TL;DR: Not every taxpayer has to migrate to Agencia Virtual in 2026. Four regimes can keep using Declaraguate after June 2 and September 1, 2026: VAT Small Taxpayer, Electronic Small Taxpayer, Special Primary (agriculture and crafts), and Special Agricultural (livestock, hydrobiological, and beekeeping). If you belong to any of them, this migration does NOT apply to you.
Why This Disambiguation Matters
When SAT announced on March 11, 2026, the migration from Declaraguate to Agencia Virtual, many small taxpayers assumed they also had to migrate. They don’t. The announcement applies specifically to Special Taxpayers (Phase 1, June 2) and to the General VAT Regime (Phase 2, September 1). Four specific regimes were explicitly excluded.
Prensa Libre published the list of the 4 unaffected regimes on May 13, 2026 in an article by reporter Glenda Burrión.
The 4 Regimes That Can Keep Using Declaraguate
| Regime | Who it typically applies to | Stays on Declaraguate |
|---|---|---|
| VAT Small Taxpayer Regime (Pequeño Contribuyente) | Small commerce and services below the legal income threshold | Yes |
| Electronic Small Taxpayer Regime (Pequeño Contribuyente Electrónico) | Small taxpayers with mandatory electronic invoicing | Yes |
| Special Primary Regime (Especial Primario) | Agricultural activities and crafts | Yes |
| Special Agricultural Regime (Especial Agropecuario) | Livestock, hydrobiological (fishing, aquaculture), and beekeeping | Yes |
What Each One Means (Quick Profile)
VAT Small Taxpayer Regime
The simplified VAT regime for taxpayers with annual income below the legal threshold. Pays a single reduced rate and carries fewer administrative burdens than the General Regime. It’s the most used regime by small shops, low-billing independent professionals, and early-stage entrepreneurs.
Electronic Small Taxpayer Regime
A variant of the Small Taxpayer that uses mandatory electronic invoicing (FEL). The underlying tax rules are those of the Small Taxpayer, but invoicing is 100% online via FEL. The suggested-returns flow in App FEL is also available for this variant.
Special Primary Regime
A specific regime for the agricultural and craft sectors. It has tax treatment tailored to activities with long production cycles, strong seasonality, and tight margins. Allows farmers and artisans to comply with SAT without the burden of the General Regime.
Special Agricultural Regime
A regime for the livestock, hydrobiological, and beekeeping sectors. Applies to ranchers, fishers (including aquaculture), and beekeepers. Like Special Primary, it’s designed for activities with dynamics different from commerce or services.
What They Can (Optionally) Do Besides Declaraguate
The 4 regimes can, if they choose, use App FEL for suggested returns — a flow where SAT pre-fills the return based on FEL data and the taxpayer just reviews and confirms. Not mandatory. It’s a convenience option for those already invoicing 100% via FEL.
When You WOULD Have to Migrate to Agencia Virtual
Even if you’re in one of the 4 regimes, three scenarios make Agencia Virtual either useful or required:
- If you change regimes. If you voluntarily move from Small Taxpayer to General Regime, you fall into the mandatory September 2026 migration.
- If your activity or income changes and SAT reclassifies you. If you exceed the small-regime threshold, SAT can move you to the General Regime (with or without your application). At that point, you enter the migration.
- If you want to access features only available in Agencia Virtual. Even if you don’t have to migrate filings, many services (digital NIT card download, certificates, RTU updates, FEL invoicing) are in Agencia Virtual. Having a user doesn’t obligate you to migrate returns.
Common Mistakes (Don’t Fall Into These)
I’m a Small Taxpayer. Should I get an Agencia Virtual user anyway?
You’re not required to by the announced migration. But it’s worth having one anyway: many SAT services (digital NIT card, RTU data updates, FEL invoicing) already go through Agencia Virtual even for Small Taxpayers. The user is free and you sign up online with NIT + DPI.
I have a small farm business. Am I in Special Primary, Special Agricultural, or Small Taxpayer?
Regime assignment depends on how you’re registered in the RTU, not on self-perception. Log in to Agencia Virtual or the SAT portal and check your active RTU — it shows your exact regime. If you think your current regime doesn’t fit your real activity, you can request a Tax Regime Change.
My business grew and I’m not sure if I’m still a Small Taxpayer
Each year there are legal income thresholds separating Small Taxpayers from the General Regime. If you exceed the threshold for a sustained period, SAT can reclassify you. Review your total annual income against the current threshold (check with SAT or your accountant). If you’re near the limit, plan the transition to General Regime — and consequently to Agencia Virtual — in advance.
I’m in the fishing sector — am I Special Agricultural?
The Special Agricultural Regime includes hydrobiological activities, which cover fishing and aquaculture. If your main activity is fishing or aquaculture and you’re registered under that regime in your RTU, yes, you’re in Special Agricultural and can keep using Declaraguate.
If You Work With Foreign Currency
Even if you don’t migrate to Agencia Virtual, if you receive USD payments or other foreign currency (agricultural exports, fishing exports, crafts to the U.S., etc.), check the daily USD/GTQ exchange rate — Banguat’s daily-published rate is the official reference.
Related Pages
- Declaraguate Migration Hub — what changes and for whom
- 5 SAT forms leaving Declaraguate — the forms that ARE migrating
- How to register for Agencia Virtual SAT — if you want a user anyway
- Tax Regime Change — if you’re leaving Small Taxpayer
- SAT Guatemala Hub — full directory
- FEL Enrollment — if you don’t yet have FEL active
Official Links
- Declaraguate
- Agencia Virtual SAT
- SAT main portal
- SAT press release of March 11, 2026
- Prensa Libre, May 13, 2026 — 4 regimes that can keep using Declaraguate
Sources Cited
- SAT, official press release of March 11, 2026
- Prensa Libre, May 13, 2026, Glenda Burrión — list of 4 unaffected regimes per SAT