Frequently asked questions (FAQ)

Yes. The regulation establishing the requirements to 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, provides in its article 5 the possibility of requesting the non-application of or some aspect thereof when certain circumstances occur, which are understood to be extraordinary, related to economic activity or of a technical nature.

The application can be submitted through the Tax Agency's electronic office.

Regulations/Doctrine:

• Article 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.

Yes. The material fulfillment of the obligations of the regulation that establishes the requirements for computerized billing systems may be delegated to the recipient of the operation or to a third party, provided that the conditions established in article 5 of the regulation that regulates billing obligations ( ROF ) are met, approved by Royal Decree 1619/2012, of November 30, for the purposes of the obligation to issue the invoice, with powers granted to do so.

In any case, this possibility does not exempt the party obliged to issue invoices from responsibility for such compliance.   

Regulations/Doctrine:

• Article 6 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 5 of the regulations governing billing obligations ( ROF ), approved by Royal Decree 1619/2012, of November 30.

First of all, it must be taken into account that the object 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 entrepreneurs and professionals, and the standardization of formats of the billing records ( RRSIF ), approved by Royal Decree 1007/2023, of December 5, are precisely the computer billing systems ( SIF ), which is different from the obligation to keep VAT record books ( LRI ). They are therefore different obligations that may affect different taxpayers.

In the case raised, and with regard to the obligations imposed by the RRSIF, if the supplier has delegated the physical issuance of the invoice to its client, it is the client who, in addition to physically issuing said invoice, must generate – and, in the "VERI*FACTU" mode, send – the initial invoicing record required by the RRSIF. However, if the client keeps billing records in accordance with the terms established in article 62.6 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29, (through the immediate provision of information, or SII), they are exempt from compliance with the obligations provided for in the RRSIF for such operations.

On the other hand, the maintenance of the LRI is independent of who actually issues the invoices and is regulated in articles 62 and 63 of the Value Added Tax Regulations, approved by Royal Decree 1624/1992, of December 29. Therefore, each company must include invoices issued for all goods sold and services rendered (regardless of who actually issued the invoice, which may be the selling company itself, a third party, or the recipient/buyer) in the LRI of invoices issued, and invoices received for goods purchased or services received (regardless of who actually issued the invoice, which may be the selling company, a third party, or the recipient/buyer) in the LRI of invoices received.

Regulations/Doctrine:

• Articles 5 and 6 of the regulation establishing the requirements to be adopted by computer or electronic systems and programs that support the invoicing processes of entrepreneurs and professionals, and the standardization of invoicing record formats (RRSIF), approved by Royal Decree 1007/2023, of December 5, amended by Royal Decree 254/2025, of April 1.
• Article 5 of the regulation governing invoicing obligations (ROF), approved by Royal Decree 1619/2012, of November 30.
• Articles 62 and 63 of the Value Added Tax (RIVA) regulations, approved by Royal Decree 1624/1992, of December 29