Regulatory updates - Colombia

DIAN has announced a new validation mechanism for the "Buscar documento" (Search document) option of its electronic invoicing system, in effect from July 28, 2026. The measure is aimed at protecting the security of taxpayer information. Under the change, the system asks for the identification number of the invoice issuer or receiver when a user looks up a document. To download that document, the user will have to enter the same identification number again. Users may also encounter the message "Solicitud bloqueada por controles de seguridad" (Request blocked by security controls). According to DIAN, this appears when the system detects robots, automated processes, or artificial intelligence agents that could overload the look-up service and pose a risk to information security. It does not suspend access: the system will present a check to confirm the user is human, after which normal navigation can continue. DIAN describes the update as part of the technical controls put in place to keep the platform working properly and has asked users and taxpayers to take the change into account. The look-up tool is available through the Buscar documento option of the electronic invoicing system.

When a user consults a document, the system will request the identification number of the issuer or the receiver. To download the document, the same identification number must be entered again. While using the Search document tool, users may see a message stating that the request has been blocked by security controls. This appears when the system detects robots, automated processes, or artificial intelligence agents that could overload the query service and pose a risk to information security. In that case, the system will ask the user to confirm they are human, after which the operation can continue through the normal navigation flow. Access to the service is not suspended by these controls. DIAN describes the measure as a technical safeguard to protect the platform and taxpayer information.

The draft decree aims to address widespread misinterpretations regarding which electronic invoices must be registered in the RADIAN system and when the statutory acceptance period begins. MinCIT notes that current regulatory wording has led to divergent interpretations affecting the practical operation of electronic invoicing.

Key clarifications in the draft decree include:

• It is clarified that only electronic invoices that constitute negotiable instruments and are intended for circulation must be registered in RADIAN, and not all electronic invoices.
• Express acceptance occurs when the buyer electronically accepts within the three-day period, while tacit acceptance happens when no objection is submitted within the same timeframe
• When tacit acceptance applies and the issuer intends to endorse the invoice, they must leave an electronic record according to DIAN-defined mechanisms
• The three-business-day period for express or tacit acceptance would begin upon receipt of the invoice itself, rather than upon receipt of goods or services
• The legitimate holder must inform the debtor through RADIAN at least three days before the invoice's due date

If adopted, the decree would take effect immediately following its publication in the Official Gazette. More information in the Draft Decree is available at the following link