Congo-Brazzaville makes its certified e-invoicing system (SFEC) mandatory in the 2025 Finance Law

What changed in detail

Loi n° 47-2024 du 30 décembre 2024, the finance law for 2025, was published in the Journal officiel, Édition spéciale N° 15-2024, on 31 December 2024. Its point 22 amends the TVA law and adds article 34 bis (nouveau) and article 34 ter.

Article 34 bis requires invoices to be issued by the supplier through the Système de Facturation Électronique Certifiée (SFEC). Specifically:

• every taxable person must use the SFEC to support its transactions with third parties;
• every customer, whether or not liable to TVA, must demand an SFEC-certified invoice for its purchases;
• all economic transactions on Congolese territory are certified by the SFEC, except those involving a foreign supplier;
• any breach of the SFEC obligation is punished by a fiscal fine of FCFA 50,000,000;
• TVA borne on a non-compliant transaction gives no right to deduction.

Article 34 ter makes the tax administration responsible for implementing the system. The same law adds SFEC security elements to the statement that must accompany a deduction claim (article 31).

The finance law applies from 1 January 2025. It sets no separate operational start date for the SFEC.

What it means

This is the statutory base for the SFEC, and it is still in force. Loi n° 41-2025 of 31 December 2025 (the 2025 amending finance law, Journal officiel, Édition spéciale N° 2-2026) restates the SFEC article. The system itself started later. Décret n° 2026-101 of 31 March 2026 organised the platform and its invoicing methods. Mandatory use was postponed from 1 July to 1 August 2026 for large and medium enterprises, with very small enterprises from 1 December 2026.

The two sanctions in this article now bite together. A non-compliant invoice exposes the supplier to the FCFA 50 million fine, and the customer loses the input TVA on it. That gives customers a reason to refuse invoices that do not come through the SFEC. The 2026 finance law (Loi n° 42-2025) went further and made an SFEC invoice a condition for deducting the expense itself.