Argentina Resolution 400/2026 introduces a new measure that modifies the application of the Electronic Credit Invoice (FCE) MiPyME regime for certain financial institutions.
The resolution, published in the Official Gazette on October 2, 2026, establishes that financial institutions covered by Law 21,526 that are not classified as “large companies” are excluded from the Electronic Credit Invoice MiPyME regime.
This amendment is related to the changes implemented during 2026 regarding electronic invoicing obligations for financial institutions and seeks to distinguish these operations from the primary purpose of the FCE MiPyME regime.
What does Resolution 400/2026 FCE Argentina establish?
Resolution 400/2026 FCE Argentina establishes that financial institutions covered by Law 21,526 that are not classified as “large companies” are excluded from the Electronic Credit Invoice MiPyME regime.
The measure is related to Law 27,440, which established the Electronic Credit Invoice MiPyME regime as a tool designed to facilitate financing for micro, small, and medium-sized enterprises.
According to the resolution’s rationale, the regime seeks to facilitate access to financing for MiPyME suppliers by allowing them to use their commercial receivables.
The regulation therefore distinguishes between financial institutions classified as “large companies” and those that do not have this status.
According to the information included in the resolution, of the 73 financial institutions authorized by the Central Bank of the Argentine Republic, 34 are classified as large companies, while 39 do not have this status.
You can consult the official text of the measure on the Official Gazette of the Argentine Republic.
Why was this change introduced?
During 2026, significant changes were introduced to the invoicing obligations applicable to financial institutions.
ARCA General Resolution 5,824 modified the treatment of financial institutions regarding the issuance of invoices, while General Resolution 5,866 subsequently established a gradual implementation schedule for these obligations.
As a result, some financial institutions could become subject to the Electronic Credit Invoice MiPyME regime when carrying out certain transactions with companies classified as large companies.
The new regulation establishes a specific exclusion for financial institutions that do not have “large company” status.
The objective is to distinguish transactions related to financial activities from the commercial financing framework promoted by the FCE MiPyME regime.
You can consult the official information regarding electronic invoicing on the ARCA website.
Who is affected by Resolution 400/2026?
Resolution 400/2026 FCE Argentina primarily affects the following groups:
Financial institutions that are not large companies
Financial institutions that are not listed as “large companies” in the corresponding registry are excluded from the FCE MiPyME regime.
According to the resolution’s recitals, this currently applies to 39 of the 73 financial institutions authorized by the Central Bank.
Financial institutions classified as large companies
Financial institutions that have “large company” status remain subject to the regime when their transactions fall within the applicable provisions.
For this reason, it is important to correctly determine the status of each financial institution before establishing the applicable invoicing obligations.
Companies that conduct transactions with financial institutions
Companies must also consider this amendment when conducting transactions with financial institutions.
The status of the counterparty and the type of transaction will be relevant factors in determining whether the Electronic Credit Invoice MiPyME regime applies.
When does the new measure take effect?
Resolution 400/2026 was published on October 2, 2026, and entered into force upon publication.
However, the exclusion applies according to the date on which each financial institution becomes required to issue electronic invoices, following the schedule established by ARCA.
The schedule includes different dates depending on the type of transaction:
| Date | Financial institution transactions |
|---|---|
| October 1, 2026 | Leasing agreements and foreign trade transactions. |
| December 1, 2026 | Loans, except overdrafts; transactions involving certain taxpayers not registered for VAT or exempt from VAT; and settlements to cardholders. |
| March 1, 2027 | Periodic settlements to participating merchants and settlement of the integrated fee. |
This gradual implementation schedule was established by ARCA for the electronic invoicing obligations applicable to financial institutions.
What should companies review?
In light of this regulatory change, companies operating in Argentina should review their invoicing processes and verify that the rules configured in their systems are aligned with current regulations.
The main aspects to consider include:
- Determine whether the financial institution is classified as a “large company.”
- Review the type of transaction being carried out.
- Verify the date on which the transaction becomes subject to electronic invoicing requirements.
- Determine whether an Electronic Credit Invoice MiPyME must be issued.
- Keep the system’s tax configurations up to date.
- Review the validation and electronic document issuance rules.
Official information about financial institutions is available on the website of the Central Bank of the Argentine Republic.
What impact does this have on Microsoft Dynamics 365 Business Central?
Changes to tax obligations can have a direct impact on companies’ invoicing and financial management processes.
For organizations using Microsoft Dynamics 365 Business Central, it is important for their tax localization to incorporate Argentina’s specific requirements and regulatory updates.
An up-to-date localization allows companies to adapt electronic invoicing processes to local requirements and facilitates the management of regulatory changes that may arise throughout the lifecycle of an implementation.
In this context, Resolution 400/2026 FCE Argentina is another example of the importance of keeping tax solutions aligned with the requirements established by local authorities.
To learn more about the legal framework of the regime, you can consult Law 27,440 on the official Government of Argentina website.
What does this change mean for Business Central implementations?
Regulatory changes may require adjustments to invoicing processes, system configuration, and document validation within a Microsoft Dynamics 365 Business Central implementation.
Therefore, companies and partners working with Business Central in Argentina should consider tax updates as part of the ongoing maintenance of their solution.
Having a specialized localization helps incorporate the country’s tax requirements and reduces the risk of regulatory changes causing inconsistencies in invoicing processes.
Resolution 400/2026 FCE Argentina introduces a significant change for financial institutions regarding the Electronic Credit Invoice MiPyME regime.
Financial institutions that are not classified as “large companies” are excluded from the regime, while those that do have this status remain subject to the applicable provisions.
For companies operating in Argentina, it will be essential to review the characteristics of each transaction and keep invoicing and tax compliance rules up to date.
In an environment of constantly evolving regulations, having an up-to-date tax localization for Microsoft Dynamics 365 Business Central helps companies adapt their processes and maintain compliance with local requirements.
Official Sources
- Official Gazette – Resolution 400/2026
- ARCA – Electronic Invoicing
- Government of Argentina – Law 27,440
- Central Bank of the Argentine Republic
Is your Business Central solution ready for Argentina’s tax changes?
Keep your invoicing processes up to date and facilitate compliance with local regulations through LLB Solutions’ localization solutions for Microsoft Dynamics 365 Business Central.
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