The Certified Electronic Invoicing System (SFEC) is a mechanism for securing and certifying invoices issued in the Republic of Congo for all sales and service transactions carried out by individuals or corporate entities.
- Legal Framework:
The SFEC was initially introduced by the Finance Law for 2012 (see section F – new provisions, page 35).
In its current form, the system was established by Law No. 77-2022 of 27 December 2022, enacting the Finance Law for 2023, and amended by Law No. 47-2024 of 30 December 2024, enacting the Finance Law for 2025.
With the Decree No. 2026-101 of 31 March 2026, regulating the Certified Electronic Invoicing System, the legal framework has now been strengthened by a key implementing text, enabling the system to enter its operational phase. This decree provides for a three (3) month transitional period for economic operators to ensure compliance.
- Effective date:
Companies under the Big Enterprises Unit (UGE) and the Medium Enterprises Unit (UME) are required to comply with the SFEC as from 1 August 2026.
Initially scheduled for 1 July 2026 (cf. article 31 of Decree No. 2026-101 of 31 March 2026, regulating the
certified electronic invoicing system), this deadline has been extended to 1 August 2026.
For companies under the Very Small and Small Enterprises Unit (UTPPE), the effective date has not yet been set by the tax authorities.
However, in our opinion, given the progress of the IT infrastructure deployment, this deadline may not be met by the tax administration and is likely to be postponed. We will keep you informed of any developments on this matter.
- Persons subject to the SFEC:
Any individual or legal entity carrying out commercial transactions.
- Objectives of the SFEC:
With the implementation of the SFEC, the tax authorities aim to:
- ensure real-time traceability of invoicing for monitoring and audit purposes,
- promote invoice dematerialization, enabling companies to modernize their operations and eliminate paper-based processes,
- enable real-time monitoring of VAT collected and deductible VAT,
- increase tax revenue collection.
- Implementation of the SFEC:
The SFEC relies on four invoicing methods:
- e-Facture: a secure web portal allowing the issuance, certification, and download of certified electronic invoices. It does not require any technical installation and is particularly suited to businesses with low invoicing volumes or without invoicing systems.
- API integration: the SFEC API is designed for businesses with internal invoicing systems (ERP, accounting software, etc.) connected to the internet. It enables automated and secure data exchange via HTTPS between the company’s system and the SFEC platform, without altering invoicing processes. Each invoice is automatically transmitted for certification.
- Invoicing and Certification Terminal (TFC): a certified standalone device intended for businesses without an invoicing system and seeking a turnkey compliant solution. It allows the issuance and instant certification of invoices, including automatic QR code generation and secure transmission to the SFEC platform.
- Control and Certification Terminal (TCC): a certified solution for businesses already using cash registers or commercial management systems. It integrates securely with existing infrastructure and enables automatic certification of invoices and receipts without modifying internal processes.
For assistance, please contact the SFEC support service via: https://sfec.gouv.cg/contact
- Penalties:
Failure to comply with the obligation to issue SFEC-certified invoices exposes offenders to the following sanctions:
- non-deductibility of expenses for corporate income tax (CIT): Article 25 of the General Tax Code Volume 1, provides that invoices not issued through the SFEC are not deductible from taxable income and must be reintegrated and taxed accordingly.
- non-deductibility of VAT: under Article 31 of the VAT Law, VAT on invoices not certified through the SFEC is not deductible.
- financial penalty: Article 34 bis of the VAT Law provides that any breach of the obligation to use the SFEC is subject to a tax fine of XAF 50,000,000.
At CLG, we are committed to making this transition as smooth as possible. Together, we can turn challenges into opportunities and ensure that your business thrives in a changing environment.
For tailored advice or to discuss the impact of these changes on your business, please feel free to contact us.
CLG Tax Team
