Regulatory updates - Colombia

DIAN has announced a new validation mechanism for the "Buscar documento" (Search document) option of its electronic invoicing system, in effect from July 28, 2026. The measure is aimed at protecting the security of taxpayer information.

Under the change, the system asks for the identification number of the invoice issuer or receiver when a user looks up a document. To download that document, the user will have to enter the same identification number again.

Users may also encounter the message "Solicitud bloqueada por controles de seguridad" (Request blocked by security controls). According to DIAN, this appears when the system detects robots, automated processes, or artificial intelligence agents that could overload the look-up service and pose a risk to information security. It does not suspend access: the system will present a check to confirm the user is human, after which normal navigation can continue.

DIAN describes the update as part of the technical controls put in place to keep the platform working properly and has asked users and taxpayers to take the change into account. The look-up tool is available through the Buscar documento option of the electronic invoicing system.

The draft decree aims to address widespread misinterpretations regarding which electronic invoices must be registered in the RADIAN system and when the statutory acceptance period begins. MinCIT notes that current regulatory wording has led to divergent interpretations affecting the practical operation of electronic invoicing.

Key clarifications in the draft decree include:

• It is clarified that only electronic invoices that constitute negotiable instruments and are intended for circulation must be registered in RADIAN, and not all electronic invoices.
• Express acceptance occurs when the buyer electronically accepts within the three-day period, while tacit acceptance happens when no objection is submitted within the same timeframe
• When tacit acceptance applies and the issuer intends to endorse the invoice, they must leave an electronic record according to DIAN-defined mechanisms
• The three-business-day period for express or tacit acceptance would begin upon receipt of the invoice itself, rather than upon receipt of goods or services
• The legitimate holder must inform the debtor through RADIAN at least three days before the invoice's due date

If adopted, the decree would take effect immediately following its publication in the Official Gazette. More information in the Draft Decree is available at the following link

The Resolution 000008/2024 from 31 January 2024 extended the implementation deadline by three months for Technical Annexes 1.9 and 1.0, covering electronic sales invoices and electronic equivalent documents. This extension grants taxpayers more time to adapt to new obligations.

What are the new obligation deadlines?

These are the revised mandatory dates:

• Annexe v1.9: The deadline, initially set for 2 February 2024, has been extended to 1 May 2024;
• Annexe v1.0: The adoption period for electronic equivalent documents is extended from 1 May 2024 to 1 November 2024 (specific dates vary based on the type of electronic equivalent document).

The implementation schedule for the electronic equivalent document, mainly for cash register machine tickets with Point of Sales (P.O.S.) systems, is as follows:

• 1 May 2024 - Large taxpayers;
• 1 June 2024 - Income tax filers who do not have the status of Large taxpayers;
• 1 July 2024 - Non-filers of income tax or taxpayers who don't meet the above criteria.

Implementation timelines for the remaining electronic equivalent documents

The following timelines apply to the implementation of other electronic equivalent documents:

• 1 August 2024
  • Home public services;
  • Passenger transport ticket;
  • Extract.

• 1 September 2024
  • The passenger air transportation ticket or ticket;
  • The ballot, fraction, form, cardboard, ticket or instrument in games of luck and chance other than localized games;
  • The document in localized games.

• 1 October 2024
  • The document issued for the collection of tolls;
  • The transaction settlement receipt issued by the Stock Exchange;
  • The operations document of the agricultural and other commodities exchange.

• 1 November 2024
  • The entrance ticket to public performances of the performing arts and other public shows;
  • The movie admission ticket.

The Resolution 000008/2024 is available here.