Cabo Verde is proposing a further tightening of its electronic invoicing regime from January 2027
Linking invoice issuance more closely to VAT chargeability, deduction and accounting records
- 2027 State Budget proposes new VAT chargeability and e-invoicing rules
- VAT due when invoices – or contingency documents – are issued
- Contingency documents would not provide a right to VAT deduction
- E-invoices to carry prescribed tax-operation and product codes
- Purchases to be recorded on receipt of the electronic invoice
The measures are contained in the 2027 State Budget proposal, approved by the Council of Ministers on 29 September and submitted to the National Assembly on 1 October 2026.
The changes go beyond electronic invoice format requirements. They connect invoice issuance more closely with when VAT becomes due, when customers may deduct VAT and when transactions enter the accounting records.
The proposals remain subject to enactment.
VAT chargeability linked to invoice issuance
Under the proposed amendments, VAT would become chargeable when an invoice is issued within the legally prescribed deadline.
Where a business operates its invoicing system in contingency mode, VAT would instead become due when the supporting contingency document is issued. However, that contingency document would not give the customer a right to deduct VAT.
This creates an important distinction during system interruptions: the supplier’s VAT liability may arise even though the customer cannot yet recover the VAT.
New e-invoice coding and purchase recording
Electronic invoices would also have to include prescribed:
- tax-operation codes; and
- product codes.
The detailed codes would be established by Ministerial Order.
Purchases would have to be recorded when the electronic invoice is received, strengthening the connection between invoice exchange and the purchaser’s accounting records.
Where non-electronic fiscal documents are permitted, they would be required to generate a HASH code supporting document integrity and verification.
Self-billing and rental invoices
The Budget also proposes tighter self-billing requirements.
Self-billing would require a prior agreement between the parties, evidence of supplier acceptance and use of a dedicated invoice series.
Property rental invoices would similarly require a dedicated series. They would have to identify the property, contract type and commencement date, together with the rent amount and payment periodicity.
2020-26 Cabo Verde’s existing e-invoicing regime
Cabo Verde introduced its electronic invoicing framework under Decree-Law No. 79/2020, establishing its Documento Fiscal Eletrónico (DFE) regime.
The system was subsequently made mandatory for taxable businesses and covers electronic fiscal documents across B2B, B2C and B2G transactions. The 2026 State Budget strengthened these controls further, including mandatory electronic issuance of invoices and other tax-relevant documents.
The reforms also introduced requirements including QR codes, a Unique Document Identifier (IUD) and the use of certified invoicing and accounting software.
The proposed 2027 changes therefore represent the next stage in this development.
Rather than simply requiring businesses to create a compliant electronic invoice, the invoice is increasingly determining how the underlying transaction moves through the VAT process:
Electronic invoice → VAT chargeability → purchase recording → VAT deduction
For businesses, that makes invoicing system controls increasingly important to VAT compliance. An invoice failure or contingency procedure may now affect not just the document itself, but the timing of VAT liability and recovery.
VATCalc’s live VAT invoice transaction and e-invoice tracker on real-time transaction-based tax reporting lists all the countries imposing transaction-based reporting.
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