The 100-invoice threshold: what it means and how to measure it
Resolution 201-6299 requires contracting a PAC if you issue 100 invoices or more per month. We explain how it's counted, which documents add up and how not to slip.
The double threshold of Resolution 201-6299 — B/.36,000 per year and 100 documents per month — determines whether a taxpayer can keep using the DGI’s free facturador. Most accountants know the revenue threshold; the 100-invoice one creates more confusion. This post clarifies how to count.
Which documents count
The count includes any electronic fiscal document issued:
- Electronic invoice (type 01).
- Receipt (type 02).
- Export document.
And also:
- Credit notes (03).
- Debit notes (04).
Even though credit and debit notes don’t generate new revenue, they do consume sequentials and are issued as electronic documents, so the DGI counts them toward the threshold.
What does NOT count
- Quotations and purchase orders — not fiscal documents.
- Invoices voided before receiving a CUFE — a sequential was consumed but the DGI did not issue a CUFE, so the document doesn’t fiscally exist.
- Internal pre-invoices or pro formas.
The measurement window
The threshold is evaluated monthly, per calendar month. If in January you issued 98 documents and in February 105, in February you had to operate with a PAC. The DGI does not apply a rolling window nor require you to stay under the threshold every month of the year: a single month above the line activates the obligation.
Edge cases
High seasons. A business that usually issues 40 documents/month but reaches 120 in December falls under the obligation for that month. In practice, the recommendation is to prepare the PAC before peak season and operate year-round with it — migrating mid-peak is traumatic.
Dual activity. A taxpayer with two RUCs (e.g., individual + company) evaluates each RUC separately. Documents don’t aggregate.
Recurring services. If you issue 90 monthly invoices to fixed clients, you’re on the edge. A new client stepping in, or any credit note, pushes you over. Better to get ahead of it.
What happens if I cross the threshold without a PAC
The DGI can reject documents issued beyond the threshold on the free facturador, which means:
- Invalid invoices for the buyer (non-deductible).
- Non-compliance penalties under the general tax regime.
- Customer complaints if they need the valid XML for their own filing.
None of those consequences is recoverable with a letter or a phone call: every rejected document must be reissued through a PAC.
How to measure it for your business
- Count documents issued last month on the DGI portal or in your current system.
- If the average of the last 3 months is above 70, get ready. A 15%-busier month takes you to 100.
- If you’ve already exceeded 100 once in the last 12 months, operating with a PAC is the safe call, even if the next few months trend down.
How FacturaHQ monitors it
Our dashboard includes a monthly volume alert. If you’re on the Pro plan (up to 100 documents/month) and approach the limit, we warn you before day 20. If you exceed it, the next document still issues with a clear marginal charge. No one halts your operation over a number on a counter.
Recommendation
The 100-invoice threshold isn’t a penalty for selling more: it’s the point where the free facturador stops being appropriate. If you’re close, don’t wait to cross it; migrate during a calm month. Avoiding onboarding in the middle of December is a lesson many learn the hard way.