Frequently asked questions (FAQ)

Traceability refers to ensuring (and, where appropriate, detecting) that there are no “gaps” or “leaps” in the sequence of generation of the billing records ( RF ) corresponding to the invoices issued using a specific SIF of a taxpayer ( OT ), as well as that said sequence corresponds to the date and time of generation used. 

This is achieved by “chaining” the RF generated by each SIF of the OT , that is, virtually forming a “chain” because within the data of each RF generated there are certain data (see below, at the bottom of this answer, NOTE 1 ) of the RF generated immediately before (and which, therefore, allow it to be identified), acting as a “pointer” to it. If this chain were altered in any way (break in the sequence of pointers, inconsistent dates and times, etc.), this fact could be detected.

In short, with the implementation of traceability it is possible to know if all the RF generated by a SIF of a OT are available and if they are in the same sequential order in which they were generated.

Finally, it should be noted that non-verifiable invoice issuing systems must also guarantee the traceability of the event records they generate, in a manner equivalent to how they do so for RF .

NOTE 1 : the data involved in the chain can be seen in the corresponding record designs in the order annex, but they are basically the invoice identification (issuer, serial number and invoice number, issue date) to which the previous RF refers and “part” of the fingerprint of the previous RF (currently it is the entire fingerprint).

Regulations/Doctrine:

• Articles 8.2.b) 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 7 of the Ministerial 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.

Billing records ( RF ) must be linked independently within each SIF , and for each OT (in the event that the SIF manages the billing of several OT ). That is, there must exist a single string of RF for each pair of distinct values of ( SIF ; OT ).

Therefore, the answer to this question will depend on how each OT has organized its billing method and the number of OT whose billing is managed in each SIF used.

In relation to 1 (the organization of the billing method by the OT ), for example, if a OT has several POS (in one or several sales centers, or stores) that issue or manage the issuance of their own invoices independently of the rest of the POS, each POS is considered to be a SIF , according to the definition given in the regulation, so it must have its own chain of RF . In this way, the OT will have as many RF chains as POS has.

In relation to 2 (number of OT managed by SIF ), if a SIF allows the management of the billing of several OT (as may be the case of a SIF used by an agency to manage the billing of several OT that are clients of that agency), said SIF must have an independent chain for each OT whose billing it manages.

The answer to this question is derived from the definition and explanation given (see other frequently asked questions in this section) on the concept of traceability, and is that it is limited to the scope of the SIF itself (for each OT , if it allows managing the billing of several OT ). That is, once the SIF implements traceability through the complete and correct linking –and dating– of the RF generated (without forgetting its signature and saving –by the non-verifiable invoice issuing systems– or submission –by the SIF VERI*FACTU– to the Tax Agency), it is already fulfilled and the RF are traceable.

From that moment on, the regulation and the order do not enter into what is done subsequently with the RF generated by the SIF (see below, at the bottom of this answer, NOTE 1 ), beyond requiring its conservation, legibility and accessibility in the future in the case of non-verifiable invoice issuing systems.

Traceability therefore does not refer to the exchange of the RF generated by a SIF with other computer systems, nor to this being traceable.

NOTE 1 : an example of this possibility, very frequent in practice, would be the possible subsequent sending of the RF generated by the SIF to other different computer systems with the idea of using them for different purposes: accounting, management of stocks … Nor would requirements be demanded in this regard for these recipient computer systems (different from the SIF ) to which the RF generated in another SIF arrive.

No. A SIF has a single chain of RF (for each taxpayer it manages, in the event that it manages several within it) in which both types of RF (registration and cancellation) are linked interchangeably, in the same sequential order in which they were generated.

Indeed, they are part of the traceability mechanism of the RF , since these fields should be consistent with the temporal order of generation of the RF that make up the chain of RF of the billing computer system ( SIF ). So this is one of the issues that the SIF should ensure is done correctly.

Furthermore, in the case of non-verifiable invoice issuing systems, the SIF should also be able to detect and report inconsistencies found in this regard in the RF generated that are within its reach.

No. It is common practice for those required to issue invoices ( OEF ) to “change” the numbering of their invoices when the year changes, since they usually include said year within the invoice numbering itself. However, this does not affect traceability in any way. These are two completely independent issues. Traceability would only require that the RF of the first invoice issued in the new fiscal year be correctly linked to the RF of the last invoice issued in the previous year, regardless of the invoice (or serial) number they have.

No. When in a billing computer system ( SIF ), a RF must be generated for the cancellation of an invoice issued improperly (in that SIF or another) or a RF for the correction of certain errors detected in an invoice issued (in that SIF or another), these will be linked to the previous billing record generated by the SIF in which the cancellation or correction operation is being carried out. That is, in terms of traceability, when linking these RF they are treated as one more RF than the SIF in which the operation is carried out.

You must act in the same way as when you detect an error in the integrity and unalterability of some RF (see the equivalent FAQ in the corresponding section).

Finally, remember that only non-verifiable invoice issuing systems are required to be able to detect these errors in the traceability of the RF and event records generated that are within their reach. See in this section the answer to a frequently asked question with more details.

No, non-verifiable invoice issuing systems have more obligations, as they do not send the billing records ( RF ) generated to the Tax Agency, so it is necessary to reinforce the control mechanisms in this regard.

It must be said that both types of SIF , VERI*FACTU systems and non-verifiable invoice issuing systems, have the same obligations in terms of implementing and guaranteeing traceability through the correct linking of the RF (and also, for their part, of the event records in the case of non-verifiable invoice issuing systems). However, from this moment on, the SIF VERI*FACTU no longer have any further obligations related to this requirement.

On the contrary, non-verifiable invoice issuing systems are also required to detect errors (and offer functionalities that allow them to do so) in the chaining of the RF and the generated event records that are within their reach, warning when this circumstance occurs, in addition to generating the corresponding event record.

On the other hand, taxpayers ( OT ) users of non-verifiable invoice issuing systems are also responsible for ensuring the accuracy of the date time with a maximum margin of error of one minute, which does not apply to OT of SIF VERI*FACTU.