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An unanswered invoice is accepted after 3 business days

Last verified: 2026-10-27 · Status: Stable

Abroad, an invoice is usually just a request for payment; in Colombia a sales invoice is a negotiable instrument that the buyer accepts irrevocably if it does not reject it within 3 business days. Electronic invoices circulate as securities through DIAN's RADIAN registry, so suppliers can sell them to factoring firms and banks. Blocking the free circulation of a supplier's invoice is a restrictive trade practice, and managers must certify every year that they did not do it.

USD figures use the TRM (tasa representativa del mercado) of COP 3,157.94 per US dollar valid on 27 October 2026, certified by the Superintendencia Financiera and published on datos.gov.co. Conversions are for orientation only.

Key facts

Period to reject an invoice before irrevocable acceptance	3 business daysCódigo de Comercio art. 773; Ley 1676 de 2013 art. 86, as of 2026-10-27 · in force
Period to reject an electronic invoice as a security, from receipt of goods or service	3 business daysDecreto 1074 de 2015 art. 2.2.2.53.4, as of 2026-10-27 · in force
TRM used for conversions on this page	3157.94 COP per USDTRM certified by the Superintendencia Financiera, valid 27 October 2026, as of 2026-10-27 · in force

The rule

1. The invoice is irrevocably accepted by the buyer or service recipient if it does not claim against its content, either by returning it with the shipping documents or by a written claim to the issuer or holder, within 3 business days of receipt. If the buyer neither accepts nor rejects and the seller wants to endorse the invoice, the seller must record that fact on the title under oath.
Cost to do it: No fee. A buyer that misses the window loses the right to dispute the invoice's content against holders.
Example: A supplier delivers an invoice for COP 50,000,000 on a Monday; if the buyer has not rejected it by Thursday, it is accepted and can be sold to a factor. / About US$15,833.Código de Comercio art. 773 as amended by Ley 1231 de 2008 art. 2; Ley 1676 de 2013 art. 86 (Diario Oficial 48.888, 20 August 2013, in force six months after promulgation), Ley 1676 de 2013 art. 86 and art. 91, 2013-08-20 official text · verified 2026-10-27 · changed: Ley 1676 de 2013 cut the period from 10 calendar days (Ley 1231 de 2008) to 3 business days. Some official compilations of the Código de Comercio and of Ley 1231 still show the old 10 day text.

2. An electronic sales invoice as a security is irrevocably accepted when the buyer expressly accepts it electronically within 3 business days of receiving the goods or service, or tacitly when it does not claim against its content in an electronic document within 3 business days of receipt of the goods or service. Receipt is evidenced by the buyer's electronic receipt record, and the issuer must record the facts of tacit acceptance in RADIAN under oath.
Cost to do it: No government fee; issuers usually pay a technology provider to register events in RADIAN.
Example: A buyer receives services on 2 November 2026 and gets the electronic invoice; unless it sends an electronic claim within 3 business days, the supplier can register tacit acceptance in RADIAN and offer the invoice to a factor. / Same timing for a US$15,833 invoice.Decreto 1074 de 2015, chapter 2.2.2.53 as replaced by Decreto 1154 de 2020 (Diario Oficial 51.412, 20 August 2020), Art. 2.2.2.53.4, 2020-08-20 official text · verified 2026-10-27

3. Accepted electronic invoices meant to circulate must be registered in RADIAN by the issuer, together with every related event (acceptance, endorsement, payment). DIAN, as RADIAN administrator, certifies the existence and traceability of the invoice to competent authorities or legitimate holders.
Cost to do it: No government fee.
Example: A factoring firm checks RADIAN before buying an invoice to confirm acceptance and that it has not already been endorsed. / Not a fee rule.Decreto 1074 de 2015 (Decreto 1154 de 2020), Art. 2.2.2.53.7 and art. 2.2.2.53.14, 2020-08-20 official text · verified 2026-10-27

4. Any retention of the invoice, or act of the buyer that prevents its free circulation, is a restrictive trade practice that the Superintendencia de Industria y Comercio investigates and sanctions on its own initiative or at the request of the affected party. Managers of commercial companies must state in their annual management report that they did not obstruct the free circulation of invoices issued by sellers or suppliers, and the statutory auditor must give an opinion on that statement.
Cost to do it: Exposure to competition sanctions; also an annual reporting item.
Example: A buyer whose purchase terms forbid suppliers from factoring its invoices risks an investigation by the Superintendencia de Industria y Comercio. / Not a fee rule.Ley 1231 de 2008 art. 7, paragraphs added by Ley 1676 de 2013 art. 87, Ley 1676 de 2013 art. 87, 2013-08-20 official text · verified 2026-10-27

Worked example

A US parent's Colombian subsidiary receives a COP 49,000,000 invoice it believes overstates the quantity delivered. Its accounts payable team routes it for approval for two weeks before objecting. By then the invoice is accepted, a factor holds it, and the subsidiary must pay the factor in full and pursue the supplier separately for the overcharge.

Step by step

Set up receipt of electronic invoices so that disputes are raised by electronic claim within 3 business days.
Record the electronic receipt of goods or services promptly; the 3 days for electronic invoices count from that receipt.
Do not include clauses that forbid suppliers from endorsing or factoring invoices.
Include the free circulation statement in the annual management report.

Common traps

The 3 days are business days and short; internal approval cycles longer than that mean accepting invoices by default.
Some official compilations still show 10 calendar days; the current period is 3 business days.
Once accepted and endorsed, the buyer cannot oppose the factor with defenses about the content of the invoice that it should have raised in time.

Sources

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