The Superintendency of Companies issued External Circulars 100-000019 and 100-000020 of 2026, adopting a new Basic Legal Circular and adding new chapters to the Basic Accounting Circular. These changes strengthen and modernize the regulatory framework applicable to entities subject to the inspection, oversight and control of this authority.
Main changes in the new Basic Legal Circular
Among the main changes introduced by External Circular 100-000020 of 2026, the following stand out:
- The expansion of its scope of application.
- The creation of a Self-Control and Risk Management System for ML/TF/PF and C/TB, which brings together under a single system the obligations previously contained in the SAGRILAFT and the Business Transparency and Ethics Program (PTEE), also incorporating the risks of Local Corruption and Transnational Bribery (C/TB).
- The strengthening of the requirements applicable to Compliance Officers.
- The update of the rules relating to corporate governance, the duties of directors and officers, conflicts of interest and meetings of corporate bodies.
- The expansion of the scope of application to new subjects, including chambers of commerce, agents and foreign non-profit entities with permanent business in Colombia.
According to the Superintendency of Companies, the new Basic Legal Circular seeks to consolidate a modern, preventive and risk-based supervision model, aimed at strengthening transparency, business management and good corporate governance.
Update to the Basic Accounting Circular
External Circular 100-000019 of 2026 adds chapters V, VI and VII to the Basic Accounting Circular.
The new chapters develop matters relating to:
- Special regimes.
- Insolvency regime.
- Voluntary liquidation.
These additions seek to strengthen the quality and transparency of the financial information reported by supervised entities, aligning the technical criteria with the International Financial Reporting Standards (IFRS).
What does it mean for companies?
These changes seek to strengthen business transparency, risk management, corporate governance and the quality of financial information.
Consequently, supervised entities must review their processes, policies and internal controls in order to identify the necessary adjustments and ensure compliance with the new provisions.
From a business perspective, the issuance of these circulars represents a step toward a more modern, technical and preventive supervision model, providing greater tools and guidance for the proper management of risks and compliance with legal obligations. In this context, it is essential that companies assess the impact of these new circulars and promptly adopt the measures necessary to ensure their proper implementation.