Guatemala: New SAT Validation for Electronic Credit Notes (FEL)

Electronic Credit Notes in Guatemala will be subject to a new criterion related to Phrase 9, Scenario 22, under the SAT’s Online Electronic Invoicing (FEL) system. This system covers the electronic issuance, transmission, certification, and storage of invoices, credit notes, debit notes, and other Electronic Tax Documents (DTEs).

The announced change establishes a specific condition for determining when this phrase must be included when issuing a credit note (NCRE), based on the month in which the original invoice was issued.

According to the information provided about this update, the change is scheduled to go live in the production environment on November 10, 2026.

For companies using business management systems integrated with FEL, this update is particularly relevant, as it may require reviewing the logic used to determine when the corresponding phrase must be included in the XML file and the document’s graphical representation.

What Is Changing for Electronic Credit Notes?

The new validation establishes that the month in which the original invoice was issued and the month in which the NCRE is generated must be taken into account, rather than calculating the difference based solely on exact dates.

Phrase 9, Scenario 22, applies when the NCRE is issued after two full calendar months have elapsed following the month in which the original invoice was issued.

In other words, this condition applies when the credit note is issued starting from the third calendar month after the invoice month.

For example, under this criterion, if an invoice was issued at any time during January, the third subsequent calendar month would be April.

This means that companies that have configured logic based on the exact difference between dates should review how they determine whether this condition applies.

To review the current technical specifications of the FEL system, companies can consult the SAT’s FEL Technical Documentation, where the authority provides technical and legal information, rules and validations, DTE schemas, and specific references for credit and debit notes.

How Should Phrase 9, Scenario 22, Be Reported in the XML?

When this condition applies, the XML file must include Phrase 9 under Scenario 22.

The structure indicated for this scenario is:

XML

<dte:Frases>
    <dte:Frase CodigoEscenario="22" TipoFrase="9"/>
</dte:Frases>

The SAT’s official DTE schema includes a section for phrases within the electronic document structure. The documentation identifies the phrase type and corresponding scenario, and indicates that this section must contain the special tax regimes and texts required in DTEs according to the taxpayer’s tax status and the type of transaction.

The corresponding graphical representation must also reflect the information applicable to this scenario, in accordance with the current specifications.

To review the available technical documentation, visit the SAT’s official section on FEL rules, validations, and schemas.

Does This Validation Also Apply to Debit Notes?

According to the information provided for this change, no.

Phrase 9, Scenario 22, under this condition applies to Electronic Credit Notes and must not be included in debit notes (NDEB).

This distinction is important for systems that may use the same logic for both credit and debit notes.

The official FEL documentation recognizes NCRE and NDEB as different types of DTEs. In addition, the SAT provides specific technical documentation on references related to credit and debit notes in its official FEL documentation section.

What Should Business Systems Be Reviewed?

Companies issuing electronic documents through a business management system should review how they currently determine when this phrase must be included.

The main points to verify include:

• The month in which the original invoice was issued.
• The month in which the NCRE is issued.
• The logic used to determine when the condition applies.
• The inclusion of Phrase 9, Scenario 22, when applicable.
• The information generated in the XML file.
• The information transferred to the document’s graphical representation.
• The distinction between credit notes (NCRE) and debit notes (NDEB).

The SAT states that a DTE issuer may generate documents using its own or contracted computer systems and subsequently transmit them to its certifier for validation and authorization.

For this reason, companies using business management systems should pay particular attention to how FEL technical changes may affect the processes that generate the information subsequently sent to the certifier.

For this review, the reference should always be the official FEL technical documentation.

What Does This Change Mean for Companies Using Business Central?

Changes to FEL rules and validations may require companies to review how the systems involved in the process generate the information required for electronic documents.

For companies using Microsoft Dynamics 365 Business Central in Guatemala, it is advisable to review the process used to issue credit notes and how it connects with the electronic document workflow and the corresponding certifier.

This is not simply a matter of checking whether the document can be issued. In this specific scenario, attention should be paid to the criterion used to determine when Phrase 9, Scenario 22, must be reported, as well as to the information subsequently included in the electronic document.

The SAT explains that DTEs generated through a company’s own or contracted computer systems are transmitted to an accredited certifier for validation and authorization. This information is available in the SAT’s official DTE Issuers section.

Why Is It Important to Review This Change Before It Goes Live?

A change to validation rules can affect systems that already have FEL document generation automated.

For this reason, it is advisable to keep three elements aligned throughout the process:

The tax rule, which determines when a specific condition must be applied.

The business system configuration, which is involved in generating the document data.

The FEL process, through which DTEs are electronically issued, transmitted, certified, and stored.

Keeping these elements aligned helps prevent discrepancies between the criteria configured in business systems and the validations currently in force.

Companies can consult the official FEL rules and validations directly on the SAT website.

When Will This Change Take Effect?

According to the information provided about this update, the production rollout is scheduled for November 10, 2026.

Before making changes in production environments, companies should verify any implementation against the current technical documentation published by the tax authority.

The SAT’s FEL Technical Documentation includes resources such as rules and validations, test cases, technical services, the main DTE schema, and the schema for references to credit and debit notes.

Keep Your FEL Processes Ready for Tax Changes

As the rules governing Online Electronic Invoicing continue to evolve, companies need to keep their tax processes aligned with the systems used to generate electronic documents.

If your organization uses Microsoft Dynamics 365 Business Central in Guatemala, reviewing these changes in advance can help identify potential adjustments to its Electronic Credit Note processes.

To verify any tax or technical changes, we always recommend consulting the SAT’s official Online Electronic Invoicing portal and its current documentation.

Does your company use Microsoft Dynamics 365 Business Central in Guatemala?

Contact LLB Solutions to assess your company’s localization requirements and learn how we can help you manage your tax processes through Microsoft Dynamics 365 Business Central.

info@llbsolutions.com | Guatemala Localization