Invoicing in contingency mode: what to do when the system fails (CFC)

You issue electronic invoices and one day the system doesn't respond, or the connection to DGI drops. Do you have to stop invoicing? No. DGI Resolution 798/012 foresees this scenario: it's called 'contingencia' (contingency). Here we explain, in plain terms, what it is, what a CFC (Comprobante Fiscal de Contingencia, contingency receipt) is, the key difference between your system going down and only the communication with DGI going down, and what happens once everything is back to normal.

What is contingency?

Contingency is simply the plan B: the set of rules for continuing to document your sales when, due to some technical problem, you can't issue your electronic fiscal receipts (CFE) the usual way. The underlying idea is simple: a failure can't halt your activity or leave operations undocumented. The rule distinguishes two very different situations depending on what fails, and the response for each is different.

The CFC (contingency receipt)

When the problem is that you can't use the system itself (say, a power cut, broken hardware or a failure in your invoicing software), the rule lets you document with a special pre-printed receipt: the Comprobante Fiscal de Contingencia (CFC). It's a backup receipt book you keep precisely for these cases. The resolution puts it like this:

DGI Resolution 798/012:

«Cuando no resulte posible la utilización del sistema, los emisores electrónicos deberán operar con un nuevo tipo de comprobantes preimpresos que se denominarán Comprobantes Fiscales de Contingencia (CFC)»

In English: When it is not possible to use the system, electronic issuers must operate with a new type of pre-printed receipts called Contingency Fiscal Receipts (CFC)

Careful: a dropped connection is not the same thing

Here's the important distinction many people get wrong. If the problem is NOT your system but only the communication with DGI (your equipment works, but it can't send the data to DGI at that moment), then you should NOT issue a CFC: you keep issuing your normal CFE and the send to DGI catches up once the connection is restored. The rule clarifies this in two parts:

On when NOT to use a CFC:

«No corresponderá emitir CFC cuando se produzcan exclusivamente fallas en la comunicación que impidan la remisión de la información correspondiente a la Dirección General Impositiva.»

In English: A CFC shall not be issued when there are exclusively communication failures that prevent sending the corresponding information to the DGI.

And on how the send is regularized:

«Cuando se verifiquen exclusivamente fallas en la comunicación con la Dirección General Impositiva, se deberá proceder al mencionado envío una vez superada la misma; sin perjuicio de continuar documentando las operaciones mediante los correspondientes CFE.»

In English: When there are exclusively communication failures with the DGI, the mentioned send shall be carried out once the failure is overcome; without prejudice to continuing to document operations through the corresponding CFE.

What happens once things are back to normal?

When the problem is resolved, you have to catch up with DGI. If it was only a communication failure, the daily report with everything issued is sent as soon as the connection returns. If you used CFC because you couldn't operate the system, those contingency receipts must also be reported to DGI per the resolution's rules, once the system is available again. In both cases, the essential point is that no operation is left undocumented and unreported.

In practice, your software handles it

The good news: you don't have to memorize the technical procedure. Your electronic-invoicing solution — your authorized provider's or your own system — detects the contingency, lets you keep documenting, and, when the connection or the system comes back, regularizes the send to DGI automatically. Your job is not to stop documenting the sale; the software resolves the rest.

Practical tips

Three simple things: (1) keep your CFC receipt book (the pre-printed backup receipts) on hand in case the system stops working; (2) during an outage, ask your provider whether it's your system that's failing or only the communication with DGI, because the correct response changes; and (3) once things are back to normal, confirm with your provider that the daily report and the contingency receipts were actually sent and accepted by DGI.

• The daily invoice report to DGI (Resolution 798/012)
• Electronic invoicing (CFE) in Uruguay: how it works

Frequently asked questions

• Can I keep invoicing if the system goes down? Yes: you document with a Contingency Fiscal Receipt (CFC).
• And if only the connection to DGI drops? You don't use a CFC: you keep issuing your normal CFE and the send catches up later.
• What is a CFC? A pre-printed backup receipt for when you can't use the system.
• Do I have to do anything technical? Generally no: your invoicing software manages the contingency and regularizes the send.
• What about what I issued during the failure? It's reported to DGI once the failure is overcome; it can't be left unreported.
• Where do I get the CFC receipt book? You arrange it through your electronic-invoicing provider.

In short: contingency is the plan B so a technical failure doesn't stop you. If your system goes down, you document with CFC; if only the DGI connection drops, you continue with your normal CFE and the send is regularized afterwards. Your software handles almost everything, but it's worth keeping the CFC book on hand and confirming, once the failure is over, that everything reached DGI. When in doubt, check with your provider and DGI.