Electronic invoicing in Argentina: CAE, CAEA, invoice types A, B, C, E and M, and the MiPyME electronic credit invoice

Key rules

A. The legal basis: duty to invoice and to keep records

• Duty to issue vouchers. Anyone who carries on any paid activity other than as an employee must keep records backed by vouchers and must "issue vouchers for the services or sales they make" that allow the taxes owed to be established clearly. The agency can limit the duty for very small operators (LPT art. 33, third paragraph).
• Duty to keep them. The agency can require responsible persons to keep duplicates and other vouchers for 10 years, or longer exceptionally (LPT art. 33, second paragraph). Books and documents must be available at the tax domicile (LPT art. 33, fifth paragraph).
• Duty to check what you receive. Taxpayers must verify that the invoices they receive for purchases are duly authorised by the agency; the Executive can limit this duty by objective indicators (LPT art. 33, unnumbered article added by Law 25.795).
• Scope of RG 1415. It covers sales of movable goods, services, leases of things, works, price-freezing deposits, transport and delivery of products, and weighing of farm products (RG 1415 art. 1), by any person or entity of LPT arts. 5 and 6 who carries out those operations habitually, including intermediaries (RG 1415 art. 2).
• Exceptions. RG 1415 Annex I, Apartado A lists who need not issue vouchers (for example public bodies that are not companies, public transport with numbered tickets, employees and domestic workers by the hour). The list was replaced by RG 5866 from 1 July 2026, which removed the old exception for financial entities and insurers except for specific operations (RG 5866 art. 1(e) and Annex; art. 4).
• Breach. Breaches of RG 1415 trigger the LPT penalties (RG 1415 art. 63); the same rule appears in RG 4291 art. 24 and RG 4290 art. 27.

B. Who must invoice electronically

• From 1 November 2026, VAT registered, exempt and non-VAT persons, and monotributistas, must back all their domestic operations with electronic vouchers under RG 4291 or with a "Controlador Fiscal" under RG 3561, or both, without telling ARCA which (RG 4290 arts. 6, 7, as replaced by RG 5893 art. 2; RG 5893 art. 5).
• Electronic only, no fiscal controller option, for (RG 4290 art. 7, second paragraph):
• a MiPyME invoicing a large company, or another MiPyME that adhered to the FCE regime;
• non-VAT persons (from 1 March 2027, RG 5893 art. 5, second paragraph);
• the activities in RG 4291 Annex II, for the operations listed there (for example private prepaid medicine, private primary and secondary schools, surety insurance, as amended by RG 5866 art. 2).
• Suppliers of the national public sector covered by Law 24.156 art. 8(a) to (d) must issue only electronic vouchers to those bodies (RG 4291 art. 1, third paragraph).
• Connectivity. A taxpayer who can choose may choose electronic vouchers only if it has internet access that ensures online issuance (RG 4290 art. 8).
• Duplicates. Taxpayers using the web service who sell to final consumers in the activities of the RG 4290 Annex must also keep electronic duplicates under RG 3685 (RG 4290 art. 10). Failure lets ARCA move them to new technology fiscal controllers (RG 4290 art. 11).
• Monotributistas without a point of sale will have one created by ARCA, linked to the Monotributo "Factura en línea" option and the tax domicile (RG 4291 art. 11, last paragraph, added by RG 5893 art. 3, from 1 November 2026).

C. Invoice classes (letters)

• Class A (RG 1415 art. 15(a)): issued by a VAT registered person to another VAT registered person or to a monotributista. When the buyer is a monotributista the invoice must carry the legend: "El crédito fiscal discriminado en el presente comprobante, sólo podrá ser computado a efectos del Régimen de Sostenimiento e Inclusión Fiscal para Pequeños Contribuyentes de la Ley Nº 27.618" (RG 1415 art. 15(a), as replaced by RG 5003/2021).
• Class B (RG 1415 art. 15(b)): issued by a VAT registered person to exempt persons, non-VAT persons (no responsables), final consumers, persons to be treated as final consumers, and Sujetos No Categorizados (point 4). The old point 3 was repealed by RG 5003/2021. A separate numbering sequence is used for A and B.
• Class C (RG 1415 art. 16, as replaced by RG 5198/2022): issued by VAT exempt or non-VAT persons and by monotributistas. A monotributista never shows VAT separately, whoever the buyer is (RG 1415 Annex II, A, IV(b)).
• Class E (RG 1415 art. 17): the voucher for an export, including to the special customs area, with an independent numbering sequence. Arts. 15 and 16 both exclude the export invoice, so a monotributista exporter also issues E, not C.
• "A" with "OPERACIÓN SUJETA A RETENCIÓN" (RG 5762 arts. 5(b), 10 to 19): the replacement for class M. A VAT registered person asking for class A for the first time gets this variant if it fails any of the RG 5762 art. 3 tests (no risk flags under RG 4132, solvency, no recent VAT deregistration while on M or this variant). The registered buyer must withhold 100% of the VAT and 6% income tax on the same base when paying (RG 5762 arts. 12, 13). It cannot be issued with a fiscal controller (RG 5762 art. 11, last paragraph) and is excluded from the FCE (RG 4367 art. 3, as replaced by RG 5764/2025).
• "A" with "PAGO EN CBU INFORMADA" (RG 5762 arts. 5, 20 to 22): an option for first-time applicants who pass the risk and deregistration tests but cannot prove solvency. The registered buyer must pay the invoice, net of any other withholdings, by bank transfer or deposit into the declared account (CBU); a monotributista buyer must pay the full amount that way (RG 5762 art. 22).
• Periodic review. Holders of A, A with retention legend and A with CBU legend are evaluated each four month period on their VAT digital book or F. 2051; the evaluation runs in February, June and October, with a preview in the first 7 calendar days and notification by the 20th (RG 5762 arts. 23 to 25). ARCA can also move a taxpayer to the retention legend for CAEA or F. 2051 failures in 2 consecutive or 3 alternate months in the last 12 months (RG 4290 art. 25, as replaced by RG 5785/2025).
• Banks and insurers are exempt from Title I of RG 5762 (the first-time class A procedure) from 1 July 2026 (RG 5830 arts. 1, 2).

D. Mandatory content

RG 1415 art. 18 and Annex II, Apartado A list the minimum data for classes A, B, C and E. Electronic invoices must contain the CAE, the voucher type code, any code showing that VAT cannot be credited, and all Annex II data except the printer data and the words "ORIGINAL" and "DUPLICADO" (RG 4291 art. 14).

• Issuer: name, commercial address, CUIT, gross income registration number, the VAT status legend ("IVA RESPONSABLE INSCRITO", "IVA EXENTO", "NO RESPONSABLE IVA", "RESPONSABLE MONOTRIBUTO", "MONOTRIBUTO TRABAJADOR INDEPENDIENTE PROMOVIDO" or "MONOTRIBUTISTA SOCIAL"), 13 digit numbering (5 digits for the point of sale and 8 for the number), start of activities date, the authorisation code preceded by "C.A.I.", "C.A.E." or "C.A.E.A.", and its expiry date (Annex II, A, I(a) and V(4)).
• Buyer: for registered, exempt, non-VAT and monotributo buyers, name, address, CUIT and the status legend; for uncategorised buyers the legend "SUJETO NO CATEGORIZADO" (Annex II, A, II(a), (c), (e), (f)). The buyer must give the seller its CUIT and status (Annex II, A, V(10)). Since RG 5616 art. 2, electronic vouchers must also show the buyer's VAT status for the operation.
• Final consumer buyer (Annex II, A, II(d), as replaced by RG 5866 art. 1(f), from 1 July 2026): the legend "A CONSUMIDOR FINAL"; if the amount is ARS 10,000,000 or more (about US$ 6,394.27), the buyer's DNI, CUIL or CDI, or for foreigners an identity document of the country of origin or passport. Name and address can be filled with "NR" or zeros. If the buyer asks, the invoice must show its CUIT, regardless of amount, so the buyer can deduct the expense for income tax.
• Export buyer: name, address, the foreign tax ID (or CUIT), and the legend "IVA EXENTO OPERACION DE EXPORTACION" (Annex II, A, II(g)).
• Operation: description, quantity, unit and total prices, the exchange rate if in foreign currency, every other item affecting the total, and, for consumer sales under Law 27.743 art. 99, the amount of "Otros Impuestos Nacionales Indirectos" (Annex II, A, III(a) to (f)).
• VAT treatment (Annex II, A, IV(a), as replaced by RG 5614 art. 2(5)): a registered seller invoicing a registered person or a monotributista shows the rate, the VAT amount, other taxes not in the net price and any perception; invoicing an exempt, non-VAT or final consumer buyer, it must show the VAT contained in the price.
• Consumer transparency block (Annex II, B(g)(1); RG 4291 art. 15, third paragraph): bottom left, the title "Régimen de Transparencia Fiscal al Consumidor (Ley 27.743)", then "IVA Contenido" and below it "Otros Impuestos Nacionales Indirectos", each with its amount. Fiscal controllers print the title "TRANSPARENCIA FISCAL" with the same two lines, abbreviations allowed (RG 5614 arts. 3, 4).

E. Deadlines to issue and deliver

RG 1415 art. 13, table replaced by RG 5866 art. 1(a) from 1 July 2026:

• Sale of movable goods: by the last day of the calendar month of delivery or of making the goods available, whichever is earlier; delivered within 10 calendar days of issuance.
• Services and works: the day the service or work is completed or the price is collected in whole or in part, whichever is earlier.
• Continuous services (no fixed end date): the last day of each calendar month, unless the price was collected or the service finished earlier.
• Leases of things: the due date for each period's rent.
• Price-fixing advances: the day the advance is collected.
• Utilities and telecoms: by the first due date for payment.
• Directors' and statutory auditors' fees: the day the individual allocation is made by the shareholders' meeting or board; delivered within 10 calendar days.
• Final consumers: delivery or availability at the moment of the operation (sale: delivery or collection, whichever is earlier; services: completion or collection, whichever is earlier) (RG 1415 art. 13, last paragraph).
• Date window for the CAE request: the request may be sent within 5 calendar days before or after the date on the voucher (same calendar month if before); for services, 10 calendar days (RG 4291 art. 9). For Factura E of goods the window is 5 calendar days (RG 2758 art. 6(c)). For FCE, up to 5 calendar days after or the day before the voucher date (RG 4367 art. 5).
• Delivery of the electronic voucher: the seller must make it available within the art. 13 terms once the CAE is granted; for consumer sales in RG 4290 Annex activities it must be printed unless the buyer accepts another medium (RG 4291 art. 14).

F. Credit and debit notes

• Notes for discounts, rebates, returns, rescissions, interest and similar must meet the requirements of the original voucher (RG 1415 Annex IV, A, 2).
• Electronic notes must be requested only with the specific codes 02, 03, 07, 08, 12, 13, 52 or 53 of ARCA's voucher table (RG 4291 art. 8(c)). RG 4290 art. 3 lists the current codes, including 002/003 (A), 007/008 (B), 012/013 (C) and 052/053 (A with retention legend).
• For Factura E, a note must state the original voucher number and relate to a single export voucher (RG 2758 art. 11, last two paragraphs). Once the CAE is granted, an E invoice can only be corrected with a credit or debit note (RG 2758 art. 8).
• For FCE, see section H.

G. CAE, CAEA and contingency

• CAE. ARCA authorises or rejects each request. Through "Comprobantes en línea" one CAE is given per request; through the web service, one per record (RG 4291 art. 12). For class A, if ARCA finds that the buyer's VAT or monotributo status is inconsistent, it still grants the CAE but with observation codes, and the VAT shown cannot be credited (RG 4291 art. 12, last paragraph).
• CAE is formal only. It does not recognise that the operation exists or is legitimate (RG 4291 art. 23).
• CAEA from 1 August 2026 (RG 5782, in force per art. 9 as replaced by RG 5852 art. 1): an exceptional procedure for the contingencies of RG 4290 Title III. Requested only through the web service (RG 5782 art. 2). One CAEA per taxpayer per half month: days 1 to 15, or 16 to the end of the month; requested from 5 calendar days before the period or during it (RG 5782 art. 4). Separate points of sale (art. 5). Every operation must be reported, with date and time, per point of sale, plus unused points of sale, from the day after the start of the period up to the 8th calendar day after its end (art. 6). Covered vouchers: A, A with CBU legend, A with retention legend, B and C invoices, receipts and notes (art. 3). RG 2926 was repealed and references to it now point to RG 5782 (arts. 7, 8).
• Contingency order. Web service users must use the CAEA as the first contingency option; the alternatives are a new technology fiscal controller or RG 100 printed vouchers (self printer or a manual booklet, the booklet only for "Comprobantes en línea" users) (RG 4290 art. 16, as replaced by RG 5785). Online channels can back each other up (RG 4290 art. 17).
• Limits. Contingency use is not exceptional if, in 2 consecutive months or 3 alternate months in a calendar year, CAEA or CAI vouchers reach 5% or more of the branch's monthly vouchers, or the CAEA time exceeds 5% of ARCA's monthly service availability per branch (RG 4290 art. 18). ARCA can then restrict CAEA or CAI, or require fiscal controllers for a year (RG 4290 art. 19).

H. MiPyME Electronic Credit Invoice (FCE)

• When compulsory: in every commercial operation in which a MiPyME must issue an electronic invoice or receipt to a large company, it must issue an FCE instead; between MiPyMEs it is optional (Law 27.440 art. 1). A MiPyME buyer can adhere voluntarily (Decree 471/2018 Annex I art. 1; RG 4367 art. 22), may leave at any time, and must then wait 1 year to re-enter (Res. MPyT 209/2018 art. 5).
• Large company: a company whose annual sales exceed the "Mediana tramo 2" cap for its sector (RG 4367 art. 2). ARCA updates the list every year and notifies it by the 7th business day of May (RG 4367 art. 2). Additions become obliged from the first business day of December after publication, and exclusions stop being obliged from the same date (Res. MDP 338/2020 arts. 1, 2, as replaced by Res. 80/2020).
• Exclusions: public utility invoices, invoices to final consumers, operations through consignees or commission agents, and invoices to the State unless it has a company form (Law 27.440 art. 22). Since 2 October 2026, financial entities that are not on the large company list are not obliged recipients (Res. SICPyME 400/2026 art. 1). Taxpayers authorised only for class M (now A with retention legend, RG 5762 art. 31) are excluded (Res. MPyT 209/2018 art. 4).
• Minimum amount: the regime applies by economic sector and from a minimum amount per voucher fixed by the authority (Res. SSP 5/2019 art. 1; Res. SSP 17/2019 art. 1). The amount schedule is in an annex that is not legible in the Infoleg text (unconfirmed).
• Vouchers: codes 201 to 213 (FCE A, B and C, with their debit and credit notes) (RG 4367 art. 3).
• Before issuing: the MiPyME must check in the "Registro de Facturas de Crédito Electrónicas MiPyMEs" whether the buyer is obliged (RG 4367 art. 4), and must choose a transmission option: the BCRA open circulation system, or a collective deposit agent (RG 4367 art. 4, last paragraph, added by RG 4919/2021).
• Content: place and date, numbering, a certain due date for payment, CBU or alias, CUITs, amount in figures and words, issued through ARCA systems, the delivery note number if any, and the tacit acceptance wording; missing any of these makes the FCE invalid as an enforceable title and as a commercial document (Law 27.440 art. 5). A wrong due date must be rejected (RG 4367 art. 9).
• Delivery and receipt: the seller must deliver it to the buyer by 24:00 of the next day after issuance (RG 4367 art. 7). ARCA puts it in the buyer's electronic tax domicile, and it is deemed received at 24:00 of the day after that (RG 4367 art. 14).
• Acceptance period: if not cancelled or accepted and recorded within 15 calendar days of receipt, it is tacitly accepted for the full amount (Law 27.440 art. 6). 21 calendar days from 1 November 2025 to 31 October 2026 (Res. SEPyME 219/2025 art. 1(a)).
• Rejection: only for damaged goods, defects or quantity differences, divergence in terms or prices, mismatch with the contracted service, formal defects, non delivery, or full payment (Law 27.440 art. 8). The rejection term in the law refers to CCyC art. 1145, temporarily set at 21 calendar days to 31 October 2026 (Res. SEPyME 219/2025 art. 1(b)). Rejection of the invoice rejects its notes automatically (RG 4367 art. 16).
• Notes: debit and credit notes adjusting the FCE must be issued within the acceptance period or until express acceptance, whichever is first (Law 27.440 art. 4, last paragraph). After acceptance, notes do not change the tradable amount, and credit notes cannot cancel the operation (RG 4367 art. 12). FX differences on foreign currency FCEs are documented by notes after acceptance and by the end of the month of acceptance (RG 4367 art. 11, as replaced by RG 4919).
• Effect: once accepted, the FCE is an enforceable title and non cartular security (Law 27.440 art. 4), acceptance is unconditional and irrevocable (art. 9), it can be traded on CNV markets or factoring platforms (arts. 12, 13), any ban on transferring it is void (art. 17), and it cannot be transferred in the 3 bank business days before maturity (art. 18).
• Withholdings: at express acceptance the buyer reports national and local withholdings; on tacit acceptance a percentage set by joint rule is deducted automatically (RG 4367 art. 18; Decree 471/2018 Annex I art. 25).
• Assignment carve out: until 31 October 2026, invoices from a MiPyME to a large company assigned under CCyC art. 1618 before cancellation, rejection or acceptance are outside the regime (Res. SEPyME 219/2025 art. 2).

I. Factura E for exports

• Goods exporters registered with customs and Exporta Simple users must issue electronic E vouchers under RG 4291 for the customs subregimes in the RG 2758 Annex (RG 2758 art. 1, as replaced by RG 4480/2019). Channels: web service, "Comprobantes en línea", or "Facturador Plus" (up to 50 records per batch) (RG 2758 art. 4). Each E invoice must state payment terms and the Incoterm (art. 6(b)(2)) and be linked to the customs declaration, with the destination country (art. 11).
• Service exporters. RG 1415 art. 17 requires class E, and RG 1415 art. 47 (as replaced by RG 5866) requires a specific point of sale code for export (class E) vouchers. No text in the source files expressly obliges a service exporter to issue class E electronically: RG 2758 art. 1 covers goods exporters only, RG 4290 art. 6 refers to domestic operations, and the RG 4290 art. 3 code table lists A, B and C only (unconfirmed).
• Exchange rate. The invoice must show the exchange rate used. When the operation is settled in the same foreign currency, the rate is the Banco de la Nación Argentina "tipo de cambio vendedor divisa" at the close of the previous foreign exchange business day before issuance; for electronic vouchers the system fills it in automatically (RG 1415 Annex II, A, III(d), as replaced by RG 5616 art. 1; RG 5616 art. 2). If the voucher date is later than the request date under RG 4291 art. 9, the previous day is counted from the date on the voucher, or from the request date (RG 5616 art. 2). For currencies without a BNA quote, the issuer reports the rate used (RG 1415 Annex II, A, III(d), last paragraph).

J. Records and digital signature

• RG 1415 art. 61 sends retention to Decree 1397/1979 art. 48 (unconfirmed). Delivery notes, order notes and budgets must be kept at least 2 years (RG 1415 art. 61, second paragraph; Annex IV, A, 3). Spoiled vouchers are marked "ANULADO" and kept (art. 61, third paragraph). Vouchers stay available at the tax domicile (art. 60).
• The receiver of an electronic voucher may store it on an independent medium under RG 3685 arts. 26 to 28 (RG 4291 art. 22).
• Law 25.506 recognises digital documents as satisfying writing (art. 6), digital signatures as satisfying a handwritten signature (art. 3), digitally signed documents as originals (art. 11), and keeping digitally signed documents as meeting a legal duty to keep records, provided they stay accessible and show origin, destination, date and time (art. 12). The invoicing resolutions do not require the issuer to sign the invoice digitally; the CAE is the authorisation.

K. Penalties

• Closure: 2 to 6 days of the establishment, office or mobile point of sale, where the value of the goods or services exceeds ARS 20,000 (about US$ 12.79), for anyone who does not issue invoices in the form ARCA requires (LPT art. 40(a), amount per Law 27.799 art. 28). The same applies to missing or defective purchase and sales records (art. 40(b)), transport without documents (art. 40(c)), and not having purchase invoices for the goods held (art. 40(e)).
• Repeat offence: minimum and maximum double if another art. 40 offence is committed within 2 years of the previous detection (LPT art. 40, penultimate paragraph). A licence or registration can also be suspended where the Executive grants it (last paragraph).
• Procedure: an inspection report (acta) with a hearing set 5 to 15 days later; the administrative judge decides at the hearing or within 2 days (LPT art. 41). During closure all activity stops but wages must still be paid (art. 43). Breaking a closure: 10 to 30 days of arrest and a new closure for double the time (art. 44).
• Formal duty fines: ARS 150,000 to ARS 2,500,000 for breaches of formal duties (LPT art. 39, first paragraph, per Law 27.799 art. 19).
• Consumer transparency: breaches of Law 27.743 art. 99 are subject to the LPT art. 40 sanction (Law 27.743 art. 99, third paragraph).
• Regime specific measures: ARCA can deny CAEA, give partial CAI, impose electronic vouchers on fiscal controller users who fail to report, or move a taxpayer to the retention legend (RG 4290 art. 25); FCE invoices missing a legal requirement are not valid invoices "with the corresponding tax effects" (Decree 471/2018 Annex I art. 5).

Step by step

1. Register and get your status right. Have a CUIT with Clave Fiscal at the security level required: level 3 for "Comprobantes en línea" and for point of sale administration (RG 4291 arts. 6(c), 11; RG 1415 art. 47). Your VAT status (registered, exempt, non-VAT or monotributo) decides the letter you issue. Keep your premises declared in "Sistema Registral", "F 420/D" (RG 1415 art. 47).

2. Ask for class A, if you are VAT registered. First-time applicants file F. 855 (individuals and estates) or F. 856 (others) in "Regímenes de Facturación y Registración (REAR/RECE/RFI)", option "Habilitación de Comprobantes" (RG 5762 art. 2). Solvency is proved by personal assets returns or by real estate and vehicles above set percentages of the personal assets tax minimum (art. 4). Documents not validated by the system go through "Presentaciones Digitales" within 15 calendar days, or the request lapses (art. 4). If you get the retention legend, you can object through "Presentaciones Digitales"; ARCA can ask for documents within 10 business days and decides within 15 business days (arts. 6 to 8). If you want the CBU legend, declare the CBU in the same F. 855/856 (art. 20).

3. Enable a point of sale. Use "Administración de Puntos de Venta y Domicilios" (RG 1415 art. 47). For a new business, at least 3 business days before starting; for a new branch, 3 business days before it opens; closures within 5 business days; a closed point of sale can never be reused (RG 1415 art. 47(a) to (c)). Each point of sale is tied to one invoicing system and the VAT status, with a specific code for export (class E) vouchers (art. 47). Web service and "Comprobantes en línea" need different points of sale (RG 4291 art. 11). If you will need CAEA for contingencies, enable separate CAEA points of sale too (RG 5782 art. 5). FCE may use the same points of sale (RG 4367 art. 4).

4. Choose the channel. (RG 4291 arts. 6, 7) * Web service: system to system, for invoicing software and ERPs; technical manuals are on the "Factura Electrónica" microsite. Only web service users with VAT registration may become self printers (art. 26). * "Comprobantes en línea": the online service with Clave Fiscal level 3. * "Facturador Móvil": the mobile app of "Comprobantes en línea", downloadable from app stores (art. 7). * "Facturador": for electronic "Tique C" and "Tique Nota de Crédito C" (art. 6, last paragraph). * Exempt persons and monotributistas may use only the web service and "Comprobantes en línea" (art. 6, penultimate paragraph). For goods export E invoices, "Facturador Plus" is also available (RG 2758 art. 4(c)).

5. Prepare the voucher. Fill in the RG 1415 Annex II data: letter and code, buyer data and VAT status, description, prices, VAT treatment, transparency block for consumers, buyer ID if a consumer sale is ARS 10,000,000 or more, currency and rate for foreign currency (sections D and I above). For an FCE, check the registry first and pick the transmission option (RG 4367 art. 4).

6. Get the CAE within the date window. 5 calendar days around the voucher date, 10 for services (RG 4291 art. 9). Read the response: approved, approved with observations (VAT not creditable for class A buyers with status problems), or rejected with codes (RG 4291 art. 12).

7. Deliver. Within the RG 1415 art. 13 deadlines, or at the moment of a consumer sale (printed for RG 4290 Annex activities unless the buyer accepts another medium; RG 4291 art. 14). For an FCE, by 24:00 of the next day (RG 4367 art. 7).

8. If the system is down. Web service users: CAEA first, then fiscal controller or RG 100 printed vouchers; report CAEA vouchers by the 8th calendar day after the half month (RG 4290 art. 16; RG 5782 art. 6). Keep contingency use under 5% (RG 4290 art. 18).

9. Corrections. Issue a credit or debit note with the right code, linked to the original (RG 4291 art. 8(c)). For an FCE, observe the acceptance period limits (Law 27.440 art. 4).

10. Record and keep. Registration of operations runs through the VAT digital book (RG 4597, mentioned in RG 5616 and RG 5762 art. 23) (unconfirmed). Keep vouchers available at the tax domicile (RG 1415 art. 60), for the period of LPT art. 33 and Decree 1397/1979 art. 48 (unconfirmed).

Cost and time. The resolutions set no fee for the CAE, CAEA, points of sale or "Comprobantes en línea" (unconfirmed). The ARCA side is online and immediate for the CAE; set up time is driven by the class A procedure and the 3 business day point of sale notice.

Costs and timelines

Table 1. Invoice class by issuer and recipient (domestic operations)

Old statuses: the legend "responsable no inscripto" was removed from RG 1415 Annex II by RG 1697/2004 (Annex II, A, II(b) and (f), Infoleg notes). Annex II still keeps "NO RESPONSABLE IVA" and "SUJETO NO CATEGORIZADO". How these map onto the status codes that RG 5616 art. 2 requires in electronic vouchers is not stated in the source files (unconfirmed).

Table 2. CAE vs CAEA

Table 3. FCE MiPyME thresholds and deadlines

Table 4. Penalties

Whether LPT art. 40 currently carries a fine in addition to closure is unclear in the source text: the opening paragraph only provides closure, yet the penultimate paragraph speaks of doubling "the sanctions of fine and closure" (unconfirmed).

Table 5. Timeline of norms (2001 to 2026)

Worked examples

Example 1. VAT registered shop sells to a consumer for ARS 1,210,000 including 21% VAT

A VAT registered retailer sells a television to an individual who pays ARS 1,210,000 (US$ 773.71). VAT is 21% (VAT law art. 28), computed on the net price (VAT law art. 39).

1. Letter: B, because the buyer is a final consumer (RG 1415 art. 15(b)(1)).
2. Net price: 1,210,000 ÷ 1.21 = ARS 1,000,000 (US$ 639.43).
3. VAT contained: 1,000,000 × 21% = ARS 210,000 (US$ 134.28). Check: 1,000,000 + 210,000 = 1,210,000.
4. Other national indirect taxes: a television sold at retail with no excise tax in this example: ARS 0 (unconfirmed).
5. Transparency block (bottom left):
6. "Régimen de Transparencia Fiscal al Consumidor (Ley 27.743)"
7. "IVA Contenido: $ 210.000,00"
8. "Otros Impuestos Nacionales Indirectos: $ 0,00" (RG 1415 Annex II, B(g)(1); RG 4291 art. 15)
9. Buyer identification: ARS 1,210,000 is below ARS 10,000,000, so the legend "A CONSUMIDOR FINAL" is enough and name and address may be "NR" (RG 1415 Annex II, A, II(d)). If the buyer asks for the invoice with their CUIT to deduct the expense, it must be shown.
10. Timing: the voucher must be delivered at the moment of delivery or payment, whichever is first (RG 1415 art. 13, last paragraph).

Variation. The same shop sells furniture for ARS 12,100,000 (US$ 7,737.07): net ARS 10,000,000, VAT ARS 2,100,000 (US$ 1,342.80). The amount is at or above ARS 10,000,000, so the invoice must show the buyer's DNI, CUIL or CDI, or the passport of a foreign buyer.

Comparison with a class A invoice. Sold to a VAT registered company for the same ARS 1,210,000, the invoice is class A and shows the net ARS 1,000,000, the rate 21% and VAT ARS 210,000 as separate lines after the description, plus any perception (RG 1415 Annex II, A, IV(a)(1); B(f)). The buyer may credit the ARS 210,000 as input VAT unless the CAE carries an observation code (RG 4291 art. 12).

If the seller holds "A OPERACIÓN SUJETA A RETENCIÓN". The registered buyer withholds 100% of VAT, ARS 210,000, and 6% income tax on the same base, ARS 1,000,000 × 6% = ARS 60,000 (US$ 38.37), and pays ARS 1,210,000 − 210,000 − 60,000 = ARS 940,000 (US$ 601.06) (RG 5762 arts. 12 to 14). A higher RG 830 withholding prevails (art. 12, last paragraph). Retention codes 499 (VAT) and 99 (income tax) (art. 16).

Example 2. Factura E for USD 5,000 of software services

An Argentine company (VAT registered) finishes a USD 5,000 software development project for a client in Spain on Friday 30 October 2026, to be paid in US dollars.

1. Letter: E, from the export point of sale (RG 1415 arts. 17, 47).
2. Deadline: for services, the day the service is completed or the price is collected, whichever is earlier: 30 October 2026 (RG 1415 art. 13).
3. Buyer data: name, address and the client's Spanish tax ID; legend "IVA EXENTO OPERACION DE EXPORTACION" (RG 1415 Annex II, A, II(g)).
4. Exchange rate: the invoice is issued in USD and settled in USD, so the rate is the BNA "vendedor divisa" closing rate of the previous exchange business day, Thursday 29 October 2026, filled in by the system (RG 1415 Annex II, A, III(d); RG 5616 art. 2). This page cannot quote that rate. For illustration only, assume ARS 1,500.00 per US$.
5. Peso amount on the voucher: 5,000 × 1,500.00 = ARS 7,500,000 (US$ 4,795.70 at the 23 Oct 2026 dólar MEP rate).
6. VAT: none shown; export legend instead.
7. Why MEP does not apply: at the MEP rate, the same USD 5,000 would be ARS 7,819,500. The difference, ARS 319,500 (US$ 204.30), shows why using a market rate on the voucher instead of the BNA rate is a formal error.
8. CAE window: if requested later, check the window. RG 4291 art. 9 allows 10 calendar days for services; RG 2758 art. 6(c) allows 5 for goods E invoices (unconfirmed).

Example 3. FCE acceptance timeline

A small manufacturing MiPyME delivers parts to a company on ARCA's large company list and issues an FCE A for ARS 30,250,000 (US$ 19,342.67): net ARS 25,000,000 (US$ 15,985.68) and VAT ARS 5,250,000 (US$ 3,356.99). It assumes the amount is above the FCE minimum (unconfirmed).

1. Monday 2 November 2026: the FCE is issued with a CAE through "Comprobantes en línea" after checking the registry, choosing the transmission option, and stating a due date of 4 January 2027 and the seller's CBU (RG 4367 arts. 4, 9; Law 27.440 art. 5). ARCA posts it to the buyer's electronic tax domicile the same day.
2. By 24:00 on Tuesday 3 November 2026: the seller must also deliver it to the buyer (RG 4367 art. 7). The FCE is deemed received at 24:00 on 3 November (RG 4367 art. 14).
3. Acceptance period: the temporary 21 day term ended on 31 October 2026 (Res. SEPyME 219/2025 art. 1). Unless extended, the law's 15 calendar days apply: counting from 4 November, day 15 is Wednesday 18 November 2026 (unconfirmed). If a 21 day term were extended, the end would be Tuesday 24 November 2026.
4. Notes: a credit note for a 2% quality discount (ARS 605,000 including VAT, US$ 386.85) must be issued by 18 November or before express acceptance, whichever is earlier (Law 27.440 art. 4). The amount to negotiate becomes ARS 30,250,000 − 605,000 = ARS 29,645,000 (US$ 18,955.82).
5. Buyer's options by 18 November: accept expressly (reporting the paying bank and CBU, and its withholdings), reject for one of the art. 8 causes, or report payment (RG 4367 arts. 15, 18). If it does nothing, the FCE is accepted tacitly for the total and becomes an enforceable title (Law 27.440 art. 6).
6. Payment term test: the due date of 4 January 2027 is more than 15 days after receipt, so the FCE is an enforceable title from acceptance (Law 27.440 art. 4(c)).
7. Trading: after acceptance, ARCA makes it available to the chosen system; it cannot be transferred during the 3 bank business days before 4 January 2027 (RG 4367 art. 21; Law 27.440 art. 18).

Example 4. CAEA cycle under RG 5782

A supermarket chain using the web service suffers an outage on 20 November 2026.

1. Period: 16 to 30 November 2026 (RG 5782 art. 4(b)).
2. Request: any time from 11 November (5 calendar days before the period) to 30 November (art. 4).
3. Use: CAEA vouchers from the dedicated contingency points of sale only during the outage (art. 5; RG 4290 art. 16(a)).
4. Report: all CAEA vouchers with date and time, and unused CAEA points of sale, from 17 November to 8 December 2026 (art. 6).
5. Limit check: if the branch issued 40,000 vouchers in November, 5% is 2,000. Issuing 2,000 or more CAEA vouchers in November counts as non exceptional; 2 such months in a row, or 3 in the year, allows ARCA to restrict the CAEA (RG 4290 arts. 18, 19).

Practical traps

• The CAE is not a seal of approval. It checks form only (RG 4291 art. 23). A buyer who receives a class A invoice with an observation code cannot credit the VAT (RG 4291 art. 12), and every buyer must check that invoices received are authorised (LPT art. 33, unnumbered article).
• Using MEP or any market rate on a foreign currency invoice. For same currency settlement the rate is the BNA "divisa" seller rate of the previous business day, and the system fills it in (RG 5616 arts. 1, 2).
• Pre-2025 consumer invoices. Systems built before RG 5614 often omit the transparency block or put the VAT in the wrong place. Since 1 April 2025 it is compulsory for everyone (RG 5614 art. 6(b)), and the sanction is LPT art. 40 (Law 27.743 art. 99).
• Old consumer ID thresholds. Since 1 July 2026 the consumer ID trigger is ARS 10,000,000 (RG 1415 Annex II, A, II(d)). Templates with older thresholds are out of date.
• Searching for "class M". Since 1 December 2025 the M letter is replaced by "A OPERACIÓN SUJETA A RETENCIÓN" and every legal reference to M is read that way, except in the fiscal controller rules (RG 5762 art. 31). Old printed M booklets can still be used until their authorisation expires (art. 27). Buyers must still withhold.
• CAEA as a routine method. From 1 August 2026 it is only for contingencies; over 5% use for 2 consecutive or 3 alternate months triggers restrictions (RG 4290 arts. 18, 19). Main CAEA users had to migrate to CAE.
• Outdated cross references. RG 4367 art. 8 still refers to RG 2926 for FCE issued with CAEA; RG 5782 art. 8 says such references now mean RG 5782, but RG 5782 allows CAEA only in contingencies (unconfirmed).
• The 21 day FCE term expired on 31 October 2026. Large buyers that planned their payables process on 21 days now have 15 unless a new resolution appears (unconfirmed).
• Point of sale closures are final. A closed point of sale cannot be reused (RG 1415 art. 47(c)).
• Monotributistas exporting services issue E, not C (RG 1415 arts. 16, 17), and the automatic point of sale ARCA creates for them is a Monotributo "Factura en línea" point, not an export point (RG 4291 art. 11).
• Contingency booklets for the A legends are limited to 100 vouchers (RG 5762 arts. 11(b), 21(c)).
• Services billed late. The deadline for services is the earlier of completion or collection, so an advance payment triggers the invoice the day it is collected (RG 1415 art. 13).

Recent changes

• 13 Dec 2024: RG 5614 introduces the transparency block and repeals the old authorisation to show VAT to consumers (RG 5614 art. 2(1), (3), (9)).
• 18 Dec 2024: RG 5616, BNA rate rule; web service version mandatory from 15 April 2025, "Comprobantes en línea" from 15 January 2025, "Facturador Móvil" and "Facturador" from 5 March 2025 (RG 5616 art. 5).
• 1 Jan 2025 and 1 Apr 2025: transparency compulsory for large companies (VAT and internal taxes), then for all (RG 5614 art. 6).
• 1 Dec 2025: class M abolished; RG 1575 abrogated (RG 5762 arts. 30, 32).
• 1 Nov 2025 to 31 Oct 2026: FCE 21 day terms (Res. SEPyME 219/2025).
• 2 Jan 2026: LPT penalty amounts updated (Law 27.799 arts. 19 to 29).
• 1 Jun 2026: no adhesion needed for contingency CAEA; no new main method CAEA (RG 5852 art. 3).
• 1 Jul 2026: RG 5866: new deadlines table, art. 47, Annex I, ARS 10m consumer ID, monthly electronic settlement for banks, insurers, card issuers, private schools, prepaid medicine and virtual asset providers (RG 5866 arts. 1, 4). RG 5830: banks and insurers out of RG 5762 Title I.
• 1 Aug 2026: CAEA only for contingencies; CAEA first contingency option for web service users (RG 5782; RG 5785; RG 5852).
• 1 Sep, 1 Oct and 1 Dec 2026, 1 Mar 2027: staged invoicing for insurers and financial entities (RG 5866 art. 4).
• 2 Oct 2026: non large financial entities out of FCE (Res. SICPyME 400/2026).
• 1 Oct 2026: RG 5866 art. 1(j) (removal of point 10 of Annex IV, B) in force (RG 5866 art. 4).

Pending changes

• 1 November 2026: RG 5893 universal electronic obligation (RG 4290 arts. 6, 7 new text), RG 100 art. 20 new partial authorisations, automatic monotributo points of sale (RG 5893 arts. 1 to 3, 5). RG 4290 Chapter B of Title II is repealed from the same date; its previous text is not in the source files (unconfirmed).
• 1 March 2027: non-VAT persons must issue electronic vouchers; until then RG 100 booklets; old booklets of social monotributistas and non-VAT persons usable only for contingencies until expiry (RG 5893 art. 5).
• 1 March 2027: insurers' coinsurance, card and transfer system settlements to merchants (RG 5866 art. 4(d)).
• 31 December 2026: last day for the surety insurance web service "wsseg" (RG 5866 art. 4).
• FCE terms after 31 October 2026: no successor to Res. SEPyME 219/2025 found (unconfirmed).
• FCE automatic withholding percentage on tacit acceptance depends on a joint rule (RG 4367 art. 18); RG Conjunta 4366/2018 appears in the Law 27.440 amendment list but is not in the source files (unconfirmed).
• Provincial and municipal taxes in the transparency block: Law 27.743 art. 99 only invites provinces and CABA to require disclosure of gross income tax and municipal fees; no provincial rule is in the source files.

FAQ

1. Can a foreign company with no Argentine CUIT issue Argentine invoices? No. Issuing requires a CUIT, Clave Fiscal and a point of sale (RG 4291 arts. 6, 11; RG 1415 art. 47). A foreign company selling into Argentina invoices from abroad; its Argentine customer handles any withholding. Registering a local entity or branch is covered on the entities pages.

2. I am a monotributista. Which letter do I use? C for all domestic sales, with no VAT shown (RG 1415 art. 16; Annex II, A, IV(b)); E for exports (art. 17). From 1 November 2026 ARCA will create a point of sale for you if you have none (RG 4291 art. 11).

3. What is the difference between CAE and CAEA? The CAE is requested for each voucher before issuance; the CAEA is a code requested in advance for a half month and reported afterwards. From 1 August 2026 the CAEA can be used only when the online systems fail (RG 5782 arts. 1, 4, 6).

4. Does class M still exist? No. From 1 December 2025 it became class A with the legend "OPERACIÓN SUJETA A RETENCIÓN" (RG 5762 arts. 31, 32). The buyer withholds 100% of VAT and 6% income tax (art. 13).

5. Do I have to show VAT on a receipt to a consumer? Yes. A VAT registered seller must show the VAT contained in the price, and the "Otros Impuestos Nacionales Indirectos", in the transparency block (Law 27.743 art. 99; RG 1415 Annex II, A, IV(a)(2) and B(g)).

6. Which exchange rate goes on a dollar invoice? The rate used. If the invoice is paid in the same currency, the BNA "divisa" seller closing rate of the previous exchange business day, filled in by the system (RG 1415 Annex II, A, III(d); RG 5616 art. 2).

7. When must I invoice a service? On the day it is completed or the day you collect any part of the price, whichever is first; continuous services monthly (RG 1415 art. 13).

8. My large customer ignores my FCE. What happens? If it neither accepts, rejects nor reports payment within the term (15 calendar days in the law; 21 until 31 October 2026), the FCE is accepted tacitly and becomes an enforceable title you can sue on or sell (Law 27.440 arts. 4, 6; Res. SEPyME 219/2025).

9. Can my customer reject an FCE because it does not want to pay yet? No. Rejection is allowed only for the causes in Law 27.440 art. 8 (damage, defects, price or term differences, mismatch, formal defects, non delivery, full payment). Acceptance is unconditional and irrevocable (art. 9).

10. What is the penalty for not issuing an invoice? Closure for 2 to 6 days where the amount exceeds ARS 20,000, doubled for a repeat within 2 years (LPT art. 40). Formal duty fines run from ARS 150,000 to ARS 2,500,000 (LPT art. 39).

11. Do I need to sign invoices digitally? The source resolutions do not require it; the CAE authorises the voucher (RG 4291 art. 12). Law 25.506 gives digitally signed documents original status and allows digital storage to meet record keeping duties (arts. 11, 12) (unconfirmed).

12. How long must I keep invoices? The LPT allows ARCA to require 10 years (art. 33); RG 1415 art. 61 refers to Decree 1397/1979 art. 48 (unconfirmed); delivery notes and budgets at least 2 years (art. 61).

Primary sources

• RG 1415/2003, updated text
• RG 2758/2010, updated text
• RG 4290/2018, updated text
• RG 4291/2018, updated text
• RG 4367/2018, updated text
• RG 4919/2021
• RG 5614/2024
• RG 5616/2024
• RG 5762/2025
• RG 5782/2025, updated text
• RG 5830/2026
• RG 5852/2026
• RG 5866/2026, updated text
• RG 5893/2026
• Law 27.440
• Decree 471/2018
• Res. MPyT 209/2018, updated text
• Res. SSP 5/2019, updated text
• Res. SSP 17/2019
• Res. MDP 338/2020, updated text
• Res. SEPyME 219/2025
• Res. SICPyME 400/2026
• Law 27.743
• Law 25.506, updated text
• ARCA "Factura electrónica" microsite
• ARCA "Facturación" microsite

Related pages

• What is the difference between factura A, B and C?
• Tax system overview and calendar
• Fiscal Innocence Law: simplified income tax return, statute of limitations and penalties
• Corporate income tax
• VAT
• Withholdings, perceptions and non resident rates
• Bank debits and credits tax
• Transfer pricing
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