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Corporations and branches need a statutory auditor

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

Abroad, small and closely held companies often need no external auditor; in Colombia every corporation with shares under the Código de Comercio and every branch of a foreign company must have a revisor fiscal. Any other commercial company, including an SAS, needs one when its gross assets reach 5,000 minimum wages or its gross income 3,000 minimum wages. The revisor fiscal must be a licensed public accountant, independent of the company, and answers for negligence.

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

Gross assets that require a revisor fiscal5000 monthly minimum wagesLey 43 de 1990 art. 13 par. 2, as of 2026-10-27 · in force
Gross income that requires a revisor fiscal3000 monthly minimum wagesLey 43 de 1990 art. 13 par. 2, as of 2026-10-27 · in force
Entities that always need a revisor fiscalCompanies with shares under the Código de Comercio and foreign company branches textCódigo de Comercio art. 203, as of 2026-10-27 · in force
Monthly minimum wage 20261750905 COPDecreto 1469 de 2025 art. 1, as of 2026-10-27 · in force
TRM used for conversions on this page3157.94 COP per USDTRM certified by the Superintendencia Financiera, valid 27 October 2026, as of 2026-10-27 · in force

The rule

1. Companies with shares (sociedades por acciones), branches of foreign companies, and companies where management does not belong to all partners when partners excluded from management holding at least 20 percent of capital so request, must have a revisor fiscal, elected by absolute majority of the shareholders' meeting or, for branches, by the competent body under the bylaws.
Cost to do it: Professional fees of a licensed accountant or audit firm.
Example: A Colombian sociedad anónima or a branch of a US company must appoint a revisor fiscal from day one, whatever its size. / Not a government fee.Código de Comercio (Decreto 410 de 1971), Art. 203 and art. 204, 1971-03-27 official text · verified 2026-10-27
2. It is mandatory to have a revisor fiscal in all commercial companies of any kind whose gross assets at 31 December of the prior year reach 5,000 minimum wages and/or whose gross income in the prior year reaches 3,000 minimum wages.
Cost to do it: Professional fees once the threshold is reached.
Example: At the 2026 minimum wage of COP 1,750,905, the thresholds are about COP 8,754,525,000 of gross assets and COP 5,252,715,000 of gross income. / About US$2.77 million of assets and US$1.66 million of income.Ley 43 de 1990 (13 December 1990), Art. 13 par. 2, 1990-12-13 official text · verified 2026-10-27
3. In an SAS, if the law requires a revisor fiscal, the position must be filled by a public accountant with a valid professional card; in any case, profits must be supported by financial statements audited by an independent public accountant.
Cost to do it: Professional fees.
Example: A small SAS below the Ley 43 thresholds needs no revisor fiscal, but distributing dividends requires statements certified by an independent accountant. / Not a government fee.Ley 1258 de 2008, Art. 28, 2008-12-05 official text · verified 2026-10-27
4. A revisor fiscal may not be a shareholder of the company or its subsidiaries, a relative within the fourth degree of managers or the accountant, or hold any other position in the company. The revisor fiscal checks that operations follow the bylaws and decisions, reports irregularities in writing, and issues an opinion on the financial statements; it is liable for damages caused by negligence or wilful misconduct, and knowingly certifying materially inaccurate statements carries criminal penalties.
Cost to do it: Professional fees; liability falls on the auditor.
Example: The foreign parent's group CFO cannot act as revisor fiscal of the Colombian subsidiary. / Not a fee rule.Código de Comercio, Art. 205, 207, 208, 211 and 212, 1971-03-27 official text · verified 2026-10-27
5. Ley 2294 de 2023 created the Unidad de Valor Básico (UVB) and provides that charges, fines and financial requirements for operating companies that are set in minimum wages must be computed by their UVB equivalence. Whether this reaches the revisor fiscal thresholds of Ley 43 de 1990 is debated; this page states them in minimum wages as the text of Ley 43 does.
Cost to do it: No fee.
Example: A company close to the thresholds should check them under both readings with its advisers. / Not a fee rule.Ley 2294 de 2023 (Diario Oficial 52.400, 19 May 2023), Art. 313, 2023-05-19 official text · verified 2026-10-27
EntityRevisor fiscalSource
Sociedad anónima and other companies with shares under the Código de ComercioAlwaysCódigo de Comercio art. 203
Branch of a foreign companyAlwaysCódigo de Comercio art. 203
SAS, limitada and other commercial companiesWhen gross assets reach 5,000 or gross income 3,000 minimum wagesLey 43 de 1990 art. 13 par. 2

Who needs a revisor fiscal

Worked example

  • A foreign investor choosing between a branch and an SAS for a small sales office should factor in that the branch must appoint a revisor fiscal immediately, while the SAS needs one only once it crosses the asset or income thresholds.

Step by step

  1. Check at each 31 December whether the company crossed the asset or income threshold.
  2. Have the shareholders' meeting elect the revisor fiscal and register the appointment in the commercial registry.
  3. Confirm independence: no shares, family links or other roles in the company.
  4. Include the revisor fiscal in the annual close timetable; its opinion goes with the financial statements.

Common traps

  • A branch needs a revisor fiscal even with no revenue.
  • The thresholds use the prior year's figures, so an SAS growing fast may need one the following year.
  • Group auditors abroad do not replace the Colombian revisor fiscal.

Sources

Related pages

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