Frequently asked questions (FAQ)

In which the billing computer system (SIF) automatically detects and collects, at the time they occur, certain interactions with said computer system, operations carried out with it or events that occur during its use, saving the data corresponding to each of them, which must be able to be consulted from the SIF itself.

This event log is only mandatory in the case of non-verifiable invoice issuing systems, and is not necessary in the case of SIF « VERI*FACTU ».

Regulations/Doctrine:

• Article 8.3 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 regulations in this regard require that computerized billing systems (SIF) guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of the records, without interpolations, omissions or alterations that are not duly recorded in the systems themselves.

The immediate submission to the Tax Agency of the billing records generated by the SIF VERI*FACTU decisively contributes to complying with these requirements. However, this does not occur in the case of non-verifiable invoice issuing systems, so it is then necessary to adopt an additional security and control measure consisting of non-verifiable invoice issuing systems recording in an unalterable manner those circumstances – and their main characteristics – that may help to subsequently identify any possible anomaly or alteration related to any of the aforementioned requirements.

Regulations/Doctrine:

• Article 29.2.j) of Law 58/2003, of December 17, General Tax Law.

• Article 8.3 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.

At least the following event records exist:

1. Start of operation of the computer system as "NO VERI*FACTU ".

2. End of operation of the computer system as "NO VERI*FACTU ".

3. Launch of the process for detecting anomalies in billing records.

4. Detection of anomalies in the integrity, unalterability and traceability of billing records.

5. Launch of the anomaly detection process in the event logs.

6. Detection of anomalies in the integrity, immutability and traceability of event records.

7. Backup restoration, when this is managed from the billing computer system itself.

8. Exporting billing records generated in a period.

9. Exporting event logs generated in a period.

In addition to the above, there is an additional event record, which is the summary record of events that occurred in a certain period (since the previous event summary record was generated, or since the start of operation of the computer system according to the Regulation if no previous event summary record has yet been generated). This event summary log will be recorded every 6 hours that the SIF has been operational and available for use, as well as before it is shut down or powered off.

Finally, the producer (manufacturer) of SIF could voluntarily record other events that it considers of interest in this regard.

Regulations/Doctrine:

• Article 8.3 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.

• Articles 9.1 and 9.2 of the order developing the technical, functional and content specifications referred to in the regulation establishing the requirements to be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

In the mentioned case, the SIF must register the events independently for each OEF , as if they were different SIF . Ultimately, there will be as many as OEF .

Regulations/Doctrine:

• Articles 7.a) and 8.3 of the regulation that establishes the requirements that must be adopted by the 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.

• Article 2.a) of the order developing the technical, functional and content specifications referred to in the regulation establishing the requirements to be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

In general, the same requirements as those required for billing records, that is, event records must be made in such a way that their characteristics of integrity, inalterability, traceability, conservation, accessibility and legibility are guaranteed, as required for billing records, analogously complying with the specifications indicated for the latter.

For more details on these features and requirements, we recommend consulting the frequently asked questions included in the corresponding sections.

Regulations/Doctrine:

• Article 8.3 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.

• Article 9.3 of the order developing the technical, functional and content specifications referred to in the regulation establishing the requirements to be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

Yes. The billing computer system (SIF) must electronically sign all event records it generates, analogously complying with the specifications given in this regard for billing records.

Regulations/Doctrine:

• Article 8.3 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.

• Article 9.3 of the order developing the technical, functional and content specifications referred to in the regulation establishing the requirements to be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

The period of time during which the generated event records must be kept coincides with that which applies to billing records generated in the same time period (see the corresponding section for the equivalent FAQ ).

As for the responsibility for its conservation, it is also the same as in the case of billing records (see in the corresponding section the equivalent frequently asked question ).

Regulations/Doctrine:

• Article 8.3 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.

• Article 9.3 of the order developing the technical, functional and content specifications referred to in the regulation establishing the requirements to be adopted by the computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

No, unless the Tax Agency requires you to send them.

Regulations/Doctrine:

• Article 8.3 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.