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Would Your Business Pass a Hacienda Inspection?

Having an accountant does not automatically mean those controls are working.

Your bookkeeping is up to date. Your tax returns have been filed. You pay for professional accounting services.

But what happens when a Hacienda inspector walks into your business and makes a purchase?

At that moment, compliance depends on what your employees actually do: whether they issue and deliver the electronic invoice, whether the transaction enters your records, and whether someone catches and corrects exceptions.

Having an accountant does not automatically mean those controls are working.

A warning Costa Rican business owners should take seriously

On November 3, 2026, Costa Rica’s Ministry of Finance reported irregularities in 375 of 534 businesses inspected, with associated sanctions exceeding ₡475 million, according to reporting by Teletica and La Nación.

Approximately 70% of the inspected establishments had compliance failures. These businesses were selected using tax risk criteria; the figure is not a finding about 70% of all businesses in Costa Rica.

Inspectors used undercover purchases and field visits. In 331 establishments, they found failures to issue and deliver the corresponding electronic invoice at the time of purchase.

Your next customer could be checking your compliance.

“My accountant handles that” is a dangerous assumption

Accounting services and operational compliance are connected, but they are not interchangeable.

Bookkeeping records the information made available. Tax preparation uses that information to prepare returns. Internal controls help ensure that transactions are captured completely, handled correctly, and supported by evidence.

Consider this illustrative example: an employee receives payment but fails to issue the invoice. The sale is also missing from the information sent to the accountant. Unless a reconciliation or another review identifies the gap, the accounting process may never see the transaction.

A filed return cannot, by itself, demonstrate that every sale was invoiced correctly.

The practical question is: what process would detect that missing sale—and who checks that the process actually runs?

A written policy is only the beginning

“We have a procedure” is not the same as “we follow the procedure.”

Controls can fail because they were never implemented, employees were not trained, supervisors stopped checking, or exceptions were repeatedly left unresolved.

Ask yourself:

  • Is invoicing followed consistently across every shift and location?
  • Who checks invoice acceptance and follows up on rejected documents?
  • Who reconciles sales, cash, card settlements, bank transfers, and electronic invoices, accounting for timing differences?
  • Who investigates unexplained discrepancies?
  • What evidence shows that these reviews were completed?

If nobody owns the task, or nobody can show the review, you have a gap worth investigating.

Software needs supervision too

A billing system is a tool. Its presence does not prove that every transaction has been processed correctly.

Hacienda’s reported checks also covered electronic invoicing version 4.4 and acceptance by its institutional validator. That makes follow-up essential: generating a document is one step; verifying its status and resolving exceptions are separate tasks.

Your controls should make failures visible while there is still time to act.

For our existing clients: this applies to you too

Using our bookkeeping and accounting services should never be interpreted as confirmation that every aspect of your business is compliant.

The work covered by your engagement matters. So do the completeness of the information provided, the controls implemented within your business, and management’s response to identified issues.

We can help identify weaknesses, recommend improvements, and support implementation within an agreed scope. Management must assign responsibilities, ensure employees follow procedures, and act on exceptions. Any monitoring assigned to us should also have a clearly defined scope and reporting process.

If a recommendation remains unimplemented, the underlying exposure remains.

Find the gaps before an inspector does

Do not wait for a failed inspection to discover that everyone assumed someone else was checking.

Contact us to arrange a review of your invoicing processes and internal controls. Together, we can identify gaps, prioritize corrective actions, and define who is responsible for implementation and follow-up.

You already invest in accounting. Make sure your daily operations support it.

Would Your Business Pass a Hacienda Inspection?
CARLOS MARIO FAJARDO LIZANO November 4, 2026
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