Podcast Legal Insider EP 8 | “Year End Review”
27/11/2025
Electronic Invoicing: Analysis of Resolution 201-6299 and the Mandatory Migration to QAP
By: Benito Lucero | Director of Icaza Accounting
Panama’s General Directorate of Revenue (DGI) has marked a crucial milestone in the evolution of its tax system with the issuance of Resolution No. 201-6299 of July 29, 2025. This regulation, which enters into force on January 1, 2026, redefines taxpayers’ obligations by establishing strict limits on the use of the Free Invoicing System and mandating migration to the Qualified Authorized Provider (QAP) scheme for a significant segment of businesses that had grown accustomed to the convenience of the DGI’s free invoicing platform.
The Fundamental Change: Restriction of the Free Invoicing System
The primary goal of Resolution 201-6299 is to optimize Panama’s Electronic Invoicing System (SFEP), ensuring that taxpayers with a higher transaction volume use more robust and scalable platforms such as those offered by QAP providers.
The DGI establishes cumulative limits for the use of the Free Invoicing System, affecting both individuals and legal entities. Any taxpayer who exceeds one of these two criteria must migrate to a QAP:
| TAXPAYERS | RANGE ACCORDING TO ANNUAL GROSS INCOME | NUMBER OF MONTHLY DOCUMENTS |
| INDIVIDUALS / LEGAL ENTITIES | Up to B/. 36,000.00 | 100 |
Important: Government entities are the only exception to these limits and may use the Free Invoicing System without restrictions on the number of monthly documents.
The Central Role of the Qualified Authorized Provider (QAP)
The Qualified Authorized Provider (QAP) plays a leading role in Panama’s electronic invoicing framework. A QAP is a company certified by the DGI that acts as the technological intermediary between the taxpayer and the tax administration.
Key Functions of a QAP
1. Validation and Authorization: The QAP is responsible for verifying that the electronic invoice meets all technical and legal requirements before being sent to the recipient. Without this validation, the document has no fiscal validity.
2. Assignment of the CUFE: It assigns the Unique Electronic Invoicing Code (CUFE), which guarantees the authenticity and integrity of the document and enables its verification by the DGI.
3. Secure Transmission: It ensures the secure transmission of invoices to the DGI’s e-Tax 2.0 system.
4. Generation of the CAFE: It issues the Auxiliary Electronic Invoice Receipt (CAFE), which is the printable graphic representation of the document.
For growing businesses or those exceeding the thresholds established in the resolution, working with a QAP offers a comprehensive solution for legal compliance and data security—elements that are essential in a modern tax system.
Impact and Recommendations for Taxpayers
Resolution 201-6299 creates a mandatory migration requirement for thousands of independent professionals and small businesses that currently depend on the DGI’s free tool.
1. Mandatory Migration
As of January 1, 2026, if a business exceeds B/. 36,001.00 in annual income or issues more than 100 documents per month, it must hire a QAP.
2. Penalties for Non-Compliance
Failure to comply with this regulation is not merely an operational issue—it is a tax offense. Taxpayers required to migrate who do not do so may face fines, rejection of their invoices, and other sanctions that could negatively impact business operations and finances.
3. Strategic Recommendation
Migration to a QAP should be viewed as a strategic investment rather than a compliance expense. QAP systems often integrate with other management tools (ERP, inventory, accounting), resulting in greater operational efficiency and improved financial control for businesses with high transaction volumes.
4. Seek Expert Support
There are many QAP providers on the market, as well as accounting firms that can help you comply with the regulation at affordable costs and with strategies that will not excessively impact your 2026 budget.
Conclusion
Resolution 201-6299 reinforces the digital transformation of Panama’s tax ecosystem by encouraging formalization and the use of robust technological platforms that ensure traceability, integrity, and transparency in commercial operations.
Taxpayers should assess their current situation and seek expert guidance to explore available options and migrate to a QAP well in advance, avoiding potential penalties or interruptions to their operations beginning in 2026.
How We Can Help
At Icaza Accounting Services, we provide invoicing support and full onboarding assistance, allowing you to reduce implementation time and costs while having access to a team of experts, competitive rates, and ongoing support. For more information, please contact us.
