General issues

Description of the scope of application of the regulations, characteristics and requirements of the Billing Computer Systems.

The Regulation governing the requirements for Billing Computer Systems (RRSIF), approved by RD 1007/2023, of December 5, also known as the VERI*FACTU Regulation, has the following main characteristics:

No material alteration of obligations

It does not materially alter the substantive billing obligations, which will continue to be governed by the provisions of tax regulations, especially Law 37/1992, of December 28, on Value Added Tax, its Regulations approved by Royal Decree 1624/1992, of December 29, and by the Regulations on Billing Obligations (ROF), approved by Royal Decree 1619/2012. Therefore:

• Operations that, according to the regulations, should not be invoiced will not be subject to this regulation, without prejudice to the fact that the requirements may be voluntarily assumed by any taxpayer.

• Special authorizations issued for billing purposes by the Tax Agency's Management Department remain valid.

However, the regulation has introduced a small modification in the billing obligations of persons and entities that fall within its subjective scope (arts. 5 and 6 of the ROF). It consists of incorporating a QR code and, where appropriate, a “verifiable invoice” or VERI*FACTU legend into the invoices and simplified invoices issued.

Objectives of regulation

Its purpose is to regulate how computerized billing systems (SIF) should operate to ensure compliance with the requirements established in article 29.2.j) LGT in such a way as to guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of the billing records, without interpolations, omissions or alterations for which the proper annotation is not left in the systems themselves.

Billing Records

The standard aims to ensure the standardization and readability of the records produced by billing systems, for which purpose both the “Invoicing registration record” and the “Invoicing cancellation record” are regulated. The content of both records, which is detailed in the Regulation and whose technical specification is found in the Annex of the OM, is based on the mandatory billing information (mentioned in article 6 of the ROF) to which certain security data are added, the identity of the System and the date and time of its production.

Billing Records do not contain all invoice information and are not electronic invoices under any circumstances. The invoice itself may contain additional information not included in the mandatory register, provided that the content of the latter is not altered. Likewise, both the issuance of paper invoices and the issuance of structured electronic invoices are permitted, without either being altered by the mandatory production of the “High Billing Record”.

All billing records are structured with a unique record format and layout and must observe a security specification consisting of the generation of a Hash code for whose production parts of the immediately preceding billing record are taken.

Compliance modalities

There are two valid methods for complying with the regulations: the VERI*FACTU method and the method of keeping the billing records in the issuing system (NO VERI*FACTU method). In addition, for those small operators who do not need to have a computerized billing system, the Tax Agency will make available to them on the Electronic Headquarters of the AEAT a form in which they can prepare their invoices, also generating records adapted to the regulations. This application will be VERI*FACTU type.

Additional safety features

Security elements, for those systems that are not of the VERI*FACTU type, in addition to the aforementioned “Hash” will include the electronic signature of the records made by the issuing system thereof. For the entire system, they must also have a system “event log” maintained with security requirements similar to those applying to billing records.

Ability to export logs

All computerized billing systems produced and marketed must have the capacity to export and transmit billing records online. When the chosen modality is NO VERI* FACTU, in the event that said records are required by the Tax Administration, they may be sent directly through a simplified and automated procedure.

QR and verifiable and non-verifiable invoices

Since the entry into force of the SIF requirements regulations for those required to issue invoices (OEF), all invoices, whether complete or simplified, must include a QR code. This code contains certain invoice information and a URL to the tax agency's headquarters.

Depending on the compliance method adopted, the QR code will serve either to validate the content of the invoice received for tax purposes (in the case of verifiable invoice systems or VERI*FACTU), or to communicate it to the tax authorities (in the case of non-verifiable invoice systems or NO VERI*FACTU).

In order to obtain maximum security in the verification process, it is advisable to use the Tax Agency's APP for this purpose.

Tax services

In relation to the RRSIF Regulation, the AEAT will provide the following services.

1. Simplified billing application, which will be supported by the AEAT electronic office through a form, for the fulfillment of the obligations of those small businesses that, due to the small number of invoices issued, do not have their own SIF. This application requires the introduction of invoice information and the system returns a printable invoice with QR, in addition to keeping the invoice registration record in the Electronic Office in VERI*FACTU mode.

   Limitations of the use of this system are:

   1. Since it requires complete identification of the client, it only accepts complete invoices and cannot be used for simplified invoices.

   2. Does not support invoices with multiple recipients.

2. List of invoices sent to the Electronic Office. At any time, users issuing invoices, who have used the VERI*FACTU method, will be able to access the list of their issued invoice records available in the Electronic Office. Likewise, they will also be able to access the list of billing records received when the issuer of the invoices has in turn used the VERI*FACTU method.

   Access to this list facilitates the preparation of self-assessments, as well as the Book of Records of Issued Invoices.