Briefing document & Podcast: E-Invoicing and E-Reporting in Uruguay

SUMMARY

1. Implementation Timeline & Scope:

Gradual Rollout: Uruguay implemented electronic invoicing in phases, beginning in 2012 with large taxpayers and gradually expanding it over a decade. By 2019, approximately 90% of taxpayers were in the system.
Mandatory for All VAT Payers: As of January 1, 2025, electronic invoicing is compulsory for all VAT payers, including small businesses (“IVA mínimo”), from the moment they register or restart activities. This includes independent self-employed professionals who provide services.
End of Grace Period: The final deadline extension to end-2024 acted as a de facto grace period. There is no further grace period beyond this date. Full enforcement began in January 2025.
Near Universal Coverage: By late 2024, e-invoicing already covered around 98% of all invoices nationwide.
Quote: “Rather than having a post-implementation grace period, Uruguay managed compliance through gradual phase-in and deadline extensions. The push-back of the final deadline to end-2024 effectively served as a grace period for late adopters.”

2. Scope of Transactions:

Comprehensive Coverage: The e-invoicing mandate covers all types of transactions within the VAT system, including B2B, B2C, and B2G.
Included Documents: The regime covers standard invoices, credit notes, debit notes, and receipts.
Exports Included: Exporters must issue electronic export invoices.
Imports Excluded: Import transactions (purchases from foreign suppliers) are not subject to Uruguay’s e-invoicing mandate as the invoice is issued by an overseas supplier. These are documented via customs and import declarations.
Quote: “Essentially, any sale or transaction that would normally require a VAT invoice or receipt in Uruguay must be issued as a CFE if the issuer is in scope.”

3. Taxable Persons in Scope & Exemptions:

General Rule: All VAT-registered businesses established in Uruguay must use electronic invoicing.
Limited Exemptions: Specific exemptions exist for:
Small agricultural producers (annual revenue below approximately US$580k).
Taxpayers performing exclusively non-commercial value-added construction services.
Non-resident taxpayers (foreign companies without a permanent establishment).
Fully tax-exempt entities (with exceptions for Free Trade Zone companies on taxable transactions).
Micro-enterprise regimes (Monotributo or Monotributo Social MIDES).
Non-Established Businesses: Foreign companies without local VAT registration have no obligation. If they register for VAT (through a permanent establishment), they fall under the mandate unless they meet other exemption criteria.
Quote: “Businesses engaged exclusively in agriculture with annual revenue below about 4,000,000 UI (indexed units) are exempt from mandatory e-invoicing. (This threshold equates to roughly US$580k.)”

4. Data to be Provided (Content of E-Invoices):

Required Information: The CFE must contain all information traditionally found on a tax invoice:
Supplier and customer identification (tax ID numbers, names).
Date and invoice number.
Description of goods or services supplied.
Quantity, unit prices, total amount.
Breakdown of taxes (e.g., VAT rate and amount).
Electronic Metadata:Unique CAE (Código de Autorización de Emisión) – an authorization code from the DGI.
Digital signature of the issuer.
QR code or barcode (if printed) containing key details for verification.
Real-time Data for Tax Authority: The DGI receives all invoice details in real-time, providing comprehensive data for VAT administration. There is no need for additional summary data submissions for those invoices.
Quote: “Each CFE includes: the supplier’s and customer’s identification (tax ID numbers, names), the date and invoice number, a description of goods or services supplied, quantity, unit prices, total amount, and a breakdown of taxes (e.g. VAT rate and amount).”

5. Deadlines for Transmitting Data (Timing of E-Invoicing):

Real-time Clearance Model: Uruguay operates a real-time clearance model.
Immediate Transmission: Invoice data must be sent to the tax authority immediately at the time of issuance.
Authorization Required: The CFE is first sent to the DGI for validation/authorization. Only after receiving approval (with the CAE code and digital signature) can the invoice be delivered to the customer.
Daily Consolidated Report: A daily consolidated report with information on all CFEs issued that day must be sent to DGI. This is an automated end-of-day batch report.
Contingency Procedures: If the electronic system is unavailable, a contingency procedure (e.g., pre-numbered paper invoice with a special contingency CAE) can be used. The data must be transmitted to the DGI as soon as the system is back up.
Quote: “The official rule is that each CFE must be validated by DGI before it gains legal validity as an invoice.”

6. Technical Format and Platform:

Standardized XML Format: E-invoices are issued in a standardized XML schema (defined by DGI Resolution 798/2012 and updated periodically). The current version as of 2025 is often referenced (e.g. “format version 25”).
Transmission Channels:DGI’s e-Factura web portal (manual entry or file upload for smaller businesses).
Authorized service providers / software solutions integrating via DGI’s web services.
Digital Signature: Every CFE must be digitally signed using the issuer’s digital certificate.
QR Code/Barcode: Paper invoices must include a QR code or barcode encoding key information for verification.
Clearance Model: Uruguay’s system is a clearance model, where the invoice is issued “through” the tax authority’s system.
Quote: “Taxpayers can issue and transmit CFEs through two main channels: (1) the DGI’s e-Factura web portal… or (2) authorized service providers / software solutions that integrate via DGI’s web services.”

7. Archiving Requirements and Retention Period:

Minimum Retention: Electronic invoices must be archived and accessible for a minimum of 5 years for tax purposes, starting from the end of the fiscal year in which the invoice was issued.
Both Parties Obligated: Both the issuer and recipient must retain the invoices in a secure digital form.
Maintain XML Files: Companies should store their e-invoice XML files (and related files) in an accessible archive.
Data Integrity: Stored invoices must remain unaltered and verifiable.
Longer Retention Recommended: Some sources suggest keeping records for 7 years, or up to 10 years in case of fraud investigations.
Quote: “Under Uruguayan rules, electronic invoices must be archived and accessible for a minimum of 5 years for tax purposes.”

8. Penalties for Non-Compliance:

Monetary Fines: The DGI may impose a fine of around USD $100 for each invoice issued outside the electronic system.
Suspension of Tax Compliance Certificate: The DGI can suspend the company’s “Certificado Único,” impacting business activities like government tenders and obtaining bank credit.
Business Operation Hurdles: Without an active Certificado Único, a business will encounter major operational difficulties.
Escalation to Suspension/Deregistration: The DGI can suspend e-invoicing status or even “desafiliar” the taxpayer, effectively shutting down billing capability. In extreme cases, the business may be inhabilitated as a VAT-registered entity.
Quote: “If a taxpayer who is obliged to use electronic invoicing fails to do so… they can face: Monetary fines: The DGI may impose a fine of around USD $100 for each invoice that was issued outside the electronic system.”

9. E-Invoice Format & Data Transmission vs. “E-Reporting”:

Integrated System: Electronic invoicing and e-reporting are integrated.
Real-time Reporting: Every CFE issued and approved by DGI is simultaneously a legal invoice and a reported transaction.
No Separate E-Reporting: There is no separate e-reporting system requiring additional data like SAF-T files.
Daily Summary: The daily CFE summary fulfills remaining reporting needs.
Pre-Approval Model: Invoices must be submitted and approved before they are considered issued to the customer.
Quote: “The ‘reporting’ happens automatically with each electronic invoice. Every CFE issued and approved by DGI is simultaneously a legal invoice for the buyer and a reported transaction for the tax authority.”

10. Pre-filled VAT Returns (Leveraging E-Invoice Data):

Simplifying Compliance: Uruguay has started using e-invoice data to pre-fill certain VAT return forms.
Targeted Groups: This is currently available for specific regimes or forms, such as small VAT taxpayers (IVA mínimo) and businesses with non-creditable VAT (“IVA No Cede”).
Data Preloaded: VAT return forms are pre-populated with information from the taxpayer’s own electronic invoices and data provided by third parties.
No Universal Pre-fill Yet: Uruguay does not yet have a universally pre-filled VAT return for all businesses.
Quote: “For instance, small VAT taxpayers (IVA mínimo) who have joined electronic invoicing get access to an automatically generated payment slip, and more importantly, certain VAT return forms come with data already preloaded based on the e-invoices on record.”

11. Comparison with Other LATAM Countries:

Regional Trend: Uruguay’s approach aligns with the model adopted across Latin America.
Timing: Uruguay’s implementation was part of the second wave of Latin American countries making e-invoicing universal in the mid-2020s.
Mandate Scope: Uruguay’s mandate covers B2B, B2C, and government transactions (B2G), which is consistent with countries like Mexico, Argentina, and Chile.
System Model: Uruguay uses a clearance model, like almost all of Latin America.
Technology and Format: All Latin American e-invoicing regimes use XML-based formats with digital signatures.
Compliance and Enforcement: Uruguay’s compliance push is comparable to others, with strict enforcement to combat evasion.
Integration with VAT Administration: An emerging trend is using e-invoice data to pre-fill tax returns or conduct real-time audits.
Quote: “Uruguay is often mentioned alongside countries like Chile, Mexico, Brazil as part of the success story of e-invoicing in Latin America, which has dramatically increased tax transparency and collection efficiency.”

This briefing document provides a comprehensive overview of Uruguay’s electronic invoicing system, its implementation, and key compliance requirements. It highlights the country’s alignment with regional trends and its use of technology to enhance VAT administration and reduce tax evasion.

INDEPTH ANALYSIS

Timeline of Implementation: Uruguay introduced electronic invoicing in 2012 for large taxpayers and then expanded it in stages over the following decade. A phased schedule (set by DGI Resolution 798/2012 and 3012/2015) brought approximately 90% of taxpayers into the e-invoicing system by 2019. Subsequent resolutions in late 2023 (No. 2389/2023 and 2548/2023) extended the mandate to all remaining VAT-registered taxpayers: the final cohort was given until 31 December 2024 to join the e-invoicing regime. In other words, as of 1 January 2025, electronic invoicing became compulsory for all VAT payers (including small “IVA mínimo” businesses) from the moment they register or restart activities. By late 2024, e-invoicing was already covering about 98% of all invoices nationwide, marking the end of a gradual 10-year rollout. Grace period: Rather than having a post-implementation grace period, Uruguay managed compliance through gradual phase-in and deadline extensions. The push-back of the final deadline to end-2024 effectively served as a grace period for late adopters. After the 2024 cutoff, there is no additional grace period – full enforcement began in January 2025 with the expectation that all required taxpayers issue e-invoices going forward. [blog.groupseres.com], [blog.groupseres.com] [gub.uy] [ey.com]

Scope of Transactions (Domestic vs. Cross-Border): The e-invoicing mandate in Uruguay encompasses all types of transactions that occur within the VAT system. This includes Business-to-Business (B2B) sales, Business-to-Consumer (B2C) retail transactions, and Business-to-Government (B2G) supplies. In addition to standard invoices, the regime covers related documents like credit notes, debit notes, and receipts. It also explicitly covers export transactions – exporters must issue electronic export invoices (a specific CFE document type for goods exports) instead of paper. Essentially, any sale or transaction that would normally require a VAT invoice or receipt in Uruguay must be issued as a CFE if the issuer is in scope. By contrast, import transactions (purchases from foreign suppliers) are not subject to Uruguay’s e-invoicing mandate – since the invoice is issued by an overseas supplier, it isn’t generated through the Uruguayan CFE system. Such imports are documented via customs and import declarations rather than domestic e-invoices. (Uruguay’s regime applies to invoices issued by local taxpayers; foreign vendors cannot issue Uruguayan CFEs.) [complyance.io] [edicomgroup.com]

Taxable Persons in Scope (Established vs. Non-Established): The e-invoicing requirement applies to all VAT-registered businesses established in Uruguay, with only a few specific exceptions defined by law. In practice, this means virtually every company, partnership, and self-employed entrepreneur who is liable for VAT must use electronic invoicing. Exemptions: Uruguay carved out limited exemptions for certain small or special taxpayer categories, notably: [complyance.io], [gub.uy]

Small agricultural producers: Businesses engaged exclusively in agriculture with annual revenue below about 4,000,000 UI (indexed units) are exempt from mandatory e-invoicing. (This threshold equates to roughly US$580k.) If they exceed that revenue, they must join the electronic system in the year following the breach. [ey.com]
Real estate construction activities: Taxpayers performing exclusively non-commercial value-added construction services (an unusual category of VAT payer) are exempt. [ey.com]
Non-resident taxpayers: Entities that fall under the Non-Resident Income Tax regime (i.e. foreign companies without a permanent establishment, paying tax on Uruguayan-source income) are not required to become e-invoice issuers. [ey.com]
Fully tax-exempt entities: Businesses that are exonerated from all DGI-administered taxes for all their operations do not have to issue electronic invoices. (An exception to this exception is that companies operating in Free Trade Zones, even if mostly exempt, must comply with e-invoicing for any taxable transactions.) [ey.com]
Micro-enterprise regimes: Simplified regime taxpayers, such as those under the Monotributo or Monotributo Social MIDES programs (very small businesses and certain social contributors), are excluded from the e-invoicing mandate. These are typically entrepreneurs or small shops paying a unified small tax instead of standard VAT – they can continue using manual invoices. [ey.com]

Aside from these narrow exemptions, all VAT payers in Uruguay – including SMEs and professionals – must issue electronic invoices. Notably, independent self-employed professionals who provide services (and are VAT-registered) were among the required groups, with a deadline even earlier (they were required to switch by 1 January 2024). Non-established businesses: Foreign companies without a local VAT registration have no obligation (since they generally cannot issue local tax invoices). If a non-established entity does register for Uruguayan VAT (through a permanent establishment or tax representative), it would fall under the mandate like any other taxpayer, unless it qualifies under one of the above exemptions. [impo.com.uy]

Data to be Provided (Content of E-Invoices/E-Reports): Uruguay’s electronic invoice, known as the Comprobante Fiscal Electrónico (CFE), must contain all the information traditionally required on a tax invoice – and this information is transmitted to the tax authority as part of the electronic file. Each CFE includes: the supplier’s and customer’s identification (tax ID numbers, names), the date and invoice number, a description of goods or services supplied, quantity, unit prices, total amount, and a breakdown of taxes (e.g. VAT rate and amount). In essence, the full transactional detail and tax amount that would appear on a paper invoice are present in the electronic data. [complyance.io]

In addition, the electronic system adds specific fields for control purposes. Notably, every CFE is assigned a unique CAE (Código de Autorización de Emisión) – an authorization code from the DGI – which is like an electronic stamp of approval. The DGI’s system generates this as part of validating the invoice. The CFE is also digitally signed with the issuer’s authorized digital certificate, ensuring authenticity and integrity. The approved invoice data is then locked and cannot be altered without invalidating the signature. If a hard copy or PDF of the invoice is needed, it must include a QR code or bar code containing key details (such as the CAE and DGI approval info) so that anyone (e.g. an auditor or the customer) can scan it to verify the invoice’s validity against the DGI records. [vatcalc.com]

In summary, the data to be reported comprises all standard invoice elements (parties, items, values, taxes) plus the electronic metadata (authorization code, digital signature, unique invoice ID). This comprehensive data set is what gets transmitted to the tax authority in the CFE’s XML file. The tax authority receives all the invoice details in real time, effectively obtaining the information needed for VAT administration (sales amounts, taxable base, tax due, etc.) for each transaction. There is no need for additional summary data submissions for those invoices, since the CFE itself covers the reporting of required data invoice-by-invoice. [complyance.io]

Deadlines for Transmitting Data (Timing of E-Invoicing/E-Reporting): Uruguay operates a real-time clearance model for e-invoicing. This means that *invoice data must be sent to the tax authority essentially immediately at the time of issuance. The process is as follows: when a company creates an invoice, the CFE is first sent electronically to the DGI for validation/authorization; the DGI’s system checks the invoice details and if everything is in order, it returns the approved electronic invoice (with the CAE code and digital signature) almost instantly. Only after receiving this approval can the business deliver the invoice to its customer (in electronic form or printed form) – the approved CFE is what gets delivered. In other words, transmitting the data to the tax authority is an integral part of issuing the invoice, not something done days later. The official rule is that each CFE must be validated by DGI before it gains legal validity as an invoice. This typically occurs in seconds via web services integration. [complyance.io], [blog.groupseres.com] [complyance.io]

Because each invoice is individually reported and cleared in real time, there is no separate “e-reporting” submission required on a periodic basis for those invoices – the system already captures each transaction as it happens. However, Uruguay’s regulations do mandate a form of summary reporting for control purposes: electronic issuers must send a daily consolidated report to DGI with information on all CFEs issued that day. In practice, this is an automated end-of-day batch report that echoes the invoices that were already authorized, serving as a reconciliation. The timeline for this report is daily – effectively, by the end of each business day (or early next day), the issuer’s system transmits the summary of that day’s invoices to the tax authority. This daily report requirement ensures that even if multiple invoices were approved individually, the DGI gets a confirmation of the full day’s activity for that taxpayer. Outside of this, no additional monthly or quarterly invoice listing is required, since the detailed data is already in DGI’s possession transaction by transaction. [complyance.io] [voxelgroup.net]

Uruguay does provide for contingency scenarios: if for some reason the electronic system is unavailable (e.g. internet outage or system downtime), an authorized contingency procedure can be used (such as issuing a pre-numbered paper invoice with a special contingency CAE). In such cases, the data must be transmitted to the DGI as soon as the system is back up, within a short allowed window, to ensure those invoices are registered. Apart from such exceptional cases, the general rule is immediate electronic transmission at issuance – there is no grace period of several days to report invoices late. The allowable delay is essentially zero (or very minimal in contingencies); compliance means invoices are reported in real-time or near-real-time to the authorities. This stringent timeline is a cornerstone of the “clearance” approach: tax authorities have visibility of the transaction virtually at the moment of sale, rather than waiting for an end-of-month report.

Technical Format and Platform: Uruguay’s e-invoices are issued in a standardized digital format prescribed by the tax authority. The format is a structured XML schema for CFEs, ensuring each invoice contains all required fields in a machine-readable form. The XML invoice file includes the content and tax details, as well as the digital signature and authorization code embedded within it. This format was defined by DGI (initially in Resolution 798/2012) and has periodically been updated – for example, new versions of the CFE schema have been introduced (the current version as of 2025 is often referenced, e.g. “format version 25”). All compliant invoices must conform to this XML structure. [complyance.io] [complyance.io], [complyance.io]

Transmission platform: Taxpayers can issue and transmit CFEs through two main channels: (1) the DGI’s e-Factura web portal, which allows manual entry or file upload of invoices (suitable for smaller businesses), or (2) authorized service providers / software solutions that integrate via DGI’s web services. Many companies use certified electronic invoicing software or connect through a provider that handles the formatting and communication with DGI. In all cases, the invoice data ends up in the DGI’s central system. The tax authority (DGI) provides the infrastructure for receiving, validating, and storing the invoices. Once an invoice is approved, DGI’s system keeps a record of it, and the issuer typically also keeps a copy (often the software will store the XML and perhaps generate a human-readable PDF for business use). [complyance.io]

Format specifics: Every CFE must be digitally signed using the issuer’s digital certificate – this ensures authenticity and links the document to the issuer. Issuers are required to obtain an appropriate digital certificate for signing invoices. The invoice also contains either a QR code or barcode when presented on paper, which encodes key info (like the unique invoice ID/CAE) for verification. Uruguay’s format is designed such that a single XML schema accommodates various document types; a field within the XML specifies whether it’s an invoice, a credit note, an export invoice, etc., but the overall structure is unified. This uniform format simplifies processing for the tax authority and allows all sectors (B2B, B2C, B2G) to use the same system. [complyance.io] [vatcalc.com] [edicomgroup.com] [voxelgroup.net]

From a model perspective, Uruguay’s system is a clearance model – the invoice is issued “through” the tax authority’s system. This is similar to many Latin American countries. For example, in practice Uruguayan companies will either use the DGI’s online system or have their software send an XML payload via API; the DGI returns a validated invoice (with a timestamp, CAE, etc.) that the company then finalizes and sends to the customer. The end result is an official XML (often accompanied by a PDF) that is considered the original legal invoice. The DGI’s platform thus serves as an intermediary to ensure each invoice meets format and content rules before it’s finalized. Businesses can integrate this process seamlessly, but it means technical compliance (correct format, use of digital signature, etc.) is essential for an invoice to be accepted. [complyance.io]

Archiving Requirements and Retention Period: Under Uruguayan rules, electronic invoices must be archived and accessible for a minimum of 5 years for tax purposes. Both the invoice issuer and the recipient are generally required to retain the invoices for this period, in a secure digital form. This five-year term aligns with the standard statute of limitations for VAT audits in Uruguay (the tax authorities can typically review up to 5 years back for compliance). The clock usually starts from the end of the fiscal year in which the invoice was issued. [gosocket.net], [complyance.io]

In practical terms, compliance with this requirement means companies need to ensure they store their e-invoice XML files (and any related files) in an accessible archive for at least five years. The DGI itself keeps copies in its system, and taxpayers using the DGI portal can retrieve past invoices, but companies are still expected to maintain their own archive as well (especially if they use their own software). The stored invoices must remain unaltered and verifiable (the digital signature helps with this, as any tampering would invalidate the signature). If the tax authority conducts an audit or if any issue arises, the business must be able to present the electronic documents upon request within that 5-year window. [gosocket.net]

It’s worth noting that some guidance suggests keeping records for longer in certain cases. For example, one compliance source notes a recommended storage time of 7 years, or up to 10 years in case of investigations related to fraud. While the legal minimum is five years, companies often err on the side of caution and retain e-invoices for a longer period, especially since digital storage is not costly. In any case, 5 years is the mandatory minimum retention period explicitly stated by Uruguayan authorities. Archiving can be managed through the invoicing software, an accredited third-party archive service, or the DGI’s online portal. The key is that the invoices remain available and readable (in their original format) for the required time. Non-compliance with retention rules (e.g. deleting invoices too soon or being unable to produce them) could subject a taxpayer to penalties or issues in an audit, so this requirement is an important part of the overall e-invoicing compliance. [voxelgroup.net] [blog.groupseres.com]

Penalties for Non-Compliance: Uruguay’s tax authority (DGI) has put in place strict sanctions to enforce the e-invoicing mandate. If a taxpayer who is obliged to use electronic invoicing fails to do so (for example, continues to issue paper invoices or otherwise bypasses the CFE system), they can face:

Monetary fines: The DGI may impose a fine of around USD $100 for each invoice that was issued outside the electronic system. This per-invoice fine can accumulate quickly if a business persistently avoids e-invoicing. The fine serves as a direct financial deterrent for non-compliant invoicing practices. [asystax.com.uy]
Suspension of tax compliance certificate: Beyond fines, the DGI can suspend the company’s “Certificado Único” (a unique tax compliance certificate) as a consequence of non-compliance. Losing this certificate has serious practical implications – in Uruguay, a valid Certificado Único is often required for various business activities, such as participating in government tenders, obtaining bank credit, or even just proving one’s good standing as a taxpayer. Suspension effectively signals that the company is not in good standing with the tax authority. [asystax.com.uy]
Business operation hurdles: Without an active Certificado Único, a business will encounter major operational difficulties. For instance, the company may be barred from contracting with government entities, hindered in carrying out import/export transactions (which often require proof of tax compliance), and could even face issues in B2B commerce as partners might require a valid certificate. It also can impede certain e-commerce operations or subcontracted services. In short, the company’s ability to operate normally is compromised until compliance is restored. [asystax.com.uy]
Escalation to suspension of e-invoicing status or deregistration: If non-compliance continues or is particularly egregious, the DGI can escalate measures. They might suspend the taxpayer’s status as an authorized electronic issuer or even “desafiliar” (disaffiliate) the taxpayer from the e-invoicing regime. Essentially, the firm would no longer be recognized as an electronic invoice issuer, which means it legally cannot issue any invoices (since paper is not allowed without authorization). This is effectively a shutdown of billing capability, which can halt business operations entirely. In extreme cases of repeated or willful non-compliance, authorities might move to inhabilitate the business as a VAT-registered entity (making it illegal for them to continue operating until issues are fixed). [gosocket.net] [asystax.com.uy]

In summary, failure to comply with e-invoicing can result in hefty fines per invoice and progressively harsher consequences. First, invoices not properly issued are considered invalid (which can create tax liabilities by itself), and the DGI will levy fines. If a pattern of non-compliance is detected, the tax office can suspend the company’s tax clearance certificate, crippling its commercial abilities. Prolonged non-compliance can even jeopardize the business’s ability to function legally. These measures underscore that Uruguay treats e-invoicing obligations very seriously – companies are strongly incentivized to comply to avoid financial loss and business disruptions. (Aside from these, general tax evasion penalties would also apply if sales go unreported due to not invoicing electronically. But since the regime captures sales in real time, attempting to circumvent it is considered a direct violation.) [asystax.com.uy]

E-Invoice Format & Data Transmission vs. “E-Reporting”: In Uruguay, electronic invoicing and e-reporting are essentially integrated – there is not a separate e-reporting system for transaction data distinct from e-invoicing. The “reporting” happens automatically with each electronic invoice. Every CFE issued and approved by DGI is simultaneously a legal invoice for the buyer and a reported transaction for the tax authority (serving as a real-time VAT reporting mechanism). As noted, no periodic VAT sales list needs to be sent because each invoice is reported at issuance. Furthermore, the daily CFE summary fulfills any remaining reporting need on a daily basis. [complyance.io] [voxelgroup.net]

If by “e-reporting” one means the transmission of invoice data to authorities outside of the invoice itself, Uruguay does not require businesses to submit additional data like SAF-T files or monthly journals – the regime of continuous transaction control via CFEs replaces those needs. The format used for both invoicing and reporting is the same XML schema; there isn’t a separate format for an aggregate report. The timeline for data submission is essentially immediate (at issuance) and at most by day-end for the summary. For example, there is no rule like “submit invoice data within X days after issuance” – it’s far stricter: the invoice must be submitted and approved before it is considered issued to the customer. This is a key difference from some systems (like “post-audit” systems where you might have 48 hours or several days to report an invoice after issuing it). Uruguay’s model is a clearance (pre-approval) model, so the concept of a grace period of X days after issuance for reporting does not apply. The only exception is in contingency scenarios as mentioned, where a business might issue an invoice offline and then report it once able – even then, they are expected to upload it immediately once connectivity is restored, to remain in compliance. [complyance.io]

Archiving and Retention (VAT Records): As part of compliance, electronic invoices must be stored and archived properly for future reference and audit. Uruguay’s law requires maintaining invoice records for 5 years (counted from the end of the fiscal year). This obligation applies to both sides of the transaction: the seller must keep copies of the CFEs they issued, and buyers must keep the CFEs they received (just as they would keep traditional invoices) for the statutory period. The electronic nature of the invoices does not remove the obligation to retain them – in fact, DGI explicitly mandates digital retention. [gosocket.net], [complyance.io]

The retention can be fulfilled by keeping the original XML files in a secure archive (with backup), since those contain the signed invoice data. Many companies also keep human-readable versions (PDFs) for convenience, but the critical record is the XML with the digital signature. The DGI’s own system preserves invoices too, and taxpayers can retrieve past invoices via the DGI portal if needed. Nevertheless, the onus is on the taxpayer to ensure accessibility of their records. If audited, a taxpayer may be asked to present electronic invoices from, say, 3 or 4 years ago; they should be able to produce those (and demonstrate their validity, e.g. the digital signature).

The retention period of 5 years aligns with common practice in Latin America (several countries require five years for tax docs) and with Uruguay’s general tax code. Some companies choose to keep records longer (Uruguay’s Commercial Code, for example, might require accounting records to be kept for 10 years). Indeed, one guideline suggests 7 years as a standard retention, extendable to 10 in case of suspected irregularities, to cover any extraordinary audit scenarios. While not mandated for everyone, it indicates that for complete safety a decade of retention could be advisable in certain cases (e.g., if under a serious investigation, authorities could look further back, and having the records is crucial). [voxelgroup.net]

Moreover, Uruguay’s e-invoicing rules also include a requirement that electronic issuers guarantee the integrity and authenticity of stored invoices over the retention period. This means the storage method should protect the invoices from alteration or loss. Using the digital signature as stored in the XML, one can always verify if the document is unchanged – a tampered file would fail verification. Companies often rely on either DGI’s repository or reputable archiving solutions to meet this requirement. Ensuring secure backup is also important (so that invoices aren’t lost to a system crash). [gosocket.net]

To summarize the archiving obligations: keep all electronic invoices for at least five years in a secure, accessible form. Make sure they remain readable and verifiable (maintain the original XML and its signature). Both sellers and buyers should do this, since each might need to prove the transaction for tax credit or deduction purposes. Non-compliance (e.g., deleting invoices early or failing to produce them) can result in penalties or jeopardize the ability to substantiate tax filings. Uruguay’s DGI, by storing the invoices centrally, provides a safety net, but it does not remove the taxpayer’s responsibility to maintain their own records.

Pre-filled VAT Returns (Leveraging E-Invoice Data): Uruguay has started using the rich data obtained from electronic invoicing to pre-fill certain VAT return forms, simplifying compliance for taxpayers. Because DGI receives detailed sales and purchase information (including through third-party invoices), they are able to offer some taxpayers a declaration form that is partially completed with known data. For instance, small VAT taxpayers (IVA mínimo) who have joined electronic invoicing get access to an automatically generated payment slip, and more importantly, certain VAT return forms come with data already preloaded based on the e-invoices on record. Specifically, the tax authority has mentioned that “IVA No Cede” taxpayers (businesses with non-creditable VAT, such as certain sectors) and personal services VAT payers can benefit from pre-completed VAT declarations. Their VAT return form is populated with information from their own electronic invoices and data provided by third parties (e.g. invoices issued to them). This means the figures for sales, VAT collected, etc., are suggested by the tax authority, drawn directly from the CFE system, and the taxpayer can simply review and confirm or adjust if needed, rather than manually compiling all data. [gub.uy]

Additionally, DGI uses the data to ease VAT payment calculations – for example, it offers an online service to help calculate the bimonthly advance payments for certain professionals based on the e-invoicing data. These conveniences are part of Uruguay’s “Uruguay Digital 2025” initiative, aiming to modernize tax administration. While not every taxpayer’s VAT return is fully pre-filled yet, these are early steps toward leveraging electronic reporting for compliance simplification. [gub.uy]

It’s important to note that Uruguay does not yet have a universally pre-filled VAT return for all businesses (unlike, say, Chile which provides a draft VAT return for most taxpayers). The pre-population is currently available for specific regimes or forms. Regular VAT taxpayers still prepare their VAT declarations in the usual way, albeit with all needed data readily available from their e-invoice records. However, as the electronic invoicing system now captures nearly all transactions, Uruguay is positioned to expand pre-filled return programs in the future. The trend in Uruguay mirrors what’s happening in other countries that have implemented electronic invoicing: tax authorities are using the detailed data to automate tax compliance. In Uruguay’s case, we see it in reduced monthly tax dues for small e-invoice adopters and partially pre-completed filings for certain categories. There is no indication yet of a fully automated VAT return for the general population, but the existing measures significantly reduce compliance effort for the targeted groups and improve accuracy (since errors are less likely when the data is directly from source). [gub.uy]

To directly answer: Yes, Uruguay has begun providing pre-filled VAT return data for some taxpayers, using e-invoice information. This is a direct benefit of the e-invoicing/e-reporting system. On the other hand, if the question implies whether the government sends out pre-calculated VAT returns to everyone (like Italy’s pre-filled VAT forms pilot), the answer is not for all taxpayers yet, only certain filings are pre-filled. Nonetheless, the infrastructure and practice are moving in that direction, harnessing the comprehensive data collected through e-invoicing to simplify tax filing.

Comparison with Other LATAM Countries: Uruguay’s approach to e-invoicing and e-reporting is broadly similar to the model adopted across Latin America, albeit with its own timeline and nuances. Key points of comparison:

Regional trend and timing: Latin America as a region has been a pioneer in electronic invoicing. Chile and Brazil were among the first (Chile introduced e-invoicing in the early 2000s, Brazil’s NFe began mid-2000s), followed by Mexico (CFDI from 2011). Uruguay came slightly later to mandatory e-invoicing – starting its rollout in 2012 and achieving full coverage by 2024, which is a bit behind the earliest adopters but on par with many others. For example, Ecuador and Peru mandated nationwide e-invoicing only in 2022 and 2023 respectively, which coincides with Uruguay’s final phase. So Uruguay is neither the earliest nor the last in the region; it’s part of the second wave of Latin American countries that made e-invoicing universal in the mid-2020s. The decade-long gradual implementation Uruguay chose is comparable to approaches in, say, Colombia (which phased in e-invoices from 2018 to 2020) and Argentina (phased expansions through the 2010s). Now, by 2025, virtually all major economies in LATAM including Uruguay have a mature e-invoicing regime in place. [blog.groupseres.com]
Mandate scope: Uruguay’s mandate covers B2B, B2C, and government transactions (B2G), which is consistent with countries like Mexico, Argentina, and Chile that also require electronic invoices for both business and consumer sales. Not all countries initially included B2C (for example, some countries started with B2B and later added retail invoices), but Uruguay, similar to Argentina, brought in B2C via the “e-ticket” documents relatively early. Many countries in the region now have some mechanism for electronic receipts to consumers (Chile and Brazil do via retail-specific systems; Mexico uses the same CFDI for B2C). Uruguay’s inclusion of exports in the electronic system is also standard – most LATAM countries require export invoices electronically for control of VAT zero-rating. One area of slight difference is the treatment of very small taxpayers: Uruguay continued to exempt its smallest simplified regime taxpayers (monotributo) even in 2025, whereas Mexico and Brazil essentially require e-invoices from nearly all formal businesses (though Brazil has a separate system for small MEI taxpayers, and Mexico has a simplified CFDI for small sellers). Argentina provides a close parallel by also exempting “Monotributista” micro-entrepreneurs from e-invoicing (or offering them optional simpler electronic receipt systems). Thus, Uruguay’s approach to leave out the tiniest taxpayers is in line with Argentina’s policy, whereas countries like Chile eventually included almost everyone. This difference is minor in terms of volume, since those micro-exemptions represent a tiny fraction of turnover. [complyance.io] [ey.com]
System model (Clearance vs Post-Audit): Uruguay, like almost all of Latin America, uses a clearance model – invoices must get real-time approval from the tax authority. This is a hallmark of LATAM e-invoicing. It contrasts with, for example, European systems where often invoices are just reported after the fact. In Latin America, Mexico’s CFDI, Brazil’s NFe, Argentina’s CAE system, etc., all require obtaining an authorization code from the tax administration for each invoice, just as Uruguay does. In technical terms, Uruguay’s CFE system is very much akin to these: an XML is sent to the authority, the authority validates and returns a confirmation (with a digital signature or code), and only then is the invoice valid. So conceptually, businesses operating across LATAM find Uruguay’s system familiar. One minor variation is that some countries have slightly different channels or categorizations (e.g., Brazil has separate invoice models for goods vs. services, whereas Uruguay’s single CFE schema covers all, including services). But overall, the clearance approach and the need for a digital signature and government-issued authorization on each invoice is a common thread across the region. [vatcalc.com], [complyance.io]
Technology and format: All Latin American e-invoicing regimes use XML-based formats with digital signatures, and Uruguay is no exception. The specifics of the schema differ country by country, but conceptually they carry similar data (buyer, seller, items, tax details, etc.) and serve the same purpose. Uruguay’s use of QR codes on printed invoices for verification is also common (Mexico, Peru, and others do the same). The infrastructure – a government portal plus certified private providers – is again a shared model (e.g., Mexico allows certified PACs to intermediate, Colombia had a similar scheme; Uruguay authorizes providers like EDICOM, etc., to assist issuers). Uruguay’s DGI directly provides storage and verification, just as SUNAT does in Peru or DIAN in Colombia. So on the technical and operational side, Uruguay aligns closely with regional best practices. [complyance.io], [complyance.io]
Compliance and enforcement: The compliance push in Uruguay is comparable to others: Latin American tax authorities generally enforce e-invoicing strictly to combat evasion. Many impose fines per missed invoice and can penalize non-compliance with business restrictions. Uruguay’s fine of ~$100 per invoice and threat of shutting down non-compliers is in line with the tough stance seen elsewhere (for example, Mexico has penalties and can cancel digital certificate access for non-compliance, which halts invoicing; Brazil can impose heavy fines and even confiscate goods if they’re transported without electronic invoices). The concept of linking compliance to the ability to operate (e.g., Uruguay’s Certificado Único suspension) is similar to how other countries link tax compliance statuses to permissions. In essence, Uruguay’s penalty framework is similarly stringent, reflecting a region-wide zero-tolerance for operating outside the electronic system. [asystax.com.uy]
Integration with VAT administration: An emerging trend is using e-invoice data to pre-fill tax returns or conduct real-time audits. Uruguay is adopting this on a smaller scale (preloaded forms for some taxpayers). Other countries have gone further; for example, Chile provides a proposal for the monthly VAT return (Form 29) based entirely on electronic invoice data and other submissions, which the taxpayer simply confirms or amends. Mexico uses CFDI invoice and payroll data to pre-populate certain annual tax return fields and to cross-verify VAT credits. Colombia introduced electronic invoicing and then an electronic payroll and is moving toward electronic accounting reports. Uruguay is heading in the same direction by leveraging its e-invoices for compliance tools – the pre-filled declarations for certain VAT categories show a similar intent. We can expect Uruguay to expand on this, following the lead of peers that are using transaction data to simplify or even automate tax filings. [gub.uy]

In conclusion, Uruguay’s e-invoicing/e-reporting system aligns with the Latin American model of electronic fiscal control, characterized by mandatory use of electronic invoices for nearly all economic transactions, real-time government clearance, standardized digital formats, and strict enforcement. Its timeline was somewhat more extended, finishing in 2024, but ultimately Uruguay reached universal coverage just as countries like Mexico, Brazil, Argentina, Chile did (earlier or around the same time). Any business familiar with e-invoicing in one LATAM country will find Uruguay’s requirements quite similar. Minor differences (like specific exemptions or certain procedures) exist but do not change the overall picture: the scope is comprehensive, the process is real-time, and the policy goal – improving VAT compliance and efficiency – is shared across the region. Uruguay is often mentioned alongside countries like Chile, Mexico, Brazil as part of the success story of e-invoicing in Latin America, which has dramatically increased tax transparency and collection efficiency. [blog.groupseres.com]

Sources & References: This overview is based on the latest available information from Uruguayan government releases and reputable tax news sources. Key references include DGI official communications (e.g. DGI Resolution 2548/2023 and related guidance), as well as recent analyses by Big Four firms and tax solution providers which summarize Uruguay’s e-invoicing rules (such as EY Global Tax Alert, April 2023, and compliance summaries by EDICOM and others). These sources confirm the implementation timeline, technical specifications, and legal obligations outlined above, and they reflect the state of play up to 2025. The Uruguayan DGI’s official e-Factura portal and documentation (available in Spanish) provide further technical details and procedural guidance for businesses implementing the system. For instance, the DGI’s “Guía Informativa para el ingreso al régimen de facturación electrónica” and the FAQ on their e-factura website clarify contingency procedures and taxpayer obligations. Readers seeking more information can refer to the DGI’s website and the text of the relevant DGI resolutions (e.g., Resolución 798/2012 which established the CFE regime, and Resolución 2389/2023 with its modification 2548/2023 which set the final deadlines). These primary sources (mostly in Spanish) are linked in the footnotes for reference. [gub.uy], [gub.uy] [ey.com], [ey.com] [edicomgroup.com], [complyance.io] [gosocket.net], [gosocket.net]

See also

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

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