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Compliance

Compliance Checklist: Meeting Latin America’s New Electronic Filing & Penalties Landscape

Across LatAm, new rules are changing how and when records must be digital and penalties for non-compliance are being softened temporarily. Know what has shifted this season.

By NomadicTax Research Team · 5-8 min read

Digital Filing Thresholds & Softened Penalties

  • Peru’s SUNAT passed Resolution 0125-2026/SUNAT, allowing flexibility until 31 August 2026 for “SIRE” electronic registers for those who were already obligated by May or who get obligated starting June 2026. Penalties are waived for specific infractions during that grace period. (cpe.sunat.gob.pe)
  • Argentina’s ARCA postponed certain electronic invoicing and contingency authorization rules until 1 August 2026, under RG 5852/2026, giving more time to comply. (biblioteca.afip.gob.ar)

Communication & Deadlines Updates

  • In Mexico, the SAT declared that any submissions through the Buzón Tributario made between 20-31 July 2026 will be considered received on 3 August 2026, due to recognized non-business (inhábil) days. (wwwnp.sat.gob.mx)
  • In Colombia, DIAN under Comunicado de Prensa No. 092 / 2026 adjusted tax deadlines for multiple obligations in July because the enactment of Law 2578 of 2026 introduced a new national holiday. This affects filings like Income Tax, simple regime, VAT, retentions, etc. (dian.gov.co)

Risk Areas & Best Practices

  • Avoid missing grace-period cutoffs: Once Peru’s 31 August deadline passes, penalties resume.
  • Clarify dates if using electronic portals: Mexico’s Buzón Tributario in late July is a clear example of how physical or system-based timing can shift official deadlines.
  • Watch holiday laws: Colombia’s new holiday materially shifted deadline fallbacks; many taxpayers missed the memo in past years.

Sample Compliance Timeline for Mid-Sized Firm Operating in Both Argentina & Peru

MonthArgentina (Buenos Aires)Peru (Lima)
End-July 2026Ensure invoices falling under new ARCA electronic invoicing/co-contingency rules are identified; internal process ready by 1 August.Begin gathering records for required SIRE electronic record-keeping; if missing, take advantage of grace period until 31 August.
05-15 AugustReview whether use of CAEA contingency mode triggered; confirm CAEA or main module usage.Ensure all electronic sales, purchase records for periods June–July are captured.
01 SeptemberFully compliant with ARCA’s RG 5852/2026 changes; no more requests for contingency mode that aren’t timely’organisation.Penalization exposure − kept minimal, if records fully regularized by end of August.

Action Items for All Taxpayers in LatAm Right Now

  • Review whether you’re subject to any new or postponed electronic invoicing or record-keeping obligations in your country.
  • Identify whether you've been given a grace period, and mark firm internal dates to satisfy them.
  • Check statutory deadlines especially around new holidays or non-business days (as occurred recently in Colombia and Mexico).
  • Align your accounting or tax software with the official requirements (including specific forms, digital signatures, CAEA, SIRE etc.).

Persistence and attention right now will prevent heavy fines later.

Sources

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