The FEL schema update published by Guatemala’s Superintendency of Tax Administration (SAT) on October 14, 2026, introduces changes to the XSD schemas and technical catalogs for the Electronic Invoice Online Regime (Factura Electrónica en Línea, FEL). These changes introduce new validations, modify the structure of certain complements, and add rules related to the temporary exemptions established under Decree No. 22-2026.
The update requires special attention from companies and the teams responsible for their invoicing systems, as some changes affect mandatory data fields, product identification, and the validation of electronic tax documents (DTEs).
For organizations using Microsoft Dynamics 365 Business Central, keeping up with these requirements is essential to preparing their systems and reducing the risk of inconsistencies when generating electronic documents.
What Changes Does the FEL Schema Update Introduce?
The FEL schema update requires companies using Microsoft Dynamics 365 Business Central to assess changes to mandatory fields, taxable units, and validation rules to determine which adjustments their electronic invoicing processes may require.
The SAT publication replaces the content previously available in its official technical repository since August 4, 2026. Although the files retain their original names and version numbers, their contents have changed.
For this reason, checking the file names alone is not sufficient. Companies must verify the actual file contents to confirm that their systems use the current schemas and catalogs.
You can access the files directly in the SAT’s official Catalogo-FEL repository.
1. Changes to Export Complements
One of the most significant changes affects the PaisConsignatario field, which is now mandatory in the Export and Provisional Export complements.
In addition, the destination country must be selected from a predefined list of values accepted by the SAT. Entering the country name as free text is no longer sufficient; the value must match an entry in the corresponding catalog.
The validation pattern for the INCOTERM and transportation method fields in the Export complement has also been corrected to reject whitespace, in accordance with the technical rule description.
What should companies review?
- The mandatory destination country field.
- Whether the reported country matches the official catalog.
- The validation of fields related to INCOTERM and transportation method.
2. Changes to Fuel-Related Complements
The Storage and Gallonage and Liquefied Petroleum Gas complements include changes to their data structures.
The main adjustments include:
- Replacing the
Ducaelement withNombreCuentaCorriente. - Introducing the mandatory
Origendespachoattribute. - Defining five possible values for identifying the dispatch origin: Imports, Local Purchases, Incoming Transfers, Downgrades, and Resolution for Positive Variations.
- Removing the
OrigendespachoandProcedenciaattributes from the IDP group in the main document.
These changes require companies to review how complements are generated and how data is structured before being submitted to the electronic invoicing platform.
3. New Complements for Referencing Documents
The SAT has introduced structures that allow an electronic tax document to reference a previously issued document.
The ReferenciaDTE complement identifies a previous DTE using information such as the version, authorization number, and issue date.
The ReferenciasNotaEnvio complement allows references to shipping notes using the fields defined in its schema, including information about the source document.
Although the published documentation describes these complements, it does not yet specify which DTE types must use them. Companies should therefore avoid assuming when they apply until additional official instructions are available.
4. Updates to Phrase and Taxable Unit Catalogs
The update also introduces changes to the JSON catalogs for phrases, messages, and taxable units, particularly regarding temporary exemptions from Value Added Tax (VAT) and the Tax on the Distribution of Crude Oil and Petroleum-Derived Fuels (IDP).
Key updates include:
- Adding phrases associated with scenarios 37 and 38 in the type 4 phrase catalog.
- Updating scenarios 21, 22, and 23 in the type 9 phrase catalog.
- Introducing new exempt taxable units for certain petroleum-derived products.
- Expanding validations that check consistency between reported phrases and taxable units.
- Introducing new validation rules for certain issuers and service export documents.
These adjustments relate to the provisions of Decree No. 22-2026 and other regulatory references included in the catalogs.
5. Special Attention to IDP Taxable Units 15 and 16
One of the changes that deserves particular attention is the revised meaning of IDP taxable units 15 and 16.
Under the updated publication:
- Unit 15: Identifies regular gasoline with fuel-grade ethanol, with a factor of 4.6.
- Unit 16: Identifies exempt gasoline with fuel-grade ethanol, with a factor of 0.
The codes retain their numbering, but their meanings have changed. As a result, a system that continues to use the previous interpretation could report a product with the wrong tax treatment without necessarily triggering an automatic rejection.
This makes it particularly important to review taxable unit assignment rules and ensure that the information transmitted correctly reflects the product and its applicable tax treatment.
How Can Companies Prepare for FEL Changes in Guatemala?
In light of this update, companies should assess whether their invoicing systems and tax processes are ready to accommodate the new requirements.
The FEL schema update makes it important to identify changes that could affect electronic invoicing processes and determine which system adjustments may be necessary to support compliance with Guatemala’s tax requirements.
We recommend prioritizing the following actions:
- Verify technical files: Compare the contents of the XSD schemas and catalogs against the official SAT publication.
- Review mandatory data: Check the required fields in export and fuel-related complements.
- Validate taxable units: Confirm that IDP codes 15 and 16 are used according to their new definitions.
- Update validation rules: Review the phrases, messages, and combinations required by the catalogs.
- Assess the impact on Business Central: Identify the adjustments needed to generate and validate electronic documents.
- Monitor official announcements: Confirm when the changes will take effect and whether a testing environment will become available.
These measures help identify potential inconsistencies before they affect invoicing processes and tax compliance.
When Do the Changes Take Effect?
As of the publication date of this article, the SAT had published the updated schemas and catalogs on October 14, 2026, but had not announced a specific effective date or the availability of a testing environment.
A new version of the Rules and Validations document associated with this update had also not been published.
Companies should therefore consult official announcements before assuming a mandatory implementation date and remain alert to further guidance from the tax authority.
Preparing for Regulatory Changes Is Essential
The SAT’s technical update introduces changes that may affect electronic document structures, export data, fuel-related complements, and the tax treatment of certain taxable units.
For companies using Microsoft Dynamics 365 Business Central, reviewing these changes in advance helps identify potential impacts and prepare the necessary adjustments in line with official requirements.
At LLB Solutions, we help companies address tax requirements across Latin America through our localization solutions for Microsoft Dynamics 365 Business Central.
Does your company use Business Central in Guatemala? Our team can help you assess localization requirements and identify the areas that may need attention in response to tax updates.
Contact us to learn more about our localization solutions for Guatemala.
info@llbsolutions.com | Guatemala Localization
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