DIAN Draft Resolution 2026: Regularizing Non-Compliance in Electronic Invoicing in Colombia

Learn about the DIAN’s 2026 draft resolution on the regularization of non-compliance in electronic invoicing in Colombia, including key changes, requirements, and how to comply.

The National Tax and Customs Directorate (DIAN) has published a new 2026 draft resolution establishing a mechanism to regularize non-compliance with the obligation to issue electronic invoices in Colombia.

This update is particularly relevant for companies that need to normalize unbilled transactions or correct inconsistencies while maintaining tax compliance and reducing risks with the tax authority.

Objective of the DIAN Draft Resolution

The purpose of this draft resolution is to enable an exceptional and temporary mechanism within the electronic invoicing system that allows taxpayers to:

Regularize unbilled transactions
Correct documents issued without meeting full legal requirements
Improve the traceability of tax information

Important:
This mechanism does not modify the current tax regime nor does it limit DIAN’s auditing and enforcement powers.

Key Changes in Electronic Invoicing in Colombia

Taxpayers who opt for voluntary recognition of non-compliance must:

Generate and transmit electronic invoices

Issue invoices corresponding to pending transactions
Use a special voluntary regularization contingency mechanism

Apply current regulations

Follow Article 1.5.1.5.7.1 of Resolution 227 of 2025 (technological issues)

How should invoices be issued under this process?

Electronic invoices and related documents must meet specific conditions:

Be issued as Type 3 invoices (electronic transcription document)
Include the code “20-REG” in the CustomizationID field
Maintain the InvoiceTypeCode for Type 3 invoices

This means that no new invoice type is created, but rather a special validation within the existing model.

Special DIAN validations

The draft introduces greater flexibility in the validation process:

Certain standard validations will not be required if incompatible, such as:
- Sequence
- Timing
It will be allowed to issue invoices for transactions that occurred on previous dates

This facilitates the regularization of delayed processes without disrupting operations.

Deadline for comments

DIAN will receive feedback on this draft resolution until:

Deadline: April 6, 2026
Email: piloto_sistemas_facturacion@dian.gov.co

What is the impact on your business?

This draft represents a key opportunity to:

Reduce tax risks
Avoid penalties for non-compliance
Improve invoicing control
Increase operational traceability

However, it also requires having the right technological tools to quickly adapt to these changes.

How LLB Solutions can help

At LLB Solutions, we support companies in their tax compliance processes across Colombia and LATAM through:

Implementation of electronic invoicing integrated with Microsoft Dynamics 365 Business Central
Automation of financial and operational processes
Adaptation to DIAN regulatory changes
Specialized support in fiscal localizations

Do you need support adapting your system to this new regulation or assessing your current compliance level?

info@llbsolutions.com | Colombia Localization

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