Electronic invoice in Peru
The Definitive Guide to Peru’s CPE Mandate: Navigating SUNAT’s hybrid clearance model, localised UBL 2.1 mapping, and seamless integration with accredited OSE/PSE operators.
Peru has a mature and now near-universal system of mandatory electronic invoicing — Comprobantes de Pago Electrónicos (CPE) — built around the tax administration SUNAT. The legally significant invoice is a structured XML in a localised UBL 2.1 profile, digitally signed and validated either by SUNAT or by an accredited private operator. A PDF on its own is not an electronic tax invoice.
The architecture is best described as a hybrid CTC model with centralised tax control and delegated validation. Some documents go straight to SUNAT; others are checked by OSE — private but SUNAT-accredited operators — which return the validation result and forward the document. And crucially, validation does not always have to happen before the invoice reaches the buyer.
The mass rollout finished years ago. What has continued since is the closing of gaps — and the most recent step, in June 2026, removed the last onboarding delay entirely.
The dedicated obligation for exports of services applied from 1 January 2018 and for exports of goods from 1 July 2018 — ahead of much of the domestic market.
Taxpayers from 75 UIT moved to electronic factura and boleta on 1 January 2021; the 23–75 UIT band on 1 January and 1 April 2022; and those below 23 UIT on 1 April and 1 June 2022 — the effective completion of the general rollout. See Who is in scope.
Suppliers carrying out covered transactions with public institutions became obliged to issue electronic invoices, using the same SUNAT infrastructure as everyone else.
Resolución de Superintendencia N.° 000075-2026/SUNAT, published on 4 May 2026, made a new taxpayer an electronic issuer from the moment it registers its RUC, provided it opts for the MYPE, Régimen Especial or Régimen General regime. It also extends the obligation to use SIRE, the integrated electronic registers system, on the same basis.
There is no published plan for Peru to move to Peppol, EN 16931, CII, a European four- or five-corner model, or a ViDA-compatible cross-border regime. The current SUNAT projects are about further massification of the local CPE and SIRE ecosystem: completing coverage, automatic inclusion of new RUC holders, integration of CPE with the electronic registers, updated technical catalogues and validation rules, and tighter control of transmission timeliness.
By 2026 SUNAT states that the obligation reaches the great majority of taxpayers. The public list of all obliged issuers has effectively ceased to be a practical tool, precisely because the system became universal — so the useful question is no longer "am I on the list" but "which exception might apply".
Other exceptions survive for particular entities and document types, including certain Nuevo RUS cases, specific state funds, the liquidación de compra and documents governed by sector-specific rules. Legislation also retains special rules for some regimes — so "everyone is in" is a good working assumption, but not a safe legal conclusion for an individual client.
SUNAT operates several variants of the Sistema de Emisión Electrónica (SEE). Depending on the chosen mode, a document may be created directly in SUNAT's system, generated by the taxpayer's own system or its PSE and transmitted to SUNAT, or sent to an accredited OSE which performs the tax validation and then reports the result to SUNAT.
OpenPeppol cites the Peruvian OSE arrangement as an example of delegated clearance, where fiscal validation is entrusted to regulated private operators and the result is passed to the tax authority. That is a description of the architectural principle — it is not evidence that Peppol is used in Peru.
Peru contains clearance elements, because acceptance by SUNAT or an OSE is critical to a document's tax validity. But it is not always the hard pre-clearance of Brazil or Chile, where nothing may reach the buyer before the platform responds.
Transmit late and the document does not acquire the status of a valid electronic invoice, even if the buyer already holds a commercial rendering of it. Only a document with a positive validation result counts as a valid CPE. The accurate label is therefore near-real-time post-issuance clearance — and B2C, with its daily summary, sits further from transaction-by-transaction control than B2B does.
The term "five-corner" is sometimes used as a functional analogy here — seller, seller's service provider, buyer and tax authority really can all participate. Technically it is not a Peppol five-corner model: there are no Peppol Access Points, no SMP or SML, and no Peppol BIS as the mandatory transport and document infrastructure.
A supplier to a public institution uses the same factura electrónica and the same SUNAT infrastructure as for any domestic B2B sale, choosing between the SUNAT, PSE or OSE channel. The obligation for covered suppliers has applied since 1 October 2021.
There is no dedicated government network comparable to European B2G Peppol, no national B2G Access Point and no EN 16931 profile. Exemptions exist for certain entities and document types, including specific Nuevo RUS cases, particular state funds, the liquidación de compra and documents governed by sector rules.
Consumer sales normally use the boleta de venta electrónica, and it behaves differently from a factura in ways that matter well beyond the checkout.
The practical consequence for a B2B buyer in Peru: accepting a boleta where a factura was needed is not a formatting inconvenience — it is usually the loss of the tax credit. Nuevo RUS remains one of the main categories where exceptions or voluntary participation still apply.
The mandatory format is UBL 2.1, localised by SUNAT's requirements, catalogues and validation rules. The familiar syntax is a trap worth naming: UBL here does not mean EN 16931, Peppol BIS Billing or any European profile, and a European document must be mapped into the SUNAT structure rather than merely converted.
A single PDF file is not an electronic tax invoice. The tax original is the signed XML together with its validation result — a document held only as a PDF, however complete it looks, is a rendering of something that may or may not have been accepted.
For export operations the invoice particulars may additionally be translated into a foreign language, within the same document or its readable representation — but the local SUNAT XML structure is preserved regardless.
Peppol is not a required or principal channel in Peru. The mandate is discharged through SUNAT's own SEE infrastructure, directly or through a PSE or OSE. A foreign buyer's Peppol ID does not displace the SUNAT CPE.
A provider may of course convert Peruvian data into Peppol BIS for commercial delivery to a foreign recipient. That conversion is an additional transport process: the tax original in Peru must still comply with SUNAT. Peppol Access Point certification can be useful for the international leg — it grants no regulated status in the Peruvian domestic market.
The Peruvian seller continues to issue a CPE under SUNAT's rules. The foreign buyer needs no Peruvian RUC — the document can carry a foreign identifier and the non-resident's name. Export invoices are now embedded in the general CPE regime and pass the same SUNAT controls as any other electronic document, with the additional export fields. No separate future date for Peppol or a ViDA-style cross-border mandate has been announced.
A foreign supplier not registered as a Peruvian taxpayer is not normally required to create a SUNAT CPE merely because the buyer is in Peru. For IGV credit on imported goods, SUNAT customs documents evidencing the assessment and payment of the tax are used. Where a non-resident's services are used in Peru, the right to credit is evidenced by documents showing payment of the corresponding IGV — not necessarily by a Peruvian electronic invoice from the foreign supplier.
ViDA does not apply to Peru directly. The intra-EU category simply does not exist here — only exports from Peru to the EU, imports from the EU, and services between a Peruvian and a European party. A supply from Peru to a buyer in France or Germany remains an export under SUNAT's rules; the European buyer may have its own accounting or reporting obligations, but the Peruvian invoice does not become an intra-EU invoice in the ViDA sense.
Peppol Access Point certification is not sufficient for a regulated role in Peru, and a foreign provider cannot occupy one from Europe. Both accredited roles require local tax presence.
One thing that is not what it looks like: the SUNAT mailbox is a tax portal for dealing with SUNAT — reached through Clave SOL — not an official invoice delivery box of the Slovak kind, not a Peppol address and not a general B2B delivery channel.
What has to be retained in Peru is not one file but a pair, and the second half is the one implementations forget.
Peruvian retention follows the general tax record-keeping and limitation rules rather than a single e-invoicing figure, and the period can be extended in defined circumstances. The safe operating rule is to keep the XML and the CDR for as long as SUNAT can still assess the period concerned, and to confirm the exact term for the taxes involved with a Peruvian adviser. What is not safe is archiving the readable representation and discarding the CDR.
The first consequence is not a fine but invalidity. If a factura or a related credit or debit note is not transmitted within the three-day window, the document does not acquire the status of a valid electronic payment document. Sending the buyer a PDF or holding a record in the ERP does not cure a missed transmission, and a negative validation result means the document must be corrected and properly reissued.
Failing to issue a document, or issuing one that does not meet the conditions for electronic issue, can lead to closure. A document meeting the basic conditions but lacking mandatory particulars or characteristics can attract the 50% UIT fine or closure.
The actual sanction depends on the taxpayer's table, repetition, voluntary correction, the gradualidad regime and how the breach was detected. No single fixed amount applies to all companies and all breaches — treat any headline figure with suspicion.
For an ordinary domestic B2B purchase, a valid electronic factura accepted by SUNAT or an OSE is the standard document supporting the right to IGV credit. The substantive conditions must also be met, the tax must be shown separately, and the purchase register requirements must be satisfied.
But the CPE is not the only legally admissible basis across the whole IGV system. The legislation also recognises customs documents on the import of goods, evidence of IGV paid on the use of non-resident services, particular special documents provided for by law, and permitted contingency documents where electronic issue is impossible for reasons outside the issuer's control.
The CPE is the principal basis for domestic purchases, not the only lawful one. And the reverse trap is more common in practice: an ordinary B2C boleta generally confers no right to tax credit at all, except in the special cases the law provides for.
Peru is a SUNAT integration, not a Peppol rollout — but the UBL 2.1 base means more of a European pipeline survives here than in Brazil or Mexico:
Peru is a finished, near-universal mandate that keeps closing its own gaps. Every taxpayer of consequence has issued CPE since 2022, exports since 2018, and since June 2026 a new business is an electronic issuer from the day it gets its tax number. SUNAT's direction of travel is deeper local integration — CPE with SIRE — not convergence on any international standard.
The architecture is worth stating precisely because it is softer than its neighbours': delegated validation through OSE operators, with a three-day window for the factura and a seven-day daily summary for the boleta. Acceptance is what makes a document valid — but it does not have to precede delivery.
For a European provider the UBL 2.1 base is the good news and the trap in one. More of the pipeline survives than in Brazil or Mexico — but SUNAT's localisation is a full mapping exercise, and the regulated PSE and OSE roles require a Peruvian entity, a RUC, ISO 27001 and 150 or 300 UIT of capital. Integrate with an accredited operator; do not plan a Peppol rollout.