Colombia Regulates Electronic Invoice Registration as a Security in RADIAN

The National Tax and Customs Directorate (DIAN) published Resolution 000015, which regulates the registration of the electronic sales invoices as a security. The commercialization of invoices in Colombia will be subject to registration in the RADIAN platform. The system will allow for users to consult and track documents. This electronic system allows the consultation and traceability of documents that meet the tax and commercial requirements.

New changes in the technical annex of the RADIAN system

The DIAN has published a draft of technical annex RADIAN 1.1. with modifications in the validation process of electronic invoices. It is important to highlight that the draft indicates that the adjustments contained in the new technical annex RADIAN 1.1, as well as the implementation of the “Receipt Acknowledgement” of the invoice and of the good/service must be implemented during the following 3 months counted from the publication of the official resolution. A deadline is being specified for companies and taxpayers to be able to use the official and mandatory platform of the DIAN for invoice management in Colombia.

In general terms, the RADIAN technical annex describes the characteristics, conditions, terms, and technological mechanisms for the generation, transmission, validation, delivery, and reception of the “events” associated with the electronic sales invoice as a security.

With this regulation the DIAN wants taxpayers to be able to register events like changes of document ownership. The hope is that it will increase trust between the parties in transactions that facilitate immediate liquidity, like factoring.

How Does the Electronic Invoice Commercialization System Work in Colombia?

The RADIAN platform provides an updated record of the events related to the electronic invoice as a security. It will allow users to track the status of documents.

As part of the process, the DIAN will register and validate the electronic invoice as a security circulating in national territory. Once the requirements and events are validated, the issuer or the legal owner will express their intention to put the electronic invoice into circulation as a security.

Requirements for Registering the Electronic Sales Invoice as a Security

• Securities must contain: reference to the law in which the title is incorporated; the signature of its creator (Article 621 of the Code of Commerce); all invoice information required for tax purposes as found in Article 617 of the Tax Statute, as well as those found in Article 11 of Resolution 000042 of May 5, 2020
• Expiration date of the electronic sales invoice
• Acknowledgement of receipt of the electronic sales invoice
• Receipt for the good or service provided
• Express acceptance, tacit acceptance, or grievance against the electronic sales invoice

The method of generation, transmission, validation, delivery, and receipt of these items must also be in line with the current “Electronic Sales Invoice Technical Annex."

Events Registered in RADIAN

“Events” are structured electronic documents that correspond to the actions taken by RADIAN users that are associated with the security.

The draft of the new technical annex 1.1 does not show any changes in the structure of the existing events. However, new events are presented that have an extension for new data (Transfer of Rights, Notification to debtor on transfer, Payment of transfer).

Event Types:

• Registration of the electronic invoice as a security circulating in national territory in the RADIAN platform
• Electronic endorsement
• Endorsement
• Mandate
• Payment report
• Payment of the electronic invoice as a security
• Limitation and termination of limitation for electronic sales invoice circulation
• Objection
• Rights Transfer
• Transfer notification to debtor
• Transfer payment

All events must be validated by the DIAN.

RADIAN Users

13 users have been defined, each with a different role:

• The Special Administrative Unit of the National Tax and Customs Directorate -DIAN
• The issuer of the electronic invoice as a security
• The acquirer/debtor/acceptor
• The legitimate owner(s) of the electronic invoice as a security
• The endorser of the electronic invoice as a security
• The endorsee of the electronic invoice as a security.
• Systems for electronic negotiation
• The principal
• The agent
• The guarantor
• The competent authorities
• The factor
• Technological suppliers

RADIAN users must have the necessary technological capacity to adapt to the system. The DIAN will qualify users that meet the requirements, one being that they make the changes set out in new technical annexes within three months from the date of publication.

The generation, transmission, delivery, and registration of events in RADIAN is considered part of the electronic invoicing system. This service may therefore be offered by technology providers.

Each RADIAN user must identify the type of software they will use for the generation, transmission, validation, and delivery of events associated with the electronic sales invoice as a security. They must register the software, and if it is being provided by a third party, they must verify that the supplier has been authorized by the DIAN to provide electronic invoicing services.

Resolution 000015 regulates the practice of factoring in Colombia, outlining how to manage it on the RADIAN platform. Factoring is a widely used financing system in Colombia in which invoices are prepaid to improve liquidity.

EDICOM, a technology partner specializing in electronic invoicing, is also recognized as a Certification Entity by the ONAC.

EDICOM’s Colombian Electronic Invoice Solution

EDICOM is an Authorized DIAN Technology Provider that offers a functional and certified electronic invoice solution for issuing and receiving invoices. The solution also offers functionalities such as the generation, transmission, delivery, and registration of events in RADIAN in an integrated and automatic way with its own internal management system.

• Management of the exchange of messages with both the issuer and the DIAN, so that an invoice can be considered as a Security Title (acknowledgements of receipt and tacit or express acceptance).
• When the tax and commercial requirements specified by the DIAN are met, the invoice is registered in the RADIAN platform.
• The EDICOM solution connects with the platform for issuing and consultation of events that provide information on the status of the document of value.