What Colombia’s New Compliance Rule Is Telling You About Your Receivables
There’s a question few companies ask themselves until it’s too late: when was the last time we checked whether our clients are still the same companies they were when we opened their credit line?
We’re not talking about whether they pay on time. We’re talking about whether the company that owes you money today is still the same company you sold to two or three years ago.
In many cases, it isn’t. And now, on top of being a financial risk, it’s also a legal one.
A rule that’s here to stay
On July 2, 2026, Colombia’s Superintendence of Companies (Superintendencia de Sociedades) issued External Circular 100-000020, introducing Chapter IX: a unified framework that merges SAGRILAFT (the anti-money-laundering system) and the Business Transparency and Ethics Program (PTEE) into a single body of rules, and adds the management of corruption and transnational bribery risk.
The most important change isn’t the name. It’s the approach. The rule expressly rejects paper compliance —having a nice policy filed away— and requires the system to be real, active and demonstrable. Having the manual isn’t enough. You have to be able to prove when, how and with what supporting evidence it was applied each time.
And here’s the point that connects compliance to your receivables: Chapter IX demands, for anti-money-laundering reasons, exactly the same discipline your collections team already needed for financial reasons.
Who does it apply to?
The rule takes effect on December 31, 2026. Broadly, it applies to companies supervised by the Superintendence of Companies with assets or revenue above COP 59,690 million (roughly COP 59.7 billion). But there is a second regime —the minimum measures regime— which kicks in at revenue of roughly COP 4,477 million and covers sectors such as legal services, real estate, construction, pharmaceuticals and manufacturing.
Minimum measures does not mean no compliance. It requires an internal officer in charge, a risk policy, a counterparty due-diligence procedure, a reporting channel and documentary evidence. It is a real standard —verifiable and enforceable.
What happens while your credit file gets older
An outdated credit assessment isn’t just an old document. It’s an X-ray of a company that no longer exists.
While the file sits in a cabinet, the debtor keeps moving. It changes shareholders —and Chapter IX now defines and requires you to identify the ultimate beneficial owner, the individual who actually controls the business. It shifts operations to a brand-new legal entity. It accumulates losses that show up in its financial statements while no one is looking. Or it enters insolvency proceedings that suspend your collection efforts and turn your claim into one more line on a list of creditors.
In 2025, insolvency filings in Colombia reached 18,726 —76% more than in 2024. Projections for 2026 exceed 26,000 cases. Thousands of companies that show up as “good payers” in your database are already in proceedings that will stop them from paying. And you don’t know it, because the credit file you have is years old.
What Chapter IX requires —and what your receivables need anyway
The rule establishes that due diligence on each counterparty must be updated at least once a year for high-risk profiles, and every two years for medium- or low-risk profiles. With immediate updating whenever a red flag appears: arrears beyond 30 days, a change of legal representative, payments from third parties, a credit-line increase requested without justification.
That is exactly what a sound receivables process should be doing —and what, in practice, few companies do systematically.
What needs reviewing isn’t just whether the client pays. It’s whether it has active enforcement proceedings in the courts, whether it appears in insolvency filings before the Superintendence, whether its ownership structure has changed, whether its collateral is still valid and whether the promissory note is properly drafted. That information exists and is public. The problem is that nobody is looking for it —until the client stops paying and there are no assets left to pursue.
The time to act is before, not after
A company that detects a client’s deterioration three months in advance has options: renegotiate terms, demand additional collateral, reduce the credit line, or start collection while there are still assets to attach.
A company that finds out once the client is already in insolvency has very few.
The deadlines look generous —companies already complying have until May 2027 to adjust. They aren’t. Cleaning up a database of hundreds of clients, segmenting them by risk, updating contracts and collateral, appointing a compliance officer and reporting it to the Superintendence within 15 business days: all of that takes months. And every month that passes is another month of open credit lines to debtors whose real profile you don’t know.
At Trébol Jurídico, we do it differently
Before starting any collection effort, we audit the debtor’s profile. At Trébol Jurídico we run credit assessments, restricted-list screening and asset searches covering court proceedings, the status of the commercial registry and red flags —because we’ve learned, case by case, that the hardest receivable to recover isn’t the one owed by an unwilling debtor. It’s the one owed by a debtor nobody knew anything about until they stopped paying.
