The Peruvian Tax Administration SUNAT recently authorised the first two e-invoicing operators that will eventually take over the current centralised clearance service at SUNAT: Peruvian/Danish owned eFact and Chilean/US owned Paperless/SOVOS. SUNAT’s new model is a distributed one, named “OSE” (Operador de Servicios Electrónicos) in Peru and has both similarities and differences with the Mexican “PAC” model.
SUNAT started the migration process towards distributed clearance earlier this year by issuing a decree with an ambitious plan to be ready by now. Despite this, as with other clearance countries and their original plans, significant changes in the regulatory & technical framework have caused delays in the process. However, progress has been made in operational aspects related to migration and accreditation of OSE operators. With the approval of eFact and Paperless/SOVOS, the new distributed OSE model has been formally launched and is today co-existing with the centralised model at SUNAT. Adherence to OSE operators is optional and companies can choose between the new OSE and the legacy SUNAT model.
However, according to legislation, as soon as a third OSE operator becomes authorised, the OSE model will automatically become mandatory, meaning that taxpayers who are newcomers to e-invoicing will only be able to issue invoices under the new OSE model. Existing taxpayers will undergo a migration period to OSE within 3 months. At the end of the 3 month migration period, SUNAT will shut down its centralised clearance services. Taxpayers who are today using accredited service providers, that essentially are accredited brokers not clearance operators, are less likely to be impacted technically as brokers would only need to change the clearance point from SUNAT to OSE.
With these changes in progress, it is worth recapping how the Peruvian clearance model has been evolving over the years. The model began by borrowing experiences from Chile, Peru’s neighbouring country to the south and a pioneer in e-invoicing. It wasn’t long before SUNAT realised that the Chilean model did not perfectly suit Peruvian needs. In fact, Chile hasn’t evolved its technical framework despite major advances in technology and e-invoicing practices and now is lagging behind in some technical aspects. The concept of centralised clearance was also not suitable for the aggressive SUNAT adoption plans. SUNAT therefore made the strategic decision to rely on the UBL standard, pure W3C signatures and minimal SUNAT-dependencies such as no control over invoice numbering (folios). With the OSE model, SUNAT is borrowing experiences from the Mexican distributed ‘PAC’ clearance model. Interestingly, a neighbouring country on the northern border, Colombia, is following the same direction as Peru. More can be read about this here.
Clearance models continue to spread across the globe, with countries learning from each other but making local decisions, resulting in clearance flavours that add compliance complexity, especially for multi-national companies. But there is one common crucial enabler – confidence and reliance on electronic signatures as the only feasible mechanism for ensuring Integrity and Authenticity for real-time tax controls. The success is impressive – in Latin-America only, the accumulated volume is 50 billion e-invoices up to this year since e-invoice was introduced more than 10 years ago.
