Frequently asked questions (FAQ)

Yes, the potential connection of all billing computer systems with the Tax Agency is required by article 8.1 of the RRSIF which establishes:

(…) The computer system must have the capacity to send by electronic means to the tax authorities, in a continuous, secure, correct, complete, automatic, consecutive, instantaneous and reliable manner, all the billing records generated as referred to in articles 9, 10 and 11 of this Regulation.

Therefore, the regulations require that all computer billing systems have the capacity to communicate with the AEAT and, for example, in response to a request from the Tax Agency, they can directly communicate the records required, or adopt the VERI*FACTU mode at any time, with immediate online referral to the AEAT .

Regulations/Doctrine:

Article 8.1 of the regulation establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats ( RRSIF ), approved by Royal Decree 1007/2023, of December 5.

The type of electronic signature to be used by software developers to fulfill the obligation to sign the invoice registration or cancellation files may be different from those used by the AEAT , provided that it is a qualified signature and serves the purpose of authenticating and making immutable the content of the registration billing record.

If all the aforementioned computer systems (both the central one and the one at the "disconnected" headquarters) independently issue invoices, each with its QR included, both systems will be considered independent billing computer systems ( SIF ), according to article 1.2 of the regulation approved by RD 1007/2023, of December 5 ( RRSIF ) and, therefore, each of them must separately comply with said RRSIF .

Thus, each of both SIF , at the same time that they issue each invoice, must generate their corresponding high billing record (RF). These Billing Records must be linked (with the corresponding hash) independently within each SIF , respecting the sequence of their generation, that is, according to the order in which they were generated in each of them. Therefore, to issue their own invoices (and generate the corresponding associated Billing Records, in a chained manner) they do not have to - or need to - know what invoices other SIF of the same company or business are issuing, since they are independent for these purposes and do not need to be "connected or communicated" with each other.

Yes, since both SIF can comply with the standard in different modalities. However, it is noted that this is not the preferred option as it will generate incomplete lists of issued invoices in the records available in the electronic headquarters of the AEAT , which will need to be completed by means of requests.

No, this subsequent transfer is not, strictly speaking, an invoice, since the clients will have already taken the printed invoices and, therefore, this “delayed” transfer is not possible.

A SIF that complies with the regulations and the order should ensure that such circumstances do not occur or that it is able to adequately recover from them and continue to comply with the regulations and the order, by establishing the necessary measures and procedures to do so.

It means that the SIF must have a different way of accessing the functionalities and data with tax relevance required by the regulation, so that the confidentiality of other different data is preserved and they cannot be improperly accessed through that means. This is especially anticipated in the event that a member of the Tax Agency appears to inspect the SIF on site, always complying with the procedures established in this regard.