Electronic invoice in Panama

The Definitive Guide to Panama’s SFEP: Navigating delegated PAC clearance, dual-authorization timings, and compliance for B2G and regulated sectors

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Overview

Panama's system is the Sistema de Facturación Electrónica de Panamá (SFEP) — a local continuous transaction control model in which the invoice is a signed XML document that acquires full legal force only once it has received an Autorización de Uso from a qualified authorised provider (a PAC) or through the tax administration's own free service.

What distinguishes Panama from its Latin American neighbours is that the mandate is not universal. SFEP is compulsory for suppliers to the state, for new taxpayers and for a list of regulated categories — but many taxpayers may still use certified fiscal equipment instead. Panama has an obligation to document transactions fiscally; that is not the same as an obligation to issue an electronic XML invoice.

Autorización de Uso

without it the signed XML is not yet a valid electronic fiscal invoice

B/.36,000

the income ceiling for using DGI's free facturador — above it, a PAC is required

5 years

minimum retention — by both the issuer and the recipient

Timeline

Panama has never run a single big-bang date. SFEP began as a voluntary pilot and has been extended group by group ever since — and the most recent change is commercial rather than technical.

Already in force

26 November 2021

Law No. 256 establishes SFEP

SFEP was written into law as one of the officially permitted ways of documenting transactions, alongside fiscal equipment rather than replacing it. Executive Decree No. 25 of 27 June 2022 and Executive Decree No. 3 of 20 January 2023 followed.

1 January 2022

All new RUC registrations must use SFEP

Anyone registering a tax number for the first time from this date is inside the system. Pilot participants followed from the first working day of 2023.

31 October 2022

The B2G obligation takes effect

Originally set for 30 July 2022 and extended by DGI. From this date public institutions accept only authorised electronic invoices or their CAFE representation. See B2G.

2023

Sectors and special zones phase in

Maritime and fuel transport, small hotels and certain leasing from 2 January; international and domestic air passenger transport from 1 March; banks and financial institutions across 30 April, 30 June and 31 August; free zones and special regimes from 30 June. See Who must use SFEP.

1 January 2026

Resolution 201-6299 narrows the free facturador

Published on 29 July 2025 and in force from 1 January 2026, it restricts DGI's free issuing tool to taxpayers with gross annual income up to B/.36,000 and a maximum of 100 electronic documents per month — both conditions at once. Exceeding either means contracting a PAC.

No universal date has been published. Executive Decree No. 3 states that dates for activities not on the published calendar may be set later, but DGI's regulatory page carries no single deadline after which every remaining domestic B2B and B2C invoice must be issued through SFEP. That is an observation about the published instruments — not an official statement that the mandate will stop expanding.

Who must use SFEP

A Panamanian taxpayer must issue a fiscal document through one of the permitted mechanisms: certified fiscal equipment with data transmission, SFEP, or — in limited cases, principally for certain liberal professions — a traditional invoice. DGI continues to list all of these as current methods. In February 2026 it reaffirmed the duty to issue fiscal documents and mentioned the electronic invoice QR code, without announcing the abolition of fiscal equipment.

Where SFEP is compulsory

—Suppliers to central government, autonomous and semi-autonomous institutions, municipalities and other public bodies

—Anyone registering a new RUC from 1 January 2022

—Former pilot participants

—The 2023 sectors: parts of the maritime sector, fuel transport, small hotels and hostels below the room limit, certain leasing, international and domestic air passenger transport, banks, financial institutions, stock exchanges and insurers

—Free zones and special regimes — Colón Free Zone, Panamá Pacífico, Ciudad del Saber, oil free zones and the Área Económica Especial de Barú

Two regimes deserve a line of their own. Businesses under SEM and EMMA must use SFEP specifically, because ordinary fiscal equipment is not available to them. For those companies the choice between mechanisms does not exist.

Exemptions

The law preserves a list of exemptions from the obligation to use fiscal equipment and SFEP, subject to conditions — certain agricultural transactions within defined thresholds, real estate transactions executed by public notarial deed, individuals in employment relationships, some street and small-scale retail sellers, defined non-profit organisations, condominium contributions, some taxi services and other specifically listed activities.

An exemption does not always mean no documentation at all — other accounting, contractual or tax requirements may still apply.

The PAC clearance model

Panama runs a delegated clearance model: authorisation is performed by licensed qualified providers, with subsequent transmission to the central DGI repository.

The sequence

01 The seller builds the XML invoice against the local DGI XSD schema

02 The XML is signed with the issuer's qualified electronic signature

03 It goes to an authorised qualified provider, which validates structure, signature, mandatory data and business rules

04 On success the PAC issues the Autorización de Uso and the authorised invoice goes to the buyer

05 The PAC transmits the document and the authorisation details to DGI, as a rule within 48 hours of validation

So the model combines near-immediate authorisation at the PAC with a subsequent feed into DGI's central repository. It is not a fully synchronous scheme in which every invoice passes through a tax authority server before reaching the buyer — but without the PAC or DGI authorisation the document is not a full electronic fiscal invoice.

Two different timings, and this is the part to get right

B2B — pre-clearance

For a B2B invoice the buyer intends to use for input ITBMS — Panama's VAT — the PAC authorisation must be obtained before the invoice is passed to the buyer. The recipient must be able to verify that a valid authorisation exists; without one the document confers no tax rights.

B2C — post-authorisation

The electronic document may be handed to the consumer before authorisation completes, but the issuer must obtain it as a rule by the end of the next working day — or within a longer contingency period, usually up to 72 hours, where the applicable contingency regime applies.

The presence of external PACs does not make this a Peppol model. A PAC acts as a licensed tax validator, not as a Peppol Access Point. Panama is neither four-corner nor five-corner, neither ordinary decentralised exchange nor pure post-audit.

B2G

This is where the mandate is unambiguous. Since 31 October 2022, public institutions must accept only electronic invoices, or their graphical CAFE representation, that have already been authorised by DGI or a PAC. A supplier to the Panamanian state has no fiscal-equipment alternative.

In 2023 DGI provided a mechanism for exceptional individual extensions for state suppliers who documented to the procuring institution that they could not implement SFEP in time. Those were individual exceptions granted case by case — they did not suspend the general B2G obligation, and they should not be assumed still to be available.

B2B and B2C

Outside the compulsory categories, domestic B2B and B2C have no single date requiring electronic invoices only. Taxpayers may issue through SFEP or through authorised fiscal equipment, depending on which regime they fall into.

B2BWhere SFEP is used and the buyer wants input ITBMS credit, the authorisation must precede delivery of the invoice

B2CEither an SFEP electronic invoice with post-authorisation, or a fiscal receipt from authorised equipment. The consumer normally receives a CAFE with a QR code while authorisation completes within the prescribed window

The distinction that matters in planning: Panama mandates fiscal documentation, not the electronic XML invoice as such. A company can be fully compliant on certified fiscal equipment — unless it falls into one of the compulsory SFEP categories.

Formats, CAFE and PDF

The legally significant electronic invoice consists of the XML document conforming to the DGI XSD, the issuer's electronic signature, the Autorización de Uso, and the associated processing protocol data. All four elements together make the original.

Panama's system is not based on EN 16931, and neither UBL 2.1 nor UN/CEFACT CII is an SFEP format. The schemas, catalogues and document types are DGI's own. A European invoice must be mapped into the local XML — this is a tax mapping exercise, not a syntax conversion.

CAFE and PDF

The CAFE — the auxiliary receipt of the electronic invoice — is the graphical representation given to the buyer, carrying a QR code and the CUFE, the unique electronic invoice code. It is a representation of the document, not an independent electronic tax original.

A PDF or CAFE with no authorised XML behind it confers no tax rights. The CUFE, on the other hand, is genuinely useful: it can be checked in DGI's public consultation service without credentials, which makes verifying a supplier's document a routine step rather than a request.

Peppol in Panama

Peppol is not part of the national mandate. No Panamanian Peppol Authority has been published and no national EAS is established for SFEP. Peppol cannot deliver an invoice into the SFEP process, and a Peppol certificate confers no standing before DGI.

Where a Panamanian company and a foreign counterparty agree to use Peppol, the workable pattern is parallel: create and authorise the local SFEP XML, convert the data into Peppol BIS Billing or another agreed profile, send that to the foreign buyer, and retain the authorised SFEP XML as the Panamanian tax original. Peppol delivery is an additional commercial channel — it does not substitute for SFEP.

Export and import

There is no separate cross-border mandate. If a Panamanian seller is required to use SFEP, an export is documented in the same system with the appropriate document type and foreign recipient details — the technical catalogues provide dedicated types for exports, re-exports, foreign-source income, free zone operations and other overseas transactions.

Identifying a foreign buyer

—The "foreign recipient" recipient type

—A foreign tax or registration number

—A passport or other identifier where applicable

—The country code and a foreign address

Imports

An import can be reflected using the applicable local document type and transaction classification. But a foreign supplier who is not a Panamanian taxpayer does not become an SFEP issuer merely by supplying into Panama. The Panamanian requirements around import documentation, customs declarations, self-billing and local recognition of the purchase have to be assessed separately, taking account of the buyer's tax status and the nature of the transaction.

ViDA

Panama is not an EU member state, so ViDA creates no Panamanian obligations, the intra-EU B2B category does not exist here, and the European digital reporting deadlines are not Panamanian deadlines. There is no separate Panamanian cross-border e-invoicing date distinct from the seller's own status.

Working with a PAC

An OpenPeppol certification, ISO 27001 or Peppol Access Point status is not sufficient on its own. Three market-entry models are realistic for a European provider, in ascending order of commitment.

01 Integrate with an existing PAC. Connect the client's ERP, convert the input into the local SFEP XML, submit to a qualified PAC, receive the authorisation, return the XML, CAFE and status to the client, and convert into Peppol BIS or another international format where needed. The simplest route, with no national qualification required

02 Strategic partnership. Supply the technology platform to a local PAC. Note that from 2026 such an integrator or strategic partner must be declared to DGI — this is no longer a purely private arrangement

03 Own PAC qualification. Requires a full local structure, a RUC and operating permission, technical and legal vetting, a guarantee, and ongoing compliance with DGI's requirements

The 2026 declaration requirement for integrators is worth planning around early. If you are the platform behind a Panamanian PAC, your relationship is now visible to the tax administration — which changes the contractual and due-diligence conversation with a prospective partner.

Archiving

All issued documents must be kept for a minimum of five years, by both the issuer and the recipient. The obligation covers electronic invoices, credit notes and any other electronic tax voucher — the two-sided nature of it is the point most often missed by buyers.

What is archived is the authorised XML with its signature and Autorización de Uso — not the CAFE

The processing protocol data belongs with it — that is what evidences the authorisation actually happened

A CUFE lookup in DGI's public service proves a document existed — it is not a substitute for holding the file

For a buyer claiming input ITBMS, the archive is not paperwork — it is the evidence base for the credit. Keeping only the CAFE leaves you holding a picture of a right you can no longer prove.

Penalties

Law No. 256 penalises failing to issue an invoice, using an unauthorised issuing method, and other breaches of the duty to document transactions. The scale escalates sharply and reaches business closure.

First breachB/.500 to B/.1,000

Repeat breachB/.5,000 to B/.10,000, plus possible temporary closure of the business

Further repetitionB/.10,000 to B/.25,000, plus possible temporary closure

The buyer can be fined too. A purchaser who does not demand a fiscal document faces a penalty of the greater of B/.1 or 7% of the value of the transaction for which no invoice was requested. There are also sanctions for failing to display the mandatory notices informing customers of their right to demand an invoice.

Is an electronic invoice the only basis for input ITBMS? Not across the whole economy. Depending on the seller's status, the lawful proof may be an authorised SFEP invoice, a document from authorised fiscal equipment, or a traditional invoice in the limited cases still permitted. But where the transaction runs through SFEP and the buyer claims input ITBMS, the document must have been authorised before being handed over — and a PDF or CAFE without an authorised XML behind it grants nothing.

How we help

Panama should not be approached as a Peppol Access Point project. The target is integration with a qualified PAC and the local DGI schemas:

Conversion of ERP, UBL, CII or Peppol input into the local SFEP XML against the DGI XSD

Qualified electronic signature and submission to a PAC, with the Autorización de Uso returned

Correct handling of the two timings — pre-clearance for ITBMS-relevant B2B, post-authorisation for B2C with the contingency window

CAFE generation with QR code and CUFE, for the buyer and for the counter

Export document types with foreign recipient identification, and free zone classifications

Parallel Peppol BIS delivery to the European counterparty, with the SFEP XML retained as the tax original

Connection by API, SFTP and CSV, with ERP and IDoc source data

Frequently asked questions

Is e-invoicing mandatory in Panama?

Not universally — and this is the single most important difference from Panama's neighbours. SFEP is compulsory for suppliers to the state since 31 October 2022, for anyone registering a new RUC since 1 January 2022, for former pilot participants, and for the sectors and special zones phased in during 2023. Everyone else may still use certified fiscal equipment. Panama mandates fiscal documentation, not the electronic XML invoice as such, and no single date has been published for the remaining taxpayers.

Can I use my European Peppol Access Point in Panama?

Not for the mandate. Peppol is not part of the national system, no Panamanian Peppol Authority has been published and no national EAS exists for SFEP. A PAC is a licensed tax validator, not a Peppol Access Point, and Peppol certification confers no standing before DGI. What works is a parallel arrangement: authorise the SFEP XML locally, convert to Peppol BIS for the foreign buyer, and keep the authorised XML as the Panamanian tax original.

Do I need my own PAC qualification?

Usually not. The simplest route is to integrate with an existing qualified PAC — convert into SFEP XML, submit, receive the authorisation and return the XML, CAFE and status to the client, with no national qualification needed. A middle option is to supply the platform to a local PAC, though from 2026 such an integrator or strategic partner must be declared to DGI. Own qualification requires a full local structure, a RUC and operating permission, technical and legal vetting and a guarantee.

When exactly must the invoice be authorised?

It depends on the transaction. For a B2B invoice the buyer will use for input ITBMS credit, the PAC authorisation must be obtained before the invoice is passed to the buyer — the recipient must be able to verify a valid authorisation exists. For B2C the document may be given to the consumer first, with authorisation obtained as a rule by the end of the next working day, or within a longer contingency period of usually up to 72 hours. Separately, the PAC must transmit to DGI as a rule within 48 hours of validation.

Is a PDF or CAFE acceptable?

Only as a representation. The legally significant original is the XML conforming to the DGI XSD, together with the issuer's electronic signature, the Autorización de Uso and the processing protocol data. The CAFE is the auxiliary receipt given to the buyer, carrying a QR code and the CUFE. A PDF or CAFE with no authorised XML behind it grants no tax rights — though the CUFE itself is genuinely useful, since it can be checked in DGI's public consultation service without credentials.

Can I still use DGI's free invoicing tool?

Only if you are small. Resolution 201-6299, published on 29 July 2025 and in force from 1 January 2026, limits the free facturador to taxpayers with gross annual income up to B/.36,000 and a maximum of 100 electronic documents per month — both conditions must hold simultaneously. Exceeding either one means contracting an authorised qualified provider. In practice this moves most formally constituted businesses onto commercial PAC solutions.

Does the buyer face penalties too?

Yes, which is unusual. A purchaser who fails to demand a fiscal document can be fined the greater of B/.1 or 7% of the value of the transaction for which no invoice was requested. On the seller's side the scale runs from B/.500–1,000 for a first breach to B/.5,000–10,000 on repetition and B/.10,000–25,000 thereafter, with possible temporary closure of the business. There are also sanctions for not displaying the notices about the customer's right to demand an invoice.

How long must documents be kept?

A minimum of five years, and by both the issuer and the recipient — covering electronic invoices, credit notes and any other electronic tax voucher. What has to be retained is the authorised XML with its signature, the Autorización de Uso and the processing protocol data, not the CAFE. A CUFE lookup proves a document existed but is not a substitute for holding the file, and for a buyer claiming input ITBMS the archive is the evidence base for the credit.

Summary

Panama is a Latin American clearance jurisdiction with a deliberately partial mandate. SFEP is compulsory for state suppliers, new taxpayers, the 2023 sectors and the special regimes — but certified fiscal equipment remains a lawful alternative for many taxpayers, and no date has been published on which that changes.

The architecture is delegated clearance: a signed XML, an Autorización de Uso from a qualified provider, and transmission on to DGI within 48 hours. Two timings apply, and confusing them is expensive — pre-clearance where the buyer needs input ITBMS, post-authorisation for consumers.

The change to watch is commercial rather than legal. From January 2026 the free DGI facturador is confined to taxpayers under B/.36,000 and 100 documents a month, pushing most formally constituted businesses toward a PAC. For a European provider the practical route is unchanged: integrate with a qualified PAC and the local schemas, not with Peppol — and remember that from 2026 an integrator behind a PAC must be declared to DGI.

Resources

Sistema de Factura Electrónica de Panamá DGI's production SFEP environment — the system your integration actually talks to Listado de Proveedores Autorizados Calificados (PAC) The official register of qualified providers — where you find and verify the partner that will authorise your documents Base legal de la factura electrónica Law 256/2021, the executive decrees and the DGI resolutions including 201-6299 — the authoritative list, and the place a new date would appear Listado de Facturadores Electrónicos Check whether a Panamanian counterparty is registered as an electronic invoicer — name, RUC, affiliation date and activity Modalidad Facturador Gratuito The free issuing option and its current limits — worth checking before assuming a small client needs a PAC DGI — preguntas frecuentes sobre factura electrónica The official answers on authorisation timing, contingency and the edge cases the decrees do not spell out

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