Country deep dive
Uruguay's CFE regime began with Decreto 36/012 in 2012, phased in mandatory adoption by taxpayer revenue tier from 2014 to 2019, and closed its remaining exemption window on 1 January 2025, when essentially all VAT taxpayers became required electronic issuers. DGI continues to evolve the underlying technical schema, most recently with new mandatory validation controls in 2026.
On 8 February 2012, Uruguay's executive branch promulgated Decreto 36/012, the founding decree of the Comprobante Fiscal Electrónico (CFE) system: it defines the CFE itself, obliges included taxpayers to document their sales exclusively through authorized CFE, requires a valid electronic certificate and signature, and establishes that CFE non-compliance is sanctioned under Uruguay's general tax-documentation penalty regime rather than a CFE-specific fine schedule. This decree is the legal foundation for everything that followed -- the DGI-run system built on top of it is one of the oldest mandatory e-invoicing regimes in Latin America.
Issued 8 May 2012, Resolución de Interés General 798/012 operationalized Decreto 36/012: it defined the CFE document types (e-Factura, e-Ticket, credit/debit notes, e-Remito, and more), set the XML-plus-electronic-signature format, required daily consolidated reporting to DGI, and established contingency receipts for system outages. This resolution is what let DGI begin designating taxpayers for voluntary and, later, compulsory incorporation -- the mechanism used for every mandatory wave that followed.
From 2014, DGI layered compulsory CFE incorporation on top of voluntary enrollment, starting with large taxpayers (Grandes Contribuyentes), CEDE-classified enterprises, and duty-free operators, then extending in successive annual waves keyed to each taxpayer's prior-year sales volume in Unidades Indexadas (UI): taxpayers with roughly UI 30 million/15 million in 2015 sales were brought in during 2016, UI 7 million/4 million (2016 sales) in 2017, UI 2.5 million/1.5 million (2017 sales) in 2018, and UI 750,000/305,000 (2018 sales) in 2019 -- each wave pulling in thousands more taxpayers. By the end of 2016, DGI counted over 5,000 cumulative electronic issuers processing more than 1.28 billion CFE a year.
Approved 30 November 2023 and published 1 December 2023, Resolución DGI 2548/023 extended an earlier compulsory-incorporation deadline (set by the companion Resolución 2389/023): taxpayers already reached by that designation got until 31 December 2024 to become electronic issuers, and anyone newly registering for VAT between 1 May 2024 and 31 December 2024 had to be issuing electronically before 1 January 2025. This resolution set the deadline that the universal-mandate milestone below actually delivers.
In an official communiqué published 28 November 2024, DGI announced that from 1 January 2025, essentially all remaining VAT contributors -- including those under the "IVA Mínimo" (minimum VAT) regime -- became electronic issuers, closing the exemption window the agency had maintained in various forms since 2012. A short, defined list of exceptions remains: taxpayers whose activity is exclusively agricultural with annual income below UI 4,000,000, VAT taxpayers performing only value-added construction services, non-resident income tax (IRNR) taxpayers, fully VAT-exempt activity outside free trade zones, and Uruguay's simplified micro-enterprise regimes (Monotributo, Monotributo Social MIDES, and Aporte Único). DGI's own announcement reported that electronic invoicing already reached 98% of documentation issued in the country at that point -- this is the closing phase of a digitalization process DGI began more than a decade earlier, not a sudden new requirement.
DGI's CFE technical specification has been revised repeatedly over the system's history -- most recently to versions 25 and 25.1. New data fields and validations across several schema zones entered production on 3 March 2026, and stricter mandatory controls followed on 15 April 2026 for invoice cross-reference and traceability data (currency and exchange-rate fields) and for authorized-representative and issuer RUC validation. This is routine technical schema evolution layered on top of the existing mandate, not an expansion of who must issue CFE.
A CFE is generated as a digitally signed XML document, using a numbered range (CAE) DGI has pre-authorized to the issuer, and transmitted to DGI for structural and format validation before being delivered to the recipient with a verification QR code. This is best understood as pre-authorized numbering with mandatory post-transmission validation -- DGI does not approve each individual invoice in real time before it reaches the buyer, but every CFE must still reach DGI and pass its checks to be a valid tax document.
Uruguay's CFE is best understood as pre-authorized numbering with mandatory post-transmission validation -- not a strict per-invoice clearance gate like Mexico's CFDI, but not a simple after-the-fact report either.
Confirm your invoicing software actually produces the specific CFE type your transaction requires -- issuing an e-Ticket where an e-Factura was needed, or vice versa, creates real compliance friction.
The mandate has expanded in stages: a voluntary pilot and legal foundation (2012), a multi-year phased rollout by taxpayer revenue tier (2014-2019), and a final deadline (Resolución 2548/023) that closed the exemption window for essentially all remaining VAT taxpayers on 1 January 2025. A short, defined list of exemptions remains -- see the dedicated scope card below for exactly who's still excluded.
This is the legal timeline -- see the next card for exactly who's covered as of the January 2025 universal mandate.
This list reflects DGI's own 28 November 2024 announcement -- if you're not sure whether an exemption still applies to your business, confirm directly with DGI rather than assuming an older carve-out survived the January 2025 closure.
A compliant invoice moves through this sequence under DGI's CFE regime:
This is not a strict per-invoice clearance gate -- DGI pre-authorizes the numbering, not each individual document in real time -- but every CFE must still reach DGI and pass its checks to be a valid tax document.
Most businesses reading this are likely already required to issue CFE, given how long Uruguay's mandate has been in place -- the real, current work is usually about maintaining compliance as DGI evolves the technical schema, not about a first-time rollout.
Check whether you were captured by an earlier revenue-tier wave (2014-2019) or only came into scope with the January 2025 universal mandate -- and confirm you don't fall into one of the narrow remaining exemptions.
You'll need an accredited electronic certificate for signing CFE, and to request your first numbered range (CAE) from DGI before you can issue compliant documents.
Use e-Factura for B2B sales, e-Ticket for retail/B2C, and the corresponding export, waybill, or withholding document types where they apply -- issuing the wrong type creates real compliance friction.
Confirm your software actually produces a compliant, signed CFE XML and transmits it to DGI -- don't rely on a manual or batch process that could fall behind DGI's numbering and validation requirements.
A CAE range is valid for two years and must be requested in batches of at least 100 numbers -- running out mid-operation would stop you from issuing compliant invoices.
DGI periodically revises the CFE technical specification -- most recently to v25.1, with new mandatory controls from 15 April 2026 -- so ask your provider directly rather than assuming ongoing compatibility.
Uruguay sets no CFE-specific fine schedule -- Decreto 36/012 itself says non-compliance is punished under the general Código Tributario regime, not a dedicated e-invoicing penalty table. That means real exposure runs through ordinary tax-procedure provisions: formal non-compliance, understated-tax fines, and -- for genuine deceit -- criminal fraud liability.
Other countries in the same region, ordered by their next dated milestone. Each links to a full briefing.