Argentina: Authorised Before Issued, and Changing Fast
Argentina has required prior authorisation of every invoice for years. What is new is the pace: a renamed authority, an abolished invoice class, the end of routine advance authorisation, and a buyer field that will cause rejections from December. A mature regime, rewritten in eighteen months.
Country briefing · September 2026 · CFOs, tax and finance leads
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The authorisation code every electronic invoice must carry before it is valid
1 Aug 2026
Advance authorisation (CAEA) restricted to contingencies only
1 Dec 2026
Requests without the buyer’s VAT status are rejected
31 Oct 2026
End of the current 21-day window for SME credit invoices
Key takeaway for finance and tax leaders: the Argentine regime is mature, but it is being rewritten. Three dates in the second half of 2026 affect invoicing or payables, and the December one turns a missing data point into a rejected invoice. The question to ask this month: does every invoice we send for authorisation already carry the buyer’s VAT status?
A Mature Regime in a Period of Rapid Revision
Every Argentine invoice has needed an authorisation code from the tax authority for years. The authority itself changed in late 2024, when AFIP was dissolved and replaced by ARCA — in practice with the same tax identifiers, systems and web services. Since then, a sequence of resolutions has simplified some things and tightened others, several with dates still to come in 2026.
The Regime in One Table
| Element | Position | Status |
|---|---|---|
| Electronic invoicing | Universal, with prior authorisation of each document by web service | LIVE |
| Class M invoices | Abolished; replaced by class A with a legend determining withholding | DEC 2025 |
| Advance authorisation (CAEA) | No longer a primary method; contingency use only, capped | AUG 2026 |
| Buyer VAT status field | Mandatory; missing values cause rejection | DEC 2026 |
| New sectors | Banks, insurers and card issuers phased in, with monthly consolidated settlements | TO MAR 2027 |
| SME credit invoices | Large companies buying from SMEs must receive and decide on them | LIVE |
| Consumer tax transparency | VAT and other national indirect taxes shown on B2C invoices | 2025 |
| Portal IVA | Pre-loaded VAT books replacing the digital VAT ledger for most | NOV 2025 |
The Question to Ask This Month
“Does every invoice we send for authorisation already carry the buyer’s VAT status?” From December, the ones that do not will be rejected — and an unauthorised invoice is not an invoice.
The Context That Shapes Everything
Monthly inflation has fallen sharply but remains material by European standards. Any rule expressed as a peso amount — buyer identification, SME credit invoices, transport codes — loses real value within months and is revised accordingly. Treat every threshold as a variable, not a constant.
Why the Pace Matters
- Each change is a configuration change. Invoice classes, legends, authorisation modes and mandatory fields all live in the billing system.
- Several arrive together. August, October and December 2026 each bring something that affects invoicing or payables.
- Inflation moves the thresholds. Peso amounts that decide scope are revised often, so hard-coded limits drift out of date quickly.
No Code, No Invoice
Argentina’s model is prior authorisation. Before an invoice can be issued, its data is sent to the tax authority’s web services, which validate it and return an authorisation code with an expiry date. The code, and a QR code, appear on the document. Without them, there is no valid invoice.
Step by Step
| Step | What happens, and where it fails |
|---|---|
| Authenticate | Your system authenticates with a digital certificate. Certificates expire, and an expiry discovered during billing stops invoicing |
| Request | Invoice data is sent to the appropriate web service for its type — domestic, with line detail, or export |
| Validate | Mandatory fields and consistency are checked. From December, a missing buyer VAT status is a rejection |
| Receive the code | The authorisation code and its expiry are returned and printed with a QR code on the invoice |
| Deliver | The invoice reaches the customer within ten calendar days of issue |
The Invoice Classes
- A: between VAT-registered parties, with VAT shown separately — now also carrying the legends that replaced class M
- B: from VAT-registered sellers to consumers, exempt or non-registered buyers
- C: from simplified-regime and exempt sellers
- E: exports
Which Web Service for Which Document
- Domestic invoices A, B, C: the standard electronic invoicing web service
- Invoices with line-item detail: the web service carrying item-level data
- Export invoices (E): the dedicated export web service
- SME credit invoices: their own document types within the invoicing services
Points of Sale Are a Control Too
Each invoicing channel operates under a registered point of sale. Opening or closing one requires notice to the authority — a few working days in each direction — which makes launching a new sales channel or entity a compliance lead-time item, not only an IT one.
Contingency Is Now Genuinely for Contingencies
Many large issuers used advance authorisation as a routine mode to keep high-volume billing independent of the web service. From August 2026 that is no longer permitted: real-time authorisation is the primary method, and advance codes are for documented outages only, within a cap. Billing architecture built around advance codes has had to change.
Simpler in Some Places, Stricter in Others
AFIP becomes ARCA, class M disappears, advance authorisation is restricted and a buyer field will cause rejections from December.
The Changes
| Change | What it does | From |
|---|---|---|
| AFIP becomes ARCA | New agency, same identifiers, logins and web services; new resolutions numbered under the new name | October 2024 |
| Class M abolished | Replaced by class A with one of two legends: subject to full withholding, or payable only to the supplier’s declared bank account. Suppliers are reclassified by periodic automatic evaluation | 1 December 2025 |
| Advance authorisation restricted | Contingency use only, capped as a share of monthly unavailability; postponed once from June | 1 August 2026 |
| New sectors and settlements | Banks, insurers, card issuers and others phased in, with monthly consolidated electronic settlements | July 2026 to March 2027 |
| Buyer identification in B2C | Required only above a high peso threshold | 2025 |
| Buyer VAT status mandatory | Authorisation requests without it are rejected | 1 December 2026 |
What the Class M Change Means for Buyers
Class M existed to signal suppliers whose invoices required full withholding by the buyer. Its replacement moves the signal into a legend on a class A invoice. Accounts payable has to read the legend: one means withhold in full, the other means pay only to the declared bank account and do not withhold.
For Accounts Payable
- Withholding logic driven by the legend, not the invoice class
- Payment to the declared account where the legend requires it
For Billing
- The correct legend applied if you are reclassified
- A process to notice reclassification when it happens
A Worked Example
A supplier previously issuing class M invoices is reclassified. From December 2025 it issues class A invoices with the legend requiring payment only to its declared bank account. A buyer whose AP logic still keys off the invoice class withholds in full and pays to a stored account — two errors on one invoice, both avoidable by reading the legend.
A Caution on Older English-Language Sources
One early-2026 resolution, widely reported in English as introducing pre-filled returns, was later repealed and replaced. Rely on the current resolutions and their annexes, not on summaries written before mid-2026 — the regime has moved faster than much of the commentary.
December in Practice
The buyer VAT status field is the change with the sharpest edge: it turns a data-quality gap into a rejected invoice. Every customer record needs a correct VAT condition before December — including one-time and consumer customers, whose treatment should be decided rather than defaulted.
The Obligations Around the Invoice
Beyond authorisation: consumer tax transparency, the portal that replaces the VAT ledger, and transport documents.
Tax Transparency on Consumer Invoices
| What must appear | Where it goes wrong |
|---|---|
| VAT contained | Price-inclusive calculations that do not reconcile to the invoice total |
| Other national indirect taxes | Taxes omitted because they are embedded in the price structure |
| The regime legend | Missing from some output forms or channels |
Since 2025, invoices to consumers must show separately the VAT contained in the price and the other national indirect taxes, with a legend identifying the transparency regime. Provincial and municipal taxes are excluded. Large companies started in January 2025, everyone else in April 2025. The sanction for non-compliance is closure of the business for a period of days — a penalty measured in lost trading, not money.
Portal IVA Replaces the Digital VAT Ledger
From the November 2025 period, VAT-registered companies use a portal in which sales and purchases are pre-loaded from the authority’s own data. The separate digital VAT ledger is kept only for exempt taxpayers. The shift is the same as elsewhere in this series: the authority starts from its data, and you correct it.
Delivery Notes and Transport Codes
| Obligation | Position |
|---|---|
| Electronic delivery notes | Optional at national level; printing no longer required |
| Transport codes | A provincial obligation, not ARCA’s, with value and weight thresholds updated for inflation — Buenos Aires province being the most relevant for many companies |
Reconciling the Pre-Loaded Books
| Comparison | What a difference suggests |
|---|---|
| Pre-loaded sales ↔ billing | Invoices authorised but not posted, or posted without authorisation |
| Pre-loaded purchases ↔ AP | Supplier invoices you have not recorded, or recorded that the authority does not hold |
| Portal totals ↔ your VAT calculation | The differences to explain before filing |
What to Do with the Pre-Loaded Books
- Pre-loaded sales should match what you invoiced
- Pre-loaded purchases depend on your suppliers’ invoicing
- Differences have to be traced and corrected each period
- A reconciliation to the ledger makes that routine
Provincial Taxes Are Their Own World
Turnover tax and provincial withholding and collection regimes sit outside this briefing but inside most Argentine finance teams’ monthly workload. They draw on the same partner data — which is one more reason to keep that data clean.
The Obligation That Lands on Accounts Payable
Under the SME credit invoice regime, an SME invoicing a large company above a set amount must issue an electronic credit invoice — and the large company must receive it, and accept or reject it within a deadline. Silence means acceptance, and an accepted credit invoice becomes a negotiable instrument the SME can finance.
The Regime
| Element | Position |
|---|---|
| Who | SMEs invoicing companies classified as large |
| Minimum amount | A peso threshold revised periodically — most recently in April 2026 |
| Decision window | 21 calendar days until 31 October 2026; the law’s own period is shorter, so the window may narrow if not extended |
| Silence | Treated as acceptance |
| After acceptance | The invoice can be traded or financed through capital-market or banking channels |
Watch 31 October
The current decision window expires on 31 October 2026. Check whether it has been extended and, if not, shorten your internal process to match — a few days lost here converts disputes into accepted debts.
Why This Matters to a Large Company
- The deadline runs whether or not anyone looks. A disputed invoice that is not rejected in time becomes an accepted, tradeable obligation.
- The payment terms change. Once accepted, the invoice may be held by a financial institution rather than the supplier.
- The window may shorten. If the current 21-day period is not extended beyond October, AP has less time than it is used to.
What Accounts Payable Needs
- Credit invoices identified on arrival, not at month-end
- A decision owner and a daily view of what is ageing
- A rejection path with recorded reasons
- Payment processes that recognise a financed invoice
How Financing Changes Payment
Once an SME credit invoice is accepted and traded, the party entitled to payment may be a bank or a capital-market participant rather than the supplier. Paying the supplier directly can mean paying the wrong party. Treasury and AP need visibility of the invoice’s status at the moment of payment, not only at receipt.
Who Should Own the Decision
Not whoever happens to open the platform. The decision to accept or reject belongs to the person who can confirm the goods or services were received as invoiced — usually the requisitioner or receiving function — with AP running the clock and recording the outcome.
A Long-Standing Localisation Under Pressure
Argentine SAP landscapes typically combine the country localisation, SAP Document and Reporting Compliance for the web-service authorisation, and local components for withholding and provincial taxes. The 2025–26 changes reach all three, and each needs to be confirmed against current SAP notes for your release.
What the Design Has to Cover
| Area | What the design has to cover |
|---|---|
| Authorisation | Real-time requests as the primary mode; advance codes only for documented outages, within the cap |
| Buyer VAT status | Held on every customer and sent with every request before December |
| Invoice classes and legends | Class M removed; the correct legend applied to class A where required |
| Withholding | Driven by the legend on incoming invoices, with payment to declared accounts where required |
| SME credit invoices | Received, identified and decided inside the window |
| Consumer invoices | Transparency lines and legend on every B2C output |
| Thresholds | Held as maintainable values, not hard-coded, given how often they change |
Where Argentine Landscapes Are Usually Weakest
- Customer VAT condition incomplete, especially for one-time customers
- Advance-authorisation batches still scheduled
- Class M logic left in custom code
- Withholding keyed to invoice class, not legend
- SME credit invoices decided at month-end
- Thresholds hard-coded years ago
Five Questions for Whoever Supports Your System
- What share of customers carry a valid VAT status today?
- Do we still depend on advance authorisation for any billing channel?
- Has class M been removed everywhere, including in custom code and output?
- Does AP withholding read the legend rather than the invoice class?
- How are SME credit invoices flagged and decided inside the window?
Where the Risk Usually Sits
Not in the core web-service call, which most landscapes handle well — but in custom code written for rules that no longer exist, class M logic, advance-authorisation batches and hard-coded thresholds. Inventory it before December.
A Design Sequence
| Order | Why in this order |
|---|---|
| 1 · VAT status | The December rejection risk; everything else can follow it |
| 2 · Retired rules | Remove class M and advance-authorisation logic before they break |
| 3 · Payables | Legend-driven withholding and SME invoice decisions |
| 4 · Reconciliation | Portal IVA to ledger, every period |
Three Dates Before the Year Ends
A plan to December, a ten-question health check and the first thirty days.
The Plan
Confirm no billing channel still relies on advance authorisation; inventory class M logic and hard-coded thresholds
Check whether the SME credit invoice window is extended beyond 31 October; adjust AP accordingly
Complete buyer VAT status on every customer; test rejection handling
Requests without buyer VAT status are rejected — monitor the first billing runs closely
Read new resolutions monthly; update thresholds; reconcile Portal IVA each period
A Health Check in Ten Questions
| No. | Question | If the answer is unclear |
|---|---|---|
| 1 | Do all customers have a buyer VAT status? | Rejected invoices from 1 December |
| 2 | Is advance authorisation used only in outages? | A mode that is no longer permitted |
| 3 | Is class M gone from billing and custom code? | Invalid invoice classes, or broken logic |
| 4 | Does AP withholding follow the legend? | Wrong withholding, or payment to the wrong account |
| 5 | Are SME credit invoices decided in time? | Disputed debts accepted by default |
| 6 | Do B2C invoices show the transparency lines? | A closure penalty, measured in lost trading days |
| 7 | Does Portal IVA reconcile to the ledger? | Differences you did not know about |
| 8 | When do our certificates expire? | Invoicing stops mid-run |
| 9 | Are thresholds maintainable, not hard-coded? | Scope rules drift with inflation |
| 10 | Who reads new resolutions each month? | Configuration falls behind the rules |
Questions 1, 2 and 5 are the ones to fix first: two decide whether you can invoice at all this winter, and the third decides whether disputes survive.
The First Thirty Days
Size the VAT-status gap
Inventory retired rules; trace AP withholding
A dated plan to December
What We Typically Find
- A core authorisation flow in good order
- Retired rules still live in custom code
- A VAT-status gap nobody has sized
- SME invoices accepted by silence
- Portal IVA differences accepted without investigation
- No routine for reading resolutions
Three Dates, One Quarter
August’s change has already happened, October’s decision window may shorten, and December’s field makes bad data a rejection. The fourth quarter is the window to finish all three — together they decide whether January’s billing runs cleanly.
An SAP Finance and Compliance Practice
Argentina’s rules are changing faster than most localisations are maintained. We help companies catch up — and put a routine in place so they do not fall behind again.
Change-readiness review
Two to three weeks. Buyer VAT status coverage, authorisation modes, class M remnants, withholding logic, SME credit invoice handling and thresholds. Output: a gap list ordered by date.
Remediation
Master data completed, custom code for retired rules removed, AP withholding and SME invoice decisions rebuilt, and Portal IVA reconciled. Output: a clean December.
Run and legal change
Resolutions read monthly and applied in controlled windows, thresholds maintained, and the design shared with your other Latin American entities. Output: a localisation that keeps up.
What Makes This Different
We sort by date. With changes landing in August, October and December, sequencing matters more than scope.
We look for what should no longer be there. Retired rules in custom code are the most common source of failure.
We bring AP in. Legends and SME credit invoices make payables as exposed as billing.
We say what we are not. We are not your tax adviser. We work alongside the people who are.
What a Change-Readiness Review Produces
A December position: customers without a buyer VAT status, and the billing volume they represent.
A retired-rules inventory: custom code and configuration still built around class M, advance authorisation or old thresholds.
A payables view: how legends and SME credit invoices are handled in practice today.
If you are ahead: if VAT status is complete, advance codes are gone and AP reads the legends, the remaining work is a routine and an owner. We will tell you that, and keep the engagement short.
A Sensible First Step
Count the customers without a buyer VAT status, and the invoices you issued to them last month. That number is your December exposure — and it is fixable in weeks if you start now.
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Sources consulted 25 September 2026: Boletín Oficial publications of Decree 953/2024 and general resolutions RG 5614/2024, 5700/2025, 5705/2025, 5762/2025, 5852/2026 and 5866/2026; ARCA and argentina.gob.ar service pages on SME credit invoices; practitioner commentary (Blog del Contador, Contadores en Red, Errepar) and Sovos. Some web-service details could not be re-verified. SAP behaviour from the SAP Help Portal and partner commentary.
Prepared by 30 Advisory (status at 25 September 2026). Information only — not tax, legal or accounting advice. It summarises publicly available material as at that date. Argentine resolutions change frequently, peso thresholds are revised often, and sources disagree on some dates — including which rules took effect in June and which in August 2026. Confirm the position for your own entity with ARCA or a qualified adviser before acting. 30 Advisory accepts no liability for decisions taken on the basis of this document.
Is Your Argentine Localisation Keeping Up with the Rules?
We’ll review buyer VAT status, authorisation modes, class M logic and SME credit invoices in our free 60-minute diagnostic.
Three things to check first
- How many customers lack a buyer VAT status, and how much billing they represent.
- Whether any billing channel still depends on advance authorisation or class M logic.
- Whether AP reads invoice legends and decides SME credit invoices in time.
Want the full picture? Score your DRC readiness →