XML when it validates the document. The digital signature and a cryptographic hash (the UUID) are embedded in the XML, ensuring that any alteration of the data would invalidate the signature. This mechanism provides non-repudiation (the sender cannot deny authorship) and guards against invoice tampering. Data integrity and authenticity are therefore legally assured for all e-invoices, as required by Guatemala’s e-invoicing regulations. [edicomgroup.com] [ivacalculator.com]
• Validation Rules: Before an invoice is considered valid, it undergoes two layers of validation:
  1. Pre-validation by a Certifier: The DTE XML is first transmitted to an authorized Certifying Entity (Proveedor de Certificación) which performs automated checks per the FEL validation rules set by SAT. These rules cover both technical format (XML schema compliance) and tax/business logic (e.g. verifying that numeric fields are correctly calculated, required data is present, NIT numbers are valid, product codes or tax rates are permissible, etc.). The certifier ensures the invoice meets all requirements. If compliant, the certifier applies its digital signature and assigns the unique Electronic Authorization Code (CAE/UUID), effectively “certifying” the invoice. If any rule is broken, certification is denied and the invoice is rejected with an error code, prompting the issuer to correct and re-submit. [edicomgroup.com]
  2. SAT Validation: Once certified, the invoice is automatically forwarded to the SAT by the certifier’s system. The SAT performs its own validations (largely to double-check authenticity and compliance). Generally, if the certifier has approved the DTE, SAT’s acceptance is a formality; however, SAT may still reject an invoice (for example, if the seller’s tax account is inactive or other compliance issues are detected). In practice, SAT issues an acknowledgment of receipt to confirm the DTE is accepted into the central system. This acknowledgment is also stored by the certifier and should be kept by the issuer as proof of acceptance. [sovos.com] [edicomgroup.com]
• E-Reporting and Real-Time Transmission: Guatemala’s model is a clearance e-invoicing system with real-time reporting to the tax authority. A DTE must be issued and cleared essentially in real-time before it can be delivered to the buyer. In practical terms, this means as soon as a seller creates an invoice in their system, it is sent via API or web portal to a certifier and then immediately relayed to SAT for approval. The buyer’s PDF or XML invoice copy is only issued after this approval. The FEL platform thereby serves as a central clearance platform: all invoices flow through it, ensuring SAT has a live feed of transaction data for tax control. There is no separate periodic “e-reporting” form for individual transactions in Guatemala – the clearance of each DTE in real time is the reporting mechanism, and SAT has stated that no additional transactional report (e.g. monthly invoice listing) is required beyond the electronic invoices themselves. (Taxpayers do still submit monthly VAT returns via the Declaraguate system, but the expectation is that invoice data in FEL will be used to cross-check those filings.) [openenvoy.com] [sovos.com] [voxelgroup.net]
• Data Model & Standards: The FEL XML schema is unique to Guatemala. It is not based on UBL or PEPPOL BIS, but rather a custom “GT DTE” schema defined in Spanish by SAT’s technical documentation. This schema outlines the structure for elements like invoice identification, supplier/buyer info, tax details, and any complements (add-ons). While not a PEPPOL standard, the FEL system performs a similar function to an electronic data interchange: larger taxpayers often integrate their ERP systems via APIs to the certifiers/SAT so that invoices are generated and sent automatically in XML format. Smaller businesses have the option to use manual entry on a web portal or mobile app, which internally generates the compliant XML (the user doesn’t see the code) and routes it for certification. Thus, companies can comply without in-depth XML knowledge, although software developers working with FEL must follow the SAT’s XML schemas and WSDL (web service definitions) provided in the technical docs. [en.portal.sat.gob.gt] [lahora.gt], [lahora.gt]

5. Transmission & Workflow

• 1. Invoice Generation: The taxpayer (seller) prepares an invoice using an electronic system – this could be their own ERP/accounting software integrated with FEL or the SAT’s provided online portal or FEL mobile app for smaller businesses. The invoice data is structured in the required XML format and electronically signed by the issuer (or by the certifier on the issuer’s behalf) using a government-authorized digital certificate. [lahora.gt] [edicomgroup.com]
• 2. Submission to Certifier: The invoice (DTE) is transmitted to an authorized Certifier (Proveedor de Certificación). Large companies typically work with a certified service provider (CSP) or integrate via API to a certifier service for automated submission. Small taxpayers have the option to use the SAT’s free “Virtual Agency” web platform or FEL mobile app, where the role of certifier is handled by the SAT’s system at no cost. [voxelgroup.net], [voxelgroup.net] [voxelgroup.net], [lahora.gt]
• 3. Certification & Authorization: The certifier’s system validates the invoice against all technical and tax business rules (as described above in Section 4). If compliant, the certifier digitally signs the DTE and assigns it a unique electronic authorization code (often called CAE or UUID). This step effectively “clears” the invoice. The certified invoice (now an official tax document) is automatically transmitted to the SAT by the certifier’s platform in an XML message, and simultaneously returned to the seller for distribution to the buyer. At this point the invoice is considered issued. [edicomgroup.com] [sovos.com]
• 4. SAT Acknowledgment: Upon receiving the certified DTE, SAT performs final checks and issues an acknowledgment (acceptance or rejection) back to the certifier. In normal operation, if the certifier has authorized the invoice, SAT’s acknowledgment is a confirmation that the invoice is recorded in the central system. The certifier relays any error or acknowledgment messages back to the issuer. (Rejections at this stage are rare but could occur in special cases – e.g., if the seller’s tax account is invalid or the DTE duplicates an existing number). [edicomgroup.com]
• 5. Delivery to Buyer: After certification (and typically after SAT’s acceptance), the issuer must deliver the e-invoice to the customer. This is usually done by sending the XML file plus a human-readable representation (often a PDF rendering) to the buyer. The law allows a PDF or printed copy as a representation of the invoice for record-keeping, but the controlling record is the electronic XML data. Buyers can also verify any invoice’s authenticity by checking it on the SAT’s online portal using the invoice’s unique code. [edicomgroup.com]

• Immediate Clearance: In practice, the clearance steps (issuer → certifier → SAT) happen within seconds or minutes. Invoices must be cleared essentially in real time before being issued to the buyer. There is no legal allowance for long delays—for example, issuing an invoice “T+1 day” after the transaction is generally not permitted. The invoice should be generated and submitted at the time of the transaction (or very shortly after) so that SAT’s confirmation is received essentially on the transaction date. This is critical because Guatemala’s VAT law requires invoices to be issued at the time of sale or service completion; under FEL, that means the electronic process must be completed when the taxable event occurs. [openenvoy.com], [sovos.com] [lexology.com]
• Monthly Summaries: Unlike some countries, Guatemala does not require monthly SAF-T or invoice summary reports for transactions. Because every individual invoice is already reported in real time, the tax authority does not mandate additional e-reporting of the same data. Businesses do continue to file monthly VAT returns (Form SAT-2237) via the Declaraguate system, but the expectation is that the detailed figures (total sales, tax collected, etc.) in those returns should align with the sum of the individual e-invoices recorded in FEL. SAT can cross-verify the return against the universe of DTEs in their system and will likely flag discrepancies as part of their new automated controls. In this sense, the FEL data itself serves as the source for periodic tax reporting, and future enhancements are expected to further integrate or even pre-fill tax return forms (see Section 10 on Pre-Filled VAT Returns). [voxelgroup.net] [bdo.global]
• Invoice Corrections & Cancellations: The FEL system includes authorized document types for adjustments, such as Credit Notes (Nota de Crédito) to cancel or reduce an invoice amount, and Debit Notes to increase an invoice amount. These must reference the original invoice’s UUID and are also issued and cleared through the same workflow. If an invoice needs to be voided (cancelled) after issuance, the issuer must initiate a cancellation through the SAT Virtual Agency portal; importantly, cancellations are time-bound – an e-invoice can only be cancelled within the period of the corresponding tax return (i.e. by the end of the filing period for the month of issuance). This rule prevents abuse (e.g., retroactively voiding invoices beyond the allowed window). All cancellations are logged in the FEL system (with a specific “DTE override” schema) for audit purposes. [ivacalculator.com] [lexology.com], [lexology.com] [en.portal.sat.gob.gt]

• Certified Service Providers (CSPs)/Certifiers: These are private companies authorized by SAT to act as digital certification intermediaries. They receive the invoice data, validate it, apply digital signatures, and forward it to SAT. Businesses may choose a CSP for value-added services (integration with their systems, support, etc.). Certifiers must renew their licenses yearly with SAT and adhere to strict security and performance standards. [edicomgroup.com]
• SAT’s Free System for Small Taxpayers: Recognizing the importance of SME inclusion, SAT provides a no-cost option: small taxpayers can use the “Agencia Virtual” web interface or the FEL mobile app to create and issue compliant e-invoices without needing a paid provider. In this case, SAT itself functions as the certifier at no charge, and as of 2023 the vast majority (over 90%) of small taxpayers use the free SAT certifier service. This dual approach (private certifiers for high-volume businesses and a free government platform for others) has been key to achieving near-total adoption. [lahora.gt] [ivacalculator.com]

6. Self-Billing

• Workflow: The buyer preparing a self-billed invoice will use their FEL access (either via their own software or the SAT portal) to enter the transaction details and the supplier’s information, and then submit the DTE for certification normally. Once certified and accepted by SAT, the buyer must provide a copy of the electronic invoice (or its printed/PDF representation) to the supplier for their records. The DTE will be stored by SAT and is accessible to both parties via the tax authority’s systems. [edicomgroup.com]
• Buyer’s Additional Obligations: When using a self-billing invoice in Guatemala, the buyer is responsible for ensuring all required fields and tax withholdings are correctly applied. In particular, a 1.5% income tax withholding is mandated on self-billed “Specific Invoices” (FEPE). This means the buyer must withhold 1.5% of the gross amount as a tax prepayment on behalf of the seller. The withheld amount is later paid to SAT (usually as part of the buyer’s routine tax remittances), and the invoice should indicate the withholding. Aside from this, self-billed invoices follow the same content rules as other DTEs. The buyer should also secure the seller’s acceptance of the self-billing arrangement, although in practice this is standard when dealing with a supplier who cannot legally issue invoices. [edicomgroup.com]
• Platform and Approval: The FEL platform handles self-billed invoices without special separate procedures – the buyer selects the appropriate DTE type (FEPE/Special Invoice) in their e-invoicing system. The invoice is then processed by the certifier and SAT just like any other, and SAT’s validation ensures, for example, that the scenario fits (e.g. the supplier is indeed not an active FEL issuer). The self-billed invoice must include a legend or “mandatory phrase” indicating it was issued by the buyer for a non-invoicing seller, to make the nature of the document clear to any reviewer. [edicomgroup.com]
• Downstream Processes: From a VAT reporting perspective, a self-billed Special Invoice allows the buyer to claim a tax credit (input VAT deduction) if the purchase is creditable – because the FEL system treats it as if an invoice was issued, now captured in SAT’s records. The 1.5% withholding acts as an income tax advance for the seller. The seller, if later registering as a taxpayer, could see those self-billed invoices in their account. Importantly, self-billing is only allowed in the limited circumstance of purchases from non-registered persons; businesses cannot simply choose to self-bill each other outside of this context. All regular B2B transactions between registered taxpayers require the supplier to issue the DTE.

7. Triangulation & Special Scenarios

• Triangulation Transactions: In typical triangulation (three-party) transactions, each leg involving a Guatemalan VAT-registered entity must be invoiced via FEL. The law does not provide an exception where one invoice covers a multi-leg chain; thus, if company A sells to B, and B resells to C, both the A→B and B→C transactions require their own DTEs (even if A delivers directly to C). Each sale is treated independently for VAT and invoicing purposes. There is no special triangulation DTE type; the standard invoice (or export invoice, if one leg is an export) is used for each sale. All general FEL rules (timing, content, etc.) apply to each transaction in the chain. This ensures that VAT obligations (or zero-rating, if applicable) are properly accounted for at each step.
• Chain Transactions: Similarly, chain or drop-shipment scenarios are handled with the existing DTE types. Guatemala does not have a concept of a “chain invoice” that covers multiple transfers of ownership. Instead, every time a taxable transfer of goods or services takes place involving a Guatemalan taxpayer, a FEL invoice must be issued. In cases where an intermediate seller in the chain never takes title (e.g., acting as an agent or commissionaire), a commission invoice or service invoice might be used for their fee, but again this would be an electronic DTE subject to FEL rules. The overarching principle is that all taxable events must be documented by a FEL-compliant electronic document in real time, regardless of complexity or sequence of the transaction.
• Cross-Border Scenarios & Reverse Charge: For cross-border services received from abroad (where a Guatemalan company is the buyer and no Guatemalan VAT is charged by the foreign supplier), Guatemala’s VAT law may require the buyer to account for VAT via reverse charge (self-assessment). However, these imports of services are not handled via the FEL e-invoice system because the foreign supplier cannot issue a Guatemalan DTE. Instead, the VAT is reported directly in the monthly VAT return by the local company (and paid to SAT), and the supporting documents remain the foreign supplier’s invoice plus proof of the tax self-assessment. There is currently no separate e-reporting form for services imports beyond the VAT return. (If the law ever required a formal self-billed invoice for services imports in the future, it would likely be done through a DTE type, but as of the latest regulations this is not the case.)
• Zero-Rated & Exempt Supplies: Zero-rated sales (e.g. exports) and VAT-exempt transactions are still required to be issued as DTEs; the FEL system handles these via special indicators and “frases” (notations). For instance, an export invoice is marked with the export complement and typically shows the 0% VAT rate applied to the sale. Domestic exempt supplies (if any, such as certain essential goods or specific transactions not subject to VAT) will be invoiced in FEL with the tax amount as 0 and a mandatory phrase indicating the legal basis for exemption. This ensures that the buyer cannot claim VAT credit on exempt or zero-rated purchases, since the DTE itself carries the information that no VAT was charged. In the new primary producer regimes (created by Decree 31-2024), invoices are technically exempt from VAT (those farmers pay a flat gross sales tax instead); accordingly, their DTEs do not show VAT and must include a legend stating that no VAT credit is granted on those sales. [edicomgroup.com] [lexology.com]
• Special Invoicing Scenarios: Guatemala has introduced a few special DTE types to cover transactions that don’t fit the standard sale/purchase model:
  • A “Special Invoice” (Factura Especial) DTE exists for certain purchases from sectors or persons who are exempt or not required to invoice. (This term is sometimes used interchangeably with the Specific Invoice (FEPE) described under self-billing – both refer to buyer-issued invoices for purchases from non-invoicing sellers, with the 1.5% tax withholding.) [edicomgroup.com]
  • A “Dispatch Guide” (Guía de Despacho, ADES) is an electronic document for goods in transit (logistics purposes). It’s not a tax invoice but is issued through the FEL system to accompany the transport of goods and ensure traceability of movements. [ivacalculator.com]
  • An “Exchange Invoice” (Factura Cambiaria) is an invoice that carries the legal status of a negotiable instrument (title of credit). It is used for sales on credit to provide the seller with stronger legal recourse for collection. This is also a DTE and is common in B2B transactions where payment is deferred. [sovos.com], [ivacalculator.com]
  All these documents are integrated into the FEL framework and follow the same certification and archiving requirements as regular invoices. In summary, the FEL system is comprehensive and flexible, aiming to encompass all billing scenarios within a single electronic compliance umbrella rather than requiring separate reporting outside the system.

8. Archiving & Retention

• Retention Period: Electronic invoices (DTE XML files) and related acknowledgments must be stored for at least four (4) years, which is the standard statute of limitations for tax purposes in Guatemala. This 4-year period is defined in the Tax Code (Código Tributario). The retention clock typically starts from the date of the invoice or the end of the fiscal year of issuance, aligning with the general requirement to keep all tax documentation for four years. [sovos.com], [voxelgroup.net]
• Format and Accessibility: The law requires that invoices be preserved in their original electronic format (XML) to maintain the digital signature and integrity of the data. Taxpayers (both issuers and recipients of DTEs) should ensure they have a reliable digital storage solution for these XML files and the corresponding SAT receipts/acknowledgments. While SAT itself retains a centralized copy of all certified DTEs on its servers, this does not exempt businesses from maintaining their own archive. Both sellers and buyers must be able to produce the original electronic invoice files (with their metadata and signatures intact) upon request by tax auditors. Acceptable storage can be on local servers or cloud storage, as long as data is secure, remains unaltered, and can be reproduced in a legible format for an audit. In practice, many companies rely on their certifier’s solutions or the SAT’s systems for storage, but ultimate responsibility to ensure availability lies with the taxpayer. [edicomgroup.com] [sovos.com]
• Integrity & Authenticity during Retention: Because each DTE is digitally signed by the certifier, any change to a stored XML would invalidate the signature. Therefore, businesses must store DTEs without modification to preserve their legal integrity. The requirement to keep the SAT’s acknowledgment of receipt is also important – it proves the invoice was accepted into the official system, so taxpayers should retain those confirmation receipts alongside the invoice XML. Both the invoice and the acknowledgment may be needed if contesting any audit issue. [sovos.com]
• Domestic vs. Cross-Border Storage: Local storage of invoices is standard (there is no explicit requirement to store the data on Guatemalan soil, but data protection laws apply if stored abroad). Since SAT already has a copy of all DTEs, storing data in Guatemala is less of a concern from a regulatory perspective, but companies should ensure that their storage location complies with any data security and privacy rules. Cross-border data transfer for storage (e.g., using an international cloud service) is not specifically prohibited in the FEL regulations. The key is that the invoices remain available and intact.
• Audit Access: Tax auditors and SAT officials have the right to access and review electronic invoices during audits or verification processes. The FEL system actually gives SAT direct access to all DTEs (since they are centrally stored), which simplifies auditing – an auditor can retrieve the needed records from the SAT database. However, the taxpayer must still be able to provide supporting documentation if required, such as proof of delivery, or additional records, in case the audit extends beyond just the invoice (e.g., contracts or purchase orders). Ensuring that electronic invoices are readable (human-readable format) and printable throughout the retention period is also part of compliance; typically, taxpayers store not only the raw XML but also PDF rendered versions for convenience.

9. Penalties & Enforcement

• Enforcement Approach: Guatemala’s SAT has coupled the e-invoicing mandate with stringent enforcement measures to ensure compliance. Penalties can be both monetary fines and administrative actions (like blocking a business’s ability to operate). Key enforcement points include:
• Failure to Issue E-Invoices: Once a taxpayer is designated to use FEL (which now includes all VAT taxpayers), issuing a non-electronic invoice when you are required to use FEL is an offense. The Tax Code provides for a fine of GTQ 100 (Guatemalan quetzales) per paper invoice issued in violation of the mandate. In other words, if a business continues using pre-printed paper invoices or other non-FEL documents after their mandated transition date, each such document can trigger a Q100 (~USD 13) penalty. Additionally, those paper invoices are considered invalid for VAT credit or tax deduction purposes by buyers, which can lead to further repercussions (e.g., the seller’s clients might refuse the invoices since they cannot use them in their VAT accounting). [lahora.gt] [lexology.com]
• Late Adoption of FEL: Simply failing to register for FEL by the deadline itself did not carry a separate one-time fine; however, as noted, the practical impact was that any continued business invoicing would inherently violate the rules and rack up per-invoice fines. SAT’s guidance indicated that taxpayers who missed the cutoff would find their previous invoicing authorizations revoked. Such taxpayers would be marked as “renuentes” (non-compliant/reluctant) in SAT’s system, effectively disabling their ability to issue valid invoices until they complied. In essence, not adopting FEL meant a business could not legally invoice its customers, amounting to a de facto business suspension until compliance was achieved. [prensalibre.com] [prensalibre.com], [prensalibre.com] [lahora.gt]
• Incorrect E-Reporting or Data Errors: The FEL system’s validation process is designed to catch errors in real time (at the point of invoice issuance). If an invoice fails the automatic validation, it is simply not certified – so there is technically no “late or incorrect e-reporting” penalty, because an incorrect invoice never becomes a legal document. However, if a taxpayer somehow manipulates or bypasses the system to under-report transactions (for example, by not issuing invoices for some sales), normal tax evasion penalties would apply. SAT’s use of FEL data allows it to detect discrepancies between reported sales/purchases and FEL records quickly, so undeclared transactions can lead to audits and sanctions under general tax fraud provisions. There are also penalties for altering or forging electronic invoices, which would constitute serious tax fraud. [bdo.global]
• Non-Compliance with Platform Requirements: Using the FEL platform is itself required by law, so attempts to avoid it are penalized. For instance, if a taxpayer’s digital certificate expires or is misused (jeopardizing the integrity of their e-invoices), SAT may consider invoices issued under that lapsed certificate as non-compliant. Similarly, if a business does not maintain the required internet connectivity or systems to issue FEL invoices, it is effectively the same as failing to issue invoices. In short, any scenario where a taxpayer does not properly issue a required DTE can trigger sanctions. As of now, there are no known penalties specific to using the FEL technical platform incorrectly – the penalties tie back to the tax law obligations (issue invoices on time, with correct details, and preserve them).
• Archiving Violations: Guatemala’s Tax Code and related SAT norms also penalize failure to keep required records. Not preserving invoices or related records for the 4-year retention period can result in fines. The Tax Code (Article 94) establishes penalties for “lack of accounting books or records” and for not retaining invoices or making them available to auditors. These fines can vary in amount (often a fixed monetary penalty per missing document or per audit obstruction). While exact figures for archiving violations are defined in tax rules (and subject to updates), taxpayers should assume that inability to produce a requested DTE or its digital acknowledgment during an audit could result in penalties similar to those for missing invoices or records.
• Negligence vs. Fraud: Guatemalan tax law distinguishes between good-faith mistakes (negligence) and willful tax evasion. Minor issues (e.g. accidentally using a wrong code on an invoice that is then corrected) are generally just administrative offenses (fines). However, deliberate non-compliance – such as persistently failing to invoice sales to evade tax – can lead to more severe consequences, including large fines, interest on unpaid taxes, and even criminal tax fraud charges if tax evasion is proven. SAT’s new electronic audit tools can automatically flag suspicious patterns (for example, a business issuing a year’s worth of invoices but reporting zero sales in VAT returns). Under Decree 31-2024’s reforms to the Tax Code (in force 2025), SAT now has expanded powers: it can suspend a taxpayer’s ability to issue FEL invoices if the taxpayer fails to file VAT returns, or files 12 consecutive months of zero-sales returns without a convincing reason. This effectively freezes the business’s operations until the issue is resolved. The suspension is lifted once the taxpayer rectifies their filings or resolves the inconsistencies. These measures underscore that e-invoicing data is now central to tax enforcement – non-compliance not only leads to fines but can directly interrupt a company’s capacity to do business. [prensalibre.com], [prensalibre.com]
• Other Penalty Provisions: Additional penalties can apply for related non-compliance, such as failing to cooperate with SAT’s invoice verification processes or breaching security requirements. For example, certifiers have compliance requirements and could lose their authorization if they fail to meet SAT’s standards. Taxpayers that knowingly use an unauthorized certifier or tamper with the FEL system would likewise be subject to penalties under general tax fraud or IT crime statutes. However, the most common penalties in practice are the Q100 per document fine for improper invoices and the potential suspension of operations for unresolved compliance failures. [edicomgroup.com]

10. Pre-Filled VAT Returns

• FEL Data for Declarations: Since FEL now captures nearly all invoice data in real time, the SAT can leverage this information to assist with return preparation. Indeed, one of the stated objectives of the FEL system is to facilitate tax compliance by integrating with VAT declarations (“Planilla IVA-FEL”). In practice, taxpayers can already access reports of all their sales and purchase invoices through the SAT’s online system. These can be used to help populate VAT return figures, though currently the taxpayer still must compile and submit the final numbers. [ivacalculator.com]
• FEL 3.0 and Auto-Filling Initiative: SAT’s upcoming “FEL 3.0” modernization (planned as of late 2025) explicitly includes the implementation of AI to assist in auto-filling tax forms. This indicates that pre-filled VAT returns are on the horizon. The idea is that SAT would use the data from FEL to pre-populate portions of a taxpayer’s VAT return (for example, total reported sales, tax collected, deductible purchases, etc.), allowing taxpayers to simply verify and adjust the figures before submission. This would be analogous to trends in some other countries where electronic invoice data is used to draft tax returns for the taxpayer’s approval. As of December 2025, this feature was still in development, but SAT’s strategic plan for 2025–2030 prioritizes such data-driven services to enhance compliance and ease filing burdens. [bdo.global] [bdo.global], [bdo.global]
• Scope of Prefilled Data: It is expected that if pre-filled VAT returns are implemented, they will rely primarily on sales (output tax) data from FEL invoices. This could cover fields like gross sales, taxable sales, exempt sales, and VAT collected in the period. However, taxpayers might still need to input certain data manually, such as any adjustments, credits not derived from purchase invoices (e.g. import VAT paid to customs), or other non-invoiced transactions. Until such services are live, taxpayers should reconcile their FEL records with their declarations each month. The SAT already utilizes FEL data behind the scenes to cross-check compliance (for instance, to ensure a business’s sales in FEL match what they declare in their VAT return), which is a precursor to fully automated return preparation. [bdo.global]
• No Pre-Populated Returns Yet: In summary, Guatemala does not yet have pre-populated VAT returns available to taxpayers as of 2026, but plans are underway to implement this. Taxpayers must continue to file their own returns, using FEL data as a tool for accuracy. Any future prefill system would likely still require the taxpayer to review and confirm the information, given that certain tax computations (like pro-rating credits for mixed-use inputs, or declaring imports or special regime sales) may need additional input. Keep an eye on SAT’s announcements for pilot programs or official launch of a prefilled return system in the coming years.

11. Impact on SMEs and Startups

• Universal Compliance with Some Phasing and Support: Unlike some countries that exempt the smallest businesses from e-invoicing, Guatemala’s FEL eventually included all VAT-registered entities, regardless of size. However, the government did implement a phased approach and support measures for SMEs: [ivacalculator.com]
  • Phased Rollout for Small Taxpayers: SMEs under the Pequeño Contribuyente regime were among the last to be mandated to join FEL, giving them extra time (until early 2023) to prepare. This phase-in constituted a de facto grace period for small businesses, during which many voluntarily adopted FEL. [lahora.gt]
  • Incentives for Early Adoption: To encourage small businesses to go digital, Decree 7-2019 provided a temporary VAT rate reduction (from 5% to 4% on gross sales) for small taxpayers who opted into FEL early. This financial incentive, along with outreach and training, spurred tens of thousands of SMEs to transition prior to the final deadline. [global.ecovis.com]
  • Free Government Platform: The SAT offers a free e-invoicing tool (Agencia Virtual web portal and a FEL mobile app) specifically to support small businesses and individuals issuing low volumes of invoices. This eliminated the need for SMEs to purchase expensive software or hire service providers. As a result, over 92% of small taxpayers use the free SAT certifier service instead of paying for a private certifier. Essentially, the government shoulders much of the technical burden for smaller firms, which has been critical in achieving widespread compliance. [lahora.gt] [ivacalculator.com]
• Operational Impact and Costs: For many SMEs, the cost of compliance has been manageable, in part due to the SAT’s support:
  • Technology and Software: SMEs that issue only a few invoices per month can use the SAT’s online system at no cost, minimizing the need for significant IT investment. Those with higher volume may choose to acquire software or integrate their systems with a certifier’s API, which can involve some upfront costs for software or development. On the whole, the availability of a free solution means even micro-businesses can comply without purchasing software licenses or paying ongoing fees, aside from maintaining an internet connection. [lahora.gt]
  • Process Changes: Administrative processes for SMEs have become more digital. Paper invoice booklets, which used to be purchased and stamped by tax authorities, are no longer needed, saving printing costs and trips to tax offices. Instead, businesses might need to invest time in learning the new system or adapting their workflow. SAT and various industry groups have offered training and educational materials to help in this transition. [global.ecovis.com]
  • ERP/Systems Changes: Startups and growing businesses may need to adapt their sales and accounting systems to either use the SAT portal or to integrate with certified providers. While large companies often have IT teams to handle this, for smaller companies this has required hiring IT support or using third-party solutions, representing a new cost. However, local software vendors and service providers (including banks and accounting software companies) have begun offering affordable FEL-compatible tools aimed at SMEs, and some accounting software used by SMEs have added FEL integration at little or no extra cost as part of their services.
• Administrative Burden vs. Simplification: There is an initial learning curve, but once implemented, e-invoicing can actually simplify tax compliance for small businesses:
  • Automatic Record-Keeping: With FEL, SMEs no longer need to maintain physical invoice books or manually report each invoice in a monthly ledger – the system automatically captures all sales. This can reduce human error and streamline bookkeeping. Many SMEs appreciate that filing VAT returns is easier when all sales are recorded in one system that can be cross-checked and downloaded for reference. [ivacalculator.com]
  • Faster VAT Processes: Because invoices are reported in real time, issues like lost invoices or delayed reporting of purchases are reduced. VAT credit claims can be verified more quickly by SAT, potentially speeding up processes such as VAT refunds or reducing audits. (For instance, the FEL data allows SAT to see if a purchase invoice was issued and is valid when an SME claims input VAT, which may reduce the need for that SME to submit physical copies of invoices for verification.)
• Cash Flow Effects: The immediate reporting of sales means that output VAT obligations are immediately visible to SAT, which may discourage under-reporting but also means businesses must be prepared to remit VAT on each sale promptly. This could theoretically have cash-flow implications (no more delaying recognition of sales). On the positive side, real-time invoicing could help cash flow through faster payments: some large buyers in Guatemala only accept FEL invoices now, and suppliers are paid faster when they issue compliant electronic invoices because buyers can reclaim VAT and record expenses without delay. Overall, the systematic discipline of FEL pushes SMEs toward more timely financial record-keeping, which can improve financial management and access to credit (as banks may accept electronic records as proof of income). [sovos.com], [sovos.com]
• Market & Competition Impacts: The universal adoption of e-invoicing has effectively raised the digitalization baseline for doing business in Guatemala:
  • Early Adopter Advantages: SMEs that transitioned early to FEL often report improvements in internal processes – e.g. less paperwork, easier tracking of sales, and improved accuracy. Early adopters gained experience that may give them a competitive edge in efficiency and compliance. On the other hand, businesses that delayed faced stress around the deadline and risked disruptions if they didn’t adapt in time.
  • Interoperability Challenges: Some very small businesses that previously operated entirely on paper had to adapt to using digital platforms. This was a challenge for those with limited internet access or technical skills. The government’s mitigation has been the free, user-friendly portal and even the option to use the system via smartphones (the FEL mobile app) to reduce the need for computers or complex setups. [lahora.gt]
  • Digital Divide: Despite high adoption, there remain concerns about those in areas with limited connectivity (such as rural regions). The inclusion of agricultural producers in 2024 (via Decree 31-2024) acknowledged these challenges by simplifying their tax regime, but still requires them to use FEL. The government may need to provide further support (like rural training or offline options) to ensure these smallest producers can comply. Notably, Decree 31-2024 made FEL registration mandatory for farmers in the new regimes and even requires geolocation data for certain businesses, indicating a push to register and monitor remote economic activities. [lexology.com]
  • SME Readiness Assessments: Guatemalan authorities and industry groups have generally considered the FEL rollout a success in terms of SME inclusion. By mid-2023, SAT reported essentially full coverage of small taxpayers in the system. International observers note that Guatemala’s experience – using incentives and free tools – is often cited as a model for successful SME e-invoicing implementation in the region.

12. Official References

• SAT Government Resources:
  • SAT Portal – Online Electronic Invoice (FEL) Homepage: Official SAT page introducing the FEL regime, its legal basis (Board Agreement 13-2018), and main features. (Available in Spanish and English on the SAT website.) [en.portal.sat.gob.gt]
  • SAT Technical Documentation for FEL: Repository of technical and legal guidelines for FEL, including process descriptions, validation rules, data schemas, and integration guidelines. This is essential for IT professionals and certifiers working with the FEL system. [en.portal.sat.gob.gt]
  • Decree 31-2024 – “Ley para la Integración del Sector Productivo Primario y Agropecuario”: The official law (Spanish) that, among other things, amends tax and e-invoicing rules for small agricultural producers. Published in the official gazette on Dec 9, 2024, effective Feb 2025. [prensalibre.com], [lexology.com]
  • SAT Resolutions SAT-DSI-1240-2021 & SAT-DSI-1350-2022: Key SAT directives (Spanish) that expanded mandatory FEL usage to all VAT taxpayers (the former required general regime taxpayers to join by Jul 1, 2022; the latter extended the mandate to small taxpayers by Mar/Apr 2023). These were published in the Diario de Centro América (official gazette) in late 2021 and 2022 respectively. [lexology.com] [lahora.gt]
• Legislation & Official Gazette Notices:
  • Board Agreement 13-2018: Original SAT Board of Directors Agreement establishing the FEL System in 2018. Forms the legal foundation of Guatemala’s e-invoicing regime. [en.portal.sat.gob.gt]
  • Tax Code (Decreto 6-91) – Article 94: Contains general penalty provisions for tax document compliance, including fines for improper invoicing and record-keeping. [lahora.gt]
  • VAT Law (Decreto 27-92): The primary legislation on Value Added Tax in Guatemala, which has been amended to accommodate electronic invoicing. For instance, it specifies the obligation to issue invoices at the time of sale and recognizes electronically issued DTEs as equivalent to paper invoices for legal and fiscal purposes. [lexology.com]
• Guidance & Analysis by Professional Firms:
  • EDICOM White Paper (May 2025) – “How to Comply with Electronic Invoicing in Guatemala and the FEL System”: A detailed English-language overview of Guatemala’s FEL requirements and processes by a global e-invoicing solution provider. Covers the evolution from FACE to FEL, how invoices are issued and validated, who must comply, and recent updates (e.g. export invoices and new regimes). [edicomgroup.com], [edicomgroup.com]
  • Sovos Insights (Dec 2022) – “E-invoicing in Guatemala – Mandatory from 2023”: A concise summary by tax technology firm Sovos, confirming the April 2023 mandate for all VAT-registered businesses and describing the clearance model and archiving rules. [sovos.com], [sovos.com]
  • VATUpdate.com Brief (May 2025) – “How the Online Electronic Invoice Regime – FEL of Guatemala works”: Short article highlighting Decree 31-2024’s changes for primary producers and summarizing key features of the FEL system (e.g. mandatory e-signature, centralized storage, July 1, 2023 full implementation date). [vatupdate.com], [vatupdate.com]
  • Lexology Article by Arias Law (June 2022) – “Guatemala – Electronic Invoice Regime (FEL)”: Legal perspective on the 2022 mandate, confirming the end of paper invoice validity after July 1, 2022 and discussing requirements for DTE validity. [lexology.com], [lexology.com]
  • Prensa Libre News (Feb 2025) – “Three reasons a taxpayer could be barred from issuing FEL invoices”: Local news piece on the enforcement measures in Decree 31-2024, such as mandatory RTU registration, providing geolocation, and conditions under which SAT may suspend a taxpayer’s e-invoicing privileges for non-compliance. [prensalibre.com], [prensalibre.com]
  • BDO Global Indirect Tax Newsletter (Aug 2025) – “Guatemala – Digital Transformation in Tax Administration”: Analysis of SAT’s digital initiatives including the success of FEL (99% of invoices electronic by 2025) and upcoming plans like FEL 3.0 for auto-filling tax returns and advanced analytics for audits. [bdo.global], [bdo.global]
  • Biz Latin Hub – Guatemala Compliance Guide (Dec 2025): Business-focused summary of tax obligations in Guatemala that confirms FEL electronic invoicing is mandatory for all sales, with real-time reporting to SAT. [bizlatinhub.com]

13. Summary