Frequently asked questions (FAQ)

There are 2 types of affected groups:

1. The producers and marketers of computerized billing systems (SIF) in matters relating to their respective production and marketing activities of computer systems intended to be used by the group mentioned below in the following section.

2. Those businessmen and professionals – natural or legal persons – who, being established in Spanish territory, issue invoices (see explanatory NOTE 1 at the end of this answer), provided that they comply with the following 4 conditions (what could be called the “rule of the 4 “NOs””):

   1. That DO NOT invoice exclusively manually (without the help of SIF). In other words, they use some SIF to issue invoices.

   2. That NOT are subscribed, either mandatorily or voluntarily, to the requirements of the so-called Immediate Supply of Information or SII. See explanatory NOTE 2 at the end of this answer.

   3. That NOT have their tax domicile in the Historical Territories of the Autonomous Community of the Basque Country or the Foral Community of Navarra. See further clarification in NOTE 3 at the end of this answer.

   4. That DOES NOT have any non-application resolution in force that exempts them from complying with the RRSIF, approved by Royal Decree 1007/2023, of December 5. See explanatory NOTE 4 at the end of this answer.

NOTE 1 to section 2 of this answer :

As can be seen, in this second section, reference is made at all times to those who issue INVOICES – including simplified invoices – whatever the reason for doing so (normally because they are required to do so under Royal Decree 1619/2012, of November 30, which approves the Regulation governing billing obligations, ROF). Thus, in this regard, all those operations that are not documented with an invoice are excluded because there is no obligation to issue an invoice according to said RD 1619/2012 and ROF (including the "special" authorizations granted that may exist in this regard).

Therefore, whether or not an invoice is issued is key because, by definition (article 1.2 of the RRSIF), the RRSIF does not change the substantial billing obligations. A SIF –whose operation is regulated by the regulations– is, in essence, a computer system used to issue INVOICES. So the RRSIF does not apply to computer systems that do not issue invoices.

NOTE 2 to letter b) of section 2 of this answer :

The SII refers to the maintenance of VAT record books in the electronic headquarters of the Tax Agency in accordance with the terms established in section 6 of article 62 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29.

If a taxpayer is covered by the SII, he/she must use a System that allows him/her to comply with the SII's information requirements.

NOTE 3 to letter c) of section 2 of this answer :

Letter c) of section 2 refers to the fact that the tax levying authority based on the domicile of the person issuing the invoice is NOT specific to the Historical Territories of the Autonomous Community of the Basque Country or the Foral Community of Navarre, in accordance with the rules of the Economic Agreement and Convention. That is, those who carry out economic activities (whether they are individuals or legal entities) that are subject to the local regulations on Direct Taxation due to said activities are NOT taxable persons, both in the case of the 3 historical territories of the Autonomous Community of the Basque Country (Law 12/2002, of May 23, approving the Economic Agreement with the Autonomous Community of the Basque Country, and, specifically, as established in articles 6 and 14 of said text, respectively, for Personal Income Tax and Corporate Tax), as in the case of the Foral Community of Navarre (Law 28/1990, of December 26, approving the Economic Agreement between the State and the Foral Community of Navarre, and, specifically, as established in articles 9 and 18 of said text, respectively, for Personal Income Tax and Corporate Tax). In accordance with the aforementioned existing regulations on this matter and according to the application conditions given in the RRSIF, this circumstance is determined based on the tax domicile of the same.

Finally, to avoid any doubts regarding this aspect, it is confirmed that those obliged to issue invoices based in the Canary Islands, Ceuta or Melilla are subject to the application of the regulation (at least as regards this criterion), understanding that the references to the Value Added Tax (VAT) should be considered to be made to the Canary Islands General Indirect Tax (IGIC) and the Tax on Production, Services and Importation (IPSI), respectively.

NOTE 4 to letter d) of section 2 of this answer :

It refers to the possibility specifically provided for in Article 5 of the RRSIF.

Regulations/Doctrine:

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

• Articles 1, 3, 4 and 5 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 (RRSIF), and the standardization of formats of billing records, approved by Royal Decree 1007/2023, of December 5.

• Royal Decree 1619/2012, of November 30, approving the regulations governing billing obligations (ROF).

• Article 62.6 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29.

This varies depending on the affected group in question:

• Taxpayers subject to Corporation Tax must have their computer systems adapted to the characteristics and requirements established in the regulations on the requirements that computer or electronic systems and programs supporting the invoicing processes of businesses and professionals must adopt and in its implementing regulations before 1 January 2027.

• The remaining taxpayers mentioned 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, 2027.

• Producers and marketers of those SIFs to which the regulation applies, in relation to their production and marketing activities of said SIFs, must offer their products fully adapted to the regulation within a maximum period of nine months from the entry into force of the ministerial order (July 29, 2025) that develops the technical specifications of the requirements imposed on the SIFs. However, with regard to SIFs included in multi-year maintenance contracts entered into before this latter deadline, they must be adapted to the content of the regulation before the dates indicated in the preceding paragraphs.

Regulations/Doctrine:

• Final Provision Four of Royal Decree 1007/2023, of December 5, which approves the regulation that establishes the requirements that must be adopted by the computer or electronic systems and programs that support the invoicing processes of businessmen and professionals, and the standardization of formats of the invoicing records (RRSIF), modified by Royal Decree-Law 15/2025, of December 2.

No, as long as no invoices are issued or they are ALL issued by hand, that is, without using a computerized billing system (SIF).

On the other hand, if at any time an invoice were issued – for whatever reason – and a SIF were used for this, then the RRSIF would be applicable (provided that the rest of the conditions indicated in section 2 of the frequently asked question "Who is affected by the regulation that establishes the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application .

It is important to remember that the RRSIF only applies to SIFs and these, by definition (article 1.2 of the RRSIF), are only considered as such if they are used to issue what –according to the ROF– is considered an INVOICE, including the simplified invoice (article 1.2 of the RRSIF) but not other similar or “equivalent” documents that also justify operations.

Regulations/Doctrine:

• Article 2.j) of Law 58/2003, of December 17, General Tax (LGT).

• Articles 1, 3, 4 and 5 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.

• Royal Decree 1619/2012, of November 30, approving the regulations governing billing obligations (ROF).

The subjective scope of the SIF Regulation approved by RD 1007/2023 does not include those persons who carry out economic activities (whether natural or legal persons) who are subject to the regional regulations on direct taxation due to said activities.

To determine which entrepreneurs and professionals are subject to regional regulations, the rules of Law 12/2002, of May 23, approving the Economic Agreement with the Autonomous Community of the Basque Country, will be followed, and, specifically, the provisions of articles 6 and 14 of said text, respectively, for Personal Income Tax and Corporate Tax.

In the historical territories of Guipúzcoa, Vizcaya and Álava, a system known as “TicketBAI” is being applied in its different content modalities similar to the VERI*FACTU modality of the Regulation of Computerized Billing Systems.

For example, in the event that a company with a registered office in the province and another with a registered office in common territory (rest of Spain) have a commercial relationship, the SIFs used by the former to issue its invoices will be subject to the obligations established by its corresponding Provincial Treasury, while the SIFs of the latter would be subject to the RRSIF.

Regulations/Doctrine:

• Article 1.3 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.

As a general rule, in the Foral Community of Navarra, RD 1007/2023, of December 5, which approves the Regulation governing computer billing systems, will not be applicable when entrepreneurs and professionals are subject to foral regulations in accordance with the rules of Law 28/1990, of December 26, which approves the Economic Agreement between the State and the Foral Community of Navarra, and, specifically, in accordance with the provisions of articles 9 and 18 of said text, respectively, for Personal Income Tax and Corporate Tax.

No.

Companies subject to the regional obligations of immediate information supply (SII (foral), when they materially issue invoices as recipients (self-invoicing), in the name and on behalf of suppliers residing in the common territory, they will not have to comply with the RRSIF for said operations (neither sending billing records to VERI*FACTU, nor keeping the generated billing records available).

The exclusion of art. 4.3 RRSIF (invoices issued physically by a recipient residing in the common territory and registered with the SII) is applicable when the recipient of the operation has their tax domicile in the Historical Territories of the Autonomous Community of the Basque Country or the Chartered Community of Navarre and is attached to the SII of said chartered territory.

Applicable regulations:

Article 4.3 of RRSIF (Regulation establishing the requirements for computer billing systems), as amended by Royal Decree 254/2025, of April 1.

Yes.

Companies Noattached to the regional obligations of immediate supply of information (SII (foral), when they materially issue invoices as recipients (self-invoicing), in the name and on behalf of suppliers residing in the common territory, they must comply with the RRSIF for said operations (sending billing records to VERI*FACTU or keeping the generated billing records available).

Yes, taxpayers with tax domicile in the Canary Islands, Ceuta and Melilla are included within the subjective scope of application of the SIF Regulation approved by Royal Decree 1007/2023 and, consequently, said regulations and those developed by Ministerial Order apply to them.

In accordance with article 1.3, the references made by the SIF Regulation to the regulations on Value Added Tax will also be considered to be made to the regulations on the Canary Islands General Indirect Tax and to the Tax on Production, Services and Importation in Ceuta and Melilla.

Yes, provided that you also meet the other conditions indicated in section 2 of the FAQ "Who is affected by the regulation establishing the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application .

Royal Decree 1007/2023, of December 5, and the regulations on requirements for computer billing systems (RRSIF) that it approves are applicable throughout non-regional Spanish territory, taking into account the specialties provided for in its specific regulations for the Canary Islands, Ceuta and Melilla, understanding that the references made to the regulations of the Value Added Tax (VAT) must also be considered to be made to the regulations of the Canary Islands General Indirect Tax (IGIC) and the Tax on Production, Services and Importation (IPSI), respectively.

Regulations/Doctrine:

• Article 1.3 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.

Yes.

Within the same taxpayer there are two taxpayers (in their consideration as legal persons in the territory of application of the tax) VAT and of permanent establishment in the territory where the tax applies IGIC) for the purposes of applying the exclusion of subjects assigned to the provision of immediate information (SII) of art.3.3 RRSIF (Regulations establishing the requirements for computerized billing systems). The exclusion must be analyzed separately for each of the two indirect taxes and, therefore, in relation to their respective SII (VAT either IGIC), without the exclusion of RRSIF by SII in VAT implies the exclusion of RSIF for billing by SII IGIC.

Article 3.3 RRSIF It refers to taxpayers, relating it to an article of the RIVA, art.62.6 (registries SII), therefore the relevant concept for the purposes of exclusion is the taxpayer that appears with respect to each of these taxes.

Consequently, if the exclusion from the application of RRSIF derives from the affiliation to SII in relation to the VAT, for the operations carried out by the Canary Islands establishment, which is not affiliated with the SII - VAT nor to SII - IGIC the aforementioned exclusion does not apply and these operations must comply with the regulations derived from RRSIF.

No.

Within the same taxpayer there are two taxpayers (in their consideration as legal persons in the territory of application of the tax) VAT and of permanent establishment in the territory where the tax applies IGIC) for the purposes of applying the exclusion of subjects assigned to the provision of immediate information (SII) of art.3.3 RRSIF (Regulations establishing the requirements for computerized billing systems). The exclusion must be analyzed separately for each of the two indirect taxes and, therefore, in relation to their respective SII (VAT either IGIC), without the exclusion of RRSIF by SII in VAT implies the exclusion of RSIF for billing by SII IGIC.

Article 3.3 RRSIF It refers to taxpayers, relating it to an article of the RIVA, art.62.6 (registries SII), therefore the relevant concept for the purposes of exclusion is the taxpayer that appears with respect to each of these taxes.

For its part, Article 1 of RRSIF It stipulates that the Regulation is applicable throughout the Spanish territory, taking into account the special provisions set out in its specific regulations for the Canary Islands, Ceuta and Melilla; and that the references made by the Regulation to the regulations of VAT They will also be considered as having been made in accordance with the regulations of IGIC already the one of IPSI in Ceuta and Melilla.

Consequently, in the case of a taxpayer assigned to the SII - VAT, but with a permanent establishment in the Canary Islands, when the operations of the establishment in the Canary Islands are declared to SII - IGIC (by mandatory or voluntary affiliation)), the exclusion from the application of the Regulation RRSIF It will apply to operations carried out within the territory where the tax applies. VAT, such as those carried out in the Canary Islands.

Regarding personal income tax, it is necessary to determine whether the lease constitutes an economic activity or, on the contrary, is a source of income from real estate capital. To be considered an economic activity, it is required that at least one person be employed with a full-time employment contract.

Therefore, if the activity is not considered a business activity, it will not be an economic activity within the meaning of article 3.1.b) RRSIF, and in that case the lessor will not have to adapt because no economic activity is being carried out.

However, if the apartment is rented as a tourist property and complementary services are offered, typical of the hotel industry, the income obtained from the rental is income from economic activities. Therefore, invoices issued in this context must be understood to fall within the scope of Royal Decree 1007/2023, which approves the Regulation governing Computerized Billing Systems (RRSIF).

Regulations/Doctrine:

• Article 3.1 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.

No.

The taxpayers of PIT that carry out economic activities and use computerized billing systems (SIF), even if only in part of their activity, must use a SIF adapted to RRSIF (Regulations establishing the requirements for computer billing systems), for all economic activities for which an invoice must be issued.

However, if the rental activity is carried out without having any person employed full-time with an employment contract, it is not considered to be an economic activity for the purposes of PITTherefore, it does not apply to him. RRSIF to the invoices that must be issued for the rental. Without prejudice to the fact that, for convenience, you may voluntarily issue these invoices using the SIF.

Yes.

Article 3 of RRSIF It specifically regulates the subjective scope of the rule and includes all taxpayers of the Corporate Income Tax, without making distinction based on the type of activity they carry out.

These are different regulations with different obligations. The SII consists of keeping VAT record books (invoices issued, invoices received, investment goods, etc.) through the electronic headquarters of the Tax Agency, which implies obligations to electronically communicate to the Tax Agency a wide range of information related to the VAT of invoices issued and received within a certain period of time. For its part, the regulation that establishes the requirements for computerized billing systems requires SIFs to record, with certain security and control measures, certain information only on invoices issued, which may optionally be sent to the Tax Agency.

The subjective scope of both projects is exclusive, that is, those who comply with the SII do not have to comply with the regulations that establish the requirements for computerized billing systems and vice versa.

Therefore, in accordance with article 3.3 of the Regulation approved by RD 1007/2023, this Regulation does NOT oblige taxpayers subject to the Immediate Supply of Information (SII) in relation to their own invoices.

Regulations/Doctrine:

• Article 3.3 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.

• Order HFP/417/2017, of May 12, regulating the normative and technical specifications that develop the maintenance of the Value Added Tax registration books through the electronic headquarters of the State Tax Administration Agency established in article 62.6 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29, and other tax regulations are modified.

Yes, through the option provided for in the census declaration model 036, a taxpayer who has registered with REDEME or who has directly voluntarily opted for the SII would not be obliged to comply with the specifications of RD 1007/2023, without prejudice to assuming from the immediately following settlement period all the obligations arising from article 62.6 of the RIVA on their issued and received invoices.

Regulations/Doctrine:

• Article 3.3 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.

No.

The subjective scope of both projects is exclusiveThat is, those who comply with the SII do not have to comply with the RRSIF (Regulation that establishes the requirements of the computer systems of invoicing) and vice versa. They are different rules and obligations.

If a company were required to register with the SII due to its volume of operations, must stop sending billing records to Veri*factu and stop include the QR code tax information on invoices from the moment you begin to comply with the SII effectively, without having to wait until the end of the current calendar year.

Pursuant to Article 3.3 of the RRSIF, this Regulation does not oblige taxpayers subject to the SII referred to in Article 62.6 of Royal Decree 1624/1992, of December 29, which approves the VAT Regulation, in relation to their own invoices.

No.

The subjective scope of both projects is exclusiveThat is, those who comply with the SII they do not have to comply with the RRSIF (Regulations that establish the requirements for computer billing systems) and vice versa. They are different rules and obligations.

If a company were required to join the SII due to its volume of operations, You must stop including the QR code tax on invoices from the moment you begin to comply with the SII effectively, without having to wait until the end of the current calendar year. In this case, since there is no submission of records and no tax QR code is printed, nothing would prevent its use voluntarily a SIF adapted to SII that also meets the other requirements of RRSIFThat is, generate a billing record, using the chained hash, signing the invoices and keeping them. 

In accordance with article 3.3 of RRSIFThis Regulation does not bind taxpayers subject to SII referred to in Article 62.6 of Royal Decree 1624/1992, of December 29, which approves the Regulation of VAT, in relation to their own invoices.

Not in general, since those subject to this regime are not required to issue an invoice except in certain exceptions.

However, the answer is the opposite, provided that they use a computerized billing system, when they issue other mandatory invoices for the delivery of real estate referred to in the second paragraph of section one of article 129 of Law 37/1992, of December 28, on Value Added Tax, as indicated in the last paragraph of article 3.3 of the ROF, and provided that they also comply with the rest of the conditions indicated in section 2 of the frequently asked question "Who is affected by the regulation that establishes the requirements for computerized billing systems?" (rule of the 4 "NOs") of General questions: areas of application . For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

Likewise, you will also be required to comply with the RRSIF when using a computerized invoicing system for the voluntary issuance of invoices for operations exempt from the obligation to issue invoices.

Regulations/Doctrine:

• Articles 3.3 and 16.1 of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

• Article 129.1 of Law 37/1992, of December 28, on Value Added Tax.

Not in general, since those subject to this regime are not required to issue an invoice, except in certain exceptions.

However, you will be required to comply with the RRSIF when you use a computerized invoicing system for the voluntary issuance of invoices for transactions exempt from the obligation to issue invoices.

You must also comply with the regulations that establish the requirements for computerized invoicing systems if you issue invoices, provided you also meet the other conditions indicated ("the 4 "NO" rule). According to the billing regulations, under the equivalence surcharge regime, invoices must be issued for carrying out certain operations:

• When you make deliveries of properties subject to and not exempt from VAT.

• When paying taxes in IROF by direct assessment.

• When the client is a businessman or professional or a Public Administration.

• When the recipient requires it to exercise any right of a tax nature.

• When required for certain foreign trade operations.

For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

Regulations/Doctrine:

• Article 3.1.b) of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

Not in general, since those subject to this regime are not required to issue an invoice, except in certain exceptions.

However, you will be required to comply with the RRSIF when you use a computerized invoicing system for the voluntary issuance of invoices for transactions exempt from the obligation to issue invoices.

You must also comply with the RRSIF obligations if you issue invoices, provided you also meet the other conditions indicated ("the 4 "NO" rule). According to the invoicing regulations, under the simplified VAT regime, invoices must be issued for carrying out certain operations:

• When the determination of the accrued quotas is made based on the volume of income,

• When making the sale of fixed assets,

• When the client is a businessman or professional or a Public Administration.

• When the recipient requires it to exercise any right of a tax nature.

• When required for certain foreign trade operations.

For these exceptional operations, they may use the system provided for this purpose by the AEAT in its electronic headquarters, in accordance with article 7.b) of the RRSIF.

For more details, please consult

Regulations/Doctrine:

• Article 3.1.c) of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.

• Article 123.One.B).3.º of Law 37/1992, of December 28, on Value Added Tax.

Taxpayers under the agricultural, livestock, and fishing, simplified, and equivalent surcharge regimes are, in general, exempt from the obligation to issue invoices or simplified invoices. However, this rule has exceptions set out in articles 3.1 and 26 of the Billing Obligations Regulation (RD 1619/2012). The aforementioned regulations regarding the obligation to issue invoices or simplified invoices are part of the regulations contained in the Regulation Governing Computerized Billing Systems (RRSIF), approved by Royal Decree 1007/2023 of December 5.

However, business practice often requires the issuance of sales receipts, which may or may not take the form of simplified invoices. These invoices, strictly speaking, are not prohibited by law and can be issued voluntarily, as the regulations limit themselves to not requiring the obligation to issue invoices in certain cases. Such supporting documents, to the extent that they are not full or simplified invoices, issued in the context of transactions excluded from the invoicing obligation, will not be subject to the RRSIF.

Therefore, it should be understood that whatever the reason a business issues invoices or simplified invoices using a Computerized Invoicing System (SIF), they must adapt their systems to the regulations derived from Royal Decree 1007/23 and its implementing OM.

On the other hand, if, in accordance with the invoicing regulations (which also include Article 26 of the ROF), invoices are not issued in the proper sense, the RRSIF will not apply.

Yes, because regardless of your VAT taxation, for personal income tax purposes your economic activity income is determined by applying the direct estimation method. 

Article 26 of the ROF establishes that personal income tax payers who obtain income from economic activities will be required to issue an invoice when said income is determined by the direct estimation method, regardless of the VAT regime under which they are subject.

Consequently, the RRSIF will be applied to the computerized billing systems used by pharmacy owners or any other personal income tax payer who determines their economic activity performance through direct estimation, regardless of the VAT regime. 

Simplified invoices are subject to the RRSIF and, in the case of VERI*FACTU systems, must be communicated to the AEAT. The above is independent of whether an invoice or summary extract is generated at the end of the day, with the purpose of recording the day's sales in a single accounting entry or managing the business.

In the case of operations corresponding to special VAT regimes, simplified, equivalence surcharge or agriculture, we refer to the questions specifically dedicated to these.

Regulations/Doctrine:

• Article 2 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

Yes, the conventional or virtual form through which goods are offered or delivered or services are provided is irrelevant for the mandatory application of the regulations included in the regulation of requirements for computerized billing systems (RRSIF), approved by Royal Decree 1007/2023, of December 5, and its implementing regulations.

Online sales, in some cases, have specific regulations when using European one-stop shop regimes, which may give rise to specific coding in the billing registration register, but such specialities do not exclude compliance with the obligations of the RRSIF.

Regulations/Doctrine:

• Articles 2 and 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.

In the event that billing is done manually, using checkbooks or by writing on them by hand or type, the RRSIF would not affect you because does not use ANY computerized billing system (SIF) to issue your invoices.

A simple and convenient alternative to replacing manual systems is to use the basic invoicing application offered free of charge by the Tax Agency on its electronic site, provided its features and terms of use are tailored to the needs of the person who will use it.

Regulations/Doctrine:

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

• Article 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.

No.

In general, It is not possible for the issuance of some invoices to coexist with a SIF and partly manually. According to the RRSIF (Regulations establishing the requirements for computerized billing systems) the use of any SIF that produces invoices requires that all invoicing must be done electronically.

With character exceptional, when those required to issue invoices do NOT use any SIF (invoicing computer system) to issue their invoices, but are required by specific legal regulations (Law 25/2013) to issue electronic invoices to an Administration and for this purpose use the free software program MiFacturaeThis circumstance constitutes an exception to the single billing rule.

The exception not applicable to the invoices generated by a SIF in Facturae format integrated with FACe.

Explanatory notes:

• Law 25/2013, of December 27, on the promotion of electronic invoicing and the creation of the accounting register of invoices in the Public Sector.

• The General Entry Point for Electronic Invoices (FACe) is an administrative record for submitting invoices to public administrations. This system is connected to the MiFacturae application and other private sector information systems, allowing for convenient and easy submission of your electronic invoices to FACe.

• MiFacturae is the free computer program offered by the Ministry of Digital Transformation for generating electronic invoices in Facturae format, which will generate a computer file with organized data and is sent through FACe.

• The main difference between FACe and Facturae is that FACe is the system for submitting electronic invoices to the Administration, while Facturae is the structured format that invoices must follow to be accepted by FACe.

• To create an electronic invoice for an Administration, you can use a computer program (private or public) that creates electronic invoices or you can do it through the intermediation of an electronic invoicing service provider (issuance by a third party). A small or medium-sized enterprise, or a self-employed person, can use the free software program offered by the Ministry of Digital Transformation (Mifacturae).

Regulation will not affect you if word processors or spreadsheets are used exclusively for:

• Enter invoice data.
• Issue and print invoices.
• Keep billing information.

On the contrary, will be subject to the regulation and will be considered a computerized billing system if, in addition to the above functions, it is used to process the billing information contained in the program to directly generate the VAT record books, the personal income tax record books, accounting, or any other result that is used for the voluntary compliance of tax obligations.

For example, if a user uses an Excel spreadsheet to generate simple lists of invoices issued, including summations or the use of other calculation rules, the Regulation will not affect him. But if you use it by programming a Macro, to generate the issued invoice logbook , your spreadsheet will be considered a computerized billing system and, therefore, must comply with the requirements of the Regulation. 

Verification by the AEAT

The Tax Agency may verify whether the word processors or spreadsheets used to issue invoices meet the criteria for an IT invoicing system based on the capabilities and tools they use.

Free alternative for small business owners and professionals

We remind you that the AEAT will offer a free basic invoicing application, which you can use as long as its features and terms of use meet your needs.

In the event that invoicing occurs materially by the employer himself manually, using checkbooks or writing on them by hand or typewriter (Word/Excel no SIF), No would affect him RRSIF because it does not use any computerized billing system (SIF) to issue their invoices.

On the contrary, Yeah It will be subject to the Regulation when the employer provides the advisor/manager with the information so that the latter can issue materially the invoices and use a SIF. In this context, if the business owner has delegated the physical issuance of the invoice to a third party (such as an advisor/manager), it is the third party who, if using a SIFIn addition to physically issuing said invoice, it must generate and, if it is in the "VERI*FACTU" mode, send the registration of billing required by the RRSIF.

In any case, this possibility (delegation) does not exempt the party obligated to issue invoices (business owner) from responsibility for said compliance.

No, if in accordance with the Regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30, or by a billing authorization of article 3.1.d) of said same Regulation, there is no billing obligation, the regulations of the Billing Computer Systems Regulation will not be applicable either. 

The inclusion of the QR code and the mention VERI*FACTU is applicable to the computer systems referred to in article 7 of the Regulation approved by Royal Decree 1007/2023. Since those obligated to the SII are excluded from this subjective scope, these requirements ONLY apply to the operations and those obligated under Article 3. Those required to submit to the SII, for all purposes, are not affected by RD 1007/2023.

Regulations/Doctrine:

• Article 3.3 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.

• Section 5 of Article 6 and Section 5 of Article 7 of the Regulation governing billing obligations, approved by Royal Decree 1619/2012 of 30 November.

Yes, in fact, all the obligations of Royal Decree 1007/2023, as regards users, will be applicable on the dates proposed in the fourth Final Provision of RD 1007/2023, wording given by Royal Decree-Law 15/2025, of December 2, since the modified regulations of the Billing Obligations Regulation (ROF) RD 1619/2012, depend on those regulated in the regulation that establishes the requirements that must be adopted by the computer or electronic systems and programs that support the billing processes of businesses and professionals, and the standardization of formats of the billing records (RRSIF).

The obligations for producers and marketers (to produce and sell adapted software programs) will come into force 9 months after the publication of the technical OM.

Regulations/Doctrine:

• Final Provision Four of Royal Decree 1007/2023, of December 5, which approves the regulation that establishes the requirements that must be adopted by the computer or electronic systems and programs that support the invoicing processes of businessmen and professionals, and the standardization of formats of the invoicing records (RRSIF), modified by Royal Decree-Law 15/2025, of December 2.

 No, these exclusions imply that the RRSIF will not apply to such operations.

However, it should be noted that even in the cases excluded from billing by article 3.1.a) ROF, there are exceptions indicated in article 2.2 of the ROF that require the issuance of an invoice. In such cases, the taxpayer must comply with the obligations of the regulation that establishes the requirements for computerized billing systems in the event that it issues invoices, provided that it also complies with the rest of the conditions indicated (“rule of the 4 “NOs””).

Regulations/Doctrine:

• Article 1.2 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 3.1.a), 3.2 and 2.2 of the Regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30.

The regulations consider taxpayers individually (not by groups) with regard to their billing obligations, so that, even if they belong to the same group of companies, they must comply with their billing obligations according to their status. Therefore, the SIF of each company must comply with the billing obligations that correspond to it. It should be noted, however, that entities within a group may voluntarily register with the SII in order to maintain management consistency with the group to which they belong.

On the other hand, there are market products capable of applying the requirements of both regulations.

Regulations/Doctrine: 

Article 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.

In the event that the sole proprietor is obliged to issue an invoice (ordinary or simplified), from the moment that he uses a computerized billing system consisting of a cash register to record the sales made and print for each of them what should be a simplified invoice to deliver to the client, he is subject to RD 1007/2023, of December 5, and the regulations approved by it, so he must comply with it, either by adapting the cash registers (if this were possible), or by acquiring an adapted computerized billing system (SIF).

As for the electronic scale, if the businessman or professional uses it only to weigh the product and obtain the amount that is then manually entered into the cash register to issue the final simplified invoice, it would not be considered a SIF, but rather an -independent- auxiliary element for measurement (and, where appropriate, for calculating the amount associated with the product, according to its price per kilogram). In this case, the SIF would be the cash register, so the electronic scale would not have to adapt to RD 1007/2023.

However, there are electronic scales with more powerful features that allow the accumulation of the amounts of the different products weighed and issue a simplified invoice for the total purchase made in a single act (among other possible features), so they would then be considered SIF as they are also used as cash registers. In other words, they would be SIF with other auxiliary electronic elements (in this case, for weighing) added. If so, then they should adapt to RD 1007/2023 and the regulations approved by it. Internet connections can be managed through telephone lines, and non-verifiable invoice issuing systems allow files to be kept at the local headquarters.

Regulations/Doctrine: 

• Article 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.

Yes, ALL operations for which entrepreneurs and professionals (natural or legal persons) must issue an invoice in accordance with current regulations (especially in accordance with the Billing Obligations Regulation approved by RD 1619/2012) are subject to the RRSIF. This includes both exports and intra-Community deliveries of goods and international or intra-Community supplies of services.

Regulations/Doctrine:

• Articles 1, 3 and 4 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.

Yes, when the non-resident entrepreneur has a permanent establishment for the purposes of the Non-Resident Income Tax regulations (Royal Legislative Decree 5/2004, of March 5).

Regulations/Doctrine:

• Article 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.