Frequently asked questions (FAQ)

Since the regulation establishing the requirements for computerized billing systems applies to computerized billing systems (SIF), meaning SIFs used to issue invoices, the only documents affected by this regulation are INVOICES, both "complete or ordinary" and simplified, not affecting any other type of supporting documents for the delivery of goods or provision of services.

Invoices issued with these SIFs must include a representation of certain information about them using a tax "QR" code. In addition, these SIFs must generate – and sign and save or, where appropriate, send – the corresponding billing records of the invoices issued.

Regulations/Doctrine :

• Articles 1.1 and 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 6.5 and 7.5 of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30, introduced by Final Provision one and two of Royal Decree 1007/2023, of December 5.

In addition to the information that invoices must currently contain, whether ordinary or simplified, those issued with computerized billing systems (SIF) referred to in Royal Decree 1007/2023, of December 5, must include a tax "QR" code that facilitates the communication of certain data to the Tax Agency. And if the SIF that issued them is operating in the VERI*FACTU mode, the phrase "Invoice verifiable at the AEAT electronic headquarters" or VERI*FACTU must also be included.

Regulations/Doctrine:

• Articles 6.5 and 7.5 of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30, introduced by sections one and two of the first Final Provision of Royal Decree 1007/2023, of December 5.

Temporary data entry and editing, preview, etc. The issuance of invoices is not prohibited by the regulations establishing the requirements for computer billing systems or by the regulations on billing obligations, although until the invoice is completed, it cannot be issued with its corresponding tax "QR" code. For this reason, both draft invoices and proforma invoices do not have any tax "QR" code. The issuance of proforma invoices or simplified invoices without tax validity is permitted as long as they are finally replaced by the official invoice or simplified invoice issued and this is delivered to the client.

When an invoice is finally issued (that is, in general, when the QR code has been incorporated into it and the corresponding high billing record has been generated, signed or sent to the Electronic Office of the Tax Agency), it can no longer be considered a draft and its alteration, in the information elements that make up the "high billing record", will not be permitted unless it is done by means of new billing records, as indicated in the third paragraph of article 8.2.a) of the regulation approved by RD 1007/2023.

For IT purposes, the system for generating pro-forma invoices or those without tax validity must be inextricably linked to the invoice issuing system, forming a unit. For internal control purposes, it is advisable to keep a record of the pre-invoices or pro forma invoices prepared.

Regulations/Doctrine :

• Articles 1.1 and 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 6.5 and 7.5 of the regulations governing billing obligations (ROF), approved by Royal Decree 1619/2012, of November 30, introduced by Final Provision one and two of Royal Decree 1007/2023, of December 5.

In short, a computerized billing system (SIF) is considered to be the set of hardware and software used to issue invoices that supports the entry of billing information by any means, stores this information and processes it to generate other derived products, regardless of where this process is carried out.

More broadly, a computerized billing system (CBS) is the set of hardware and software used to issue invoices by performing the following actions:

1. Allow entry of billing information by any method. As typical examples:

   • Enter invoice data directly into the SIF manually. Ç

   • Import the data necessary to issue invoices into the SIF, when these have been captured in other systems. 温度

   • Receive in the SIF (online or in batches) through automated processes the data necessary to issue invoices, when these have been captured in other systems.

2. Maintain billing information, inside or outside the SIF.

   This means that the product obtained, once the invoice has been issued – and typically printed – (based on the information in the previous section), is not discarded or eliminated, but is stored and saved, and maintained over time.

3. Process billing information using any procedure to produce other derived results, regardless of where such process is done (in the SIF itself or in another computer system that has access to such information).

   That is, it implies that the information captured and stored electronically from the invoices issued is reused to do other things, obtaining new results derived from it, such as calculations (counting, adding...), statistics, making accounting entries, exporting it or communicating it to other systems so that they can use it for any other purpose, fiscal or non-fiscal, etc.

   Thus, a word processor that is ONLY used to enter (and even store) invoices issued for printing is NOT considered a SIF (i.e., it is considered manual invoicing). However, if this data is reused (within the processor itself, with the calculation and/or programming functionalities – macros – that these allow, or by exporting/communicating them to other programs or computer systems) to obtain other derived products, then it is considered invoicing using a SIF (and, therefore, should be subject to the SIF Regulation).

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.