The DGI free invoicing tool has been a useful tool for micro-enterprises in Panama, but it has a strict limit: B/.36,000 in annual revenue. Once your company exceeds that threshold, migrating to an authorized PAC is no longer optional. This article is a step-by-step guide to successfully making that migration in 2026, without operational disruption.
Important: verify the current limits and requirements with the DGI or your accountant before making operational decisions. Panama's electronic invoicing regulations are updated through periodic resolutions.
When is migration mandatory?
Your company must migrate from the DGI free invoicing tool to a PAC in any of these scenarios:
- Annual revenues exceed B/.36,000: the free invoicing tool is only authorized for companies below this threshold.
- Specific DGI designation: certain activities or sectors require a PAC from the outset, regardless of revenue.
- Expected growth: if your annual projection will exceed the threshold, anticipate the migration. Operating with the wrong system at the moment of crossing the threshold constitutes non-compliance.
For more details about what the law says, see our Law 256 of 2021 guide.
What happens if you don't migrate on time?
Non-compliance can result in:
- Fines for issuing invoices without a valid CUFE.
- Surcharges on ITBMS not correctly invoiced.
- Inability to obtain a tax clearance certificate from the DGI (affects public contracts, banking transactions).
- Specific audits with additional consequences.
The 5 stages of migration
Stage 1: Validate the obligation and choose a PAC
Validation: - Calculate your current annual revenues (last 12 months). - Estimate the projection for the next 12 months. - Confirm the migration obligation with your accountant.
Choosing a PAC: Three authorized options in Panama:
- WebPOS: ideal for SMEs with a local focus, support in Panamanian Spanish.
- Alanube: modern API, regional presence, ideal for companies with a technical team.
- The Factory HKA: enterprise-grade, ideal for large companies with multi-country operations.
For a detailed comparison, see our authorized PAC comparison guide.
Stage 2: Obtain a digital certificate
For a PAC to generate the CUFE on your invoices, you need a digital certificate (electronic signature) issued by a recognized certification authority in Panama.
Typical steps:
- Contact an authorized certification authority.
- Gather documentation: legal representative's ID, company registration, RUC.
- Make payment for the certificate (certificates typically have a 1-2 year validity with associated cost).
- Receive the digital certificate (typically as a PFX/P12 file with a password).
- Safeguard the certificate: the PAC and/or your system will need access to sign invoices.
Time: 5-10 business days from the request until the certificate is issued.
Stage 3: Contract the PAC and configure the integration
With the PAC selected and the digital certificate in hand:
- Contracting: sign the contract with the PAC, define the plan based on estimated volume.
- Technical configuration: the PAC provides API credentials (sandbox and production) and documentation.
- Integration with your system:
- If you use an ERP that natively integrates the PAC (like cifraHQ), configuration means entering credentials.
- If your system is proprietary or does not integrate the PAC, development work is required (typically 2-4 weeks of development).
Time: 1-3 weeks depending on the complexity of your current system.
Stage 4: Sandbox testing
Before issuing real invoices with the PAC, your system must be tested in the PAC's and DGI's sandbox environment:
- Issuance of test invoices.
- Validation of the generated CUFE.
- Test credit notes.
- Contingency handling (when the PAC or DGI do not respond).
- Reports and digital archiving.
The PAC and DGI have certification processes for clients: your company must demonstrate that its system meets requirements before moving to production.
Time: 1-2 weeks depending on the complexity of your system and the volume of tests.
Stage 5: Go-live and decommissioning of the free invoicing tool
Go-live day: - Last invoice in the free invoicing tool. - First production invoice with the PAC. - Notify regular customers of the change (especially large taxpayers who may have automated validation processes). - Retain the historical archive of invoices from the free invoicing tool (for the legal retention period of 5 years).
Post go-live (first 2-4 weeks): - Intensive monitoring of invoicing (verify that each invoice is issued correctly). - Reconciliation with the monthly Form 430. - Rapid resolution of any incidents with the PAC or DGI.
Typical migration costs
Variable costs include:
- Digital certificate: depends on the certification authority and validity period (1-2 years).
- PAC contract: variable pricing model (monthly subscription, per transaction, enterprise plans).
- Integration (if applicable): software development if your system does not natively integrate the PAC.
- Team training: staff time dedicated to learning the new system.
Estimated total cost for a Panamanian SME: typically between B/.500 and B/.3,000 in direct costs for the initial migration, plus the monthly PAC subscription. Cost varies significantly based on volume and complexity.
Common migration mistakes
- Waiting until the last moment: starting the migration when you are already close to the threshold generates urgency and errors.
- Not testing in sandbox: moving directly to production without thorough testing guarantees problems.
- Not notifying customers: corporate customers with automated processes may reject the first CUFE-bearing invoices if not notified.
- Not retaining the free invoicing tool archive: historical invoices remain legal documentation for 5 years.
- Underestimating the digital certificate: forgetting to renew it before expiration stops invoicing entirely.
- Choosing a PAC based only on price: the cost of one day of downtime due to support issues outweighs years of savings.
How cifraHQ simplifies migration
cifraHQ has native integration with WebPOS, Alanube, and The Factory HKA. When you migrate to cifraHQ from the DGI free invoicing tool:
- PAC configuration in hours, not weeks: the technical integration is already built.
- Data import: customer catalog, products, opening balances.
- Process support: we assist with the digital certificate request and pre-certification with the PAC.
- Sandbox testing: we run thorough tests before go-live.
- Post go-live support: 30-60 days of intensive support depending on the plan.
In addition to electronic invoicing, you get IFRS accounting, payroll, inventory, multi-company — all in a single platform.
Ready to migrate? Request a demo or learn more on our free invoicing tool to PAC migration page.
Related resources
This article is educational. Costs, timelines, and procedures may change; verify with each PAC, certification authority, and the DGI before starting the migration.