4. Computer billing systems

Royal Decree 254/2025, of April 1, introduces the following amendments to the Regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support invoicing processes:

• To clarify the exclusion of the RRSIF For those transactions that, based on the Regulation governing invoicing obligations, should not be documented in an invoice, the mention of the particular case of operations covered by the special regime for agriculture, livestock and fishing, simplified regime and equivalence surcharge is eliminated.

• Transactions documented by invoices issued by the recipient of the transaction, or by a third party as a result of the application of mandatory regulatory provisions, are excluded when they are included in the Immediate Provision of Information.

• A new entry into force of the Regulation is regulated:

  • Taxpayers subject to Corporate Income Tax will have their computer systems adapted to the characteristics and requirements established in the aforementioned Regulation and its implementing regulations before January 1, 2026.

  • The remaining taxpayers referred to in Article 3.1 must have operational computer systems adapted to the characteristics and requirements established in the aforementioned Regulation and its implementing regulations before July 1, 2026.

  • Producers and marketers of systems must offer their products adapted to it within a maximum period of 9 months from the entry into force of the Order. HAC/1177/2024, of October 17 (July 29, 2025). However, with regard to IT systems included in multi-year maintenance contracts contracted before this deadline, they must be adapted to the content of the Regulation before the dates indicated in the previous points.