Frequently asked questions (FAQ)

The cited articles of the Billing Obligations Regulation refer to the computer systems of article 7 of the Regulation approved by RD 1007/23 (i.e. the RSSIF Regulation). In turn, article 3.3 of Regulation SIF excludes from the subjective scope of this those obliged to SII (Immediate Supply of Information). Therefore, these new requirements incorporated into articles 6.5 and 7.5 of the Billing Obligations Regulation (ROF) approved by RD 1619/2012, are only mandatory for those obligated entrepreneurs and professionals NOT subject to the SII, when they must issue invoices. In particular, the expressions “VERI*FACTU” or “Invoice verifiable in the AEAT electronic headquarters” included in the printed invoices issued will only be mandatory for the SIFs of the aforementioned businesses that choose to operate in accordance with this modality.

Those required to submit to the SII, for all purposes relating to their own billing, are not affected by RD 1007/2023.

Indeed, all invoices produced with a SIF, regardless of the method used, must have the "QR" code printed on them. This obligation derives from the wording of the First Final Provision of Royal Decree 1007/2023, in relation to article 17 of Regulation SIF approved by said Royal Decree.

Regarding the purpose of the "QR" code , through this the invoice is not sent to the AEAT by its issuer, but it serves:

1. So that the client receiving the invoice can compare or check whether the corresponding billing record is in the possession of the AEAT or not. This comparison will take place when a verifiable invoice issuing system is used (VERI*FACTU system).

2. On the contrary, when the computerized billing system used is a system for issuing non-verifiable invoices, the sending of the information to the Tax Administration by the client receiving the invoice, by means of the QR code, serves to record the existence of the invoice itself and its essential content, which could serve for a possible future contrast by the AEAT.

In general, the "QR" contributes to allowing better control of the tax compliance of the invoice issuer, that is, it is a way of showing greater fiscal "reliability" (if the invoice is registered with the AEAT , the client can expect that their supplier is not committing any type of tax fraud, nor is they charging them VAT that they then do not declare).

Regulations/Doctrine:

• Article 17 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 response that the business or final consumer, recipient of the invoice, will receive will depend on whether or not "VERI*FACTU" systems have been used to issue the invoice.

If the invoice has been generated through a "VERI*FACTU" system, the AEAT will proceed to compare the information received with the billing records sent by the invoice issuer. The responses given to requests made through the "QR" code by a "VERI*FACTU" system will be the following:

1. Invoice found. The Tax Agency has an invoice with identical characteristics to the one sent.

2. Invoice not found. The Tax Agency does not have any invoice with the characteristics sent.

If the invoice has been generated through a non-verifiable invoice issuing system, the AEAT cannot perform a comparison with the billing records because these have not been previously sent by the invoice issuer.  In this case, the response message is “Invoice not verifiable.” This invoice has been issued by a computerized billing system that is NOT “VERI*FACTU” (i.e., one that does not send invoice information to the Tax Agency), so it cannot be verified, although this information may help the Tax Agency in carrying out its tax compliance control tasks.

In the event that structured electronic invoicing is used, since there is no paper printing, the QR code cannot be incorporated as such into the invoice. However, the obligation to include the QR information, in the case of electronic invoicing, whether the complete or simplified invoice, is replaced by the incorporation of the QR content into the e-Invoices, including the URL for verification at the invoice site. This is established in article 6.5.a) of the Billing Obligations Regulations by providing that In the event that the invoice is electronic, the graphic representation may be replaced by the content represented by the “QR” code.

Therefore, customers who receive structured electronic invoices will be able to use the information contained in the electronic invoice to access the invoice verification service via the URL received (the same one that would encode the QR code), just as if they were scanning the QR code.

If the electronic invoice is not structured, but is simply transmitted in a visible electronic format (PDF, TIF, etc.) and printable, the incorporation of the QR will have no special features compared to the one corresponding to the issuance on paper.

Regulations/Doctrine:

• Article 6.5.a) of the Regulation governing billing obligations, approved by Royal Decree 1619/2012, of November 30, as amended by RD 1007/2023, of December 5.

• Article 17 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, and its development by Ministerial Order.

No. The tax "QR" code is only added to invoices - whether "complete or ordinary" or simplified, whether in paper or electronic - issued by the billing computer systems affected by RRSIF .

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.

It is NOT mandatory to print the invoice on paper, provided that electronic invoicing systems are used (whether structured or unstructured).

On the other hand, any printout of an invoice (ordinary or simplified), or image of it in digital format (unstructured electronic invoice), must have the QR code and other required information printed or visible. On the other hand, if the invoice is structured electronic, the QR image is not required, but its content is (in the form of the URL of the electronic office enabled for this purpose).

The submission of the billing record (with all the content referred to in articles 10 and 11 of the RRSIF approved by RD 1007/2023) by the company to the AEAT is an additional obligation (in the VERI*FACTU mode), but it responds to another purpose and in no way contradicts the obligation to incorporate the "QR" code or the url to the invoices issued.

Regulations/Doctrine:

• Article 17 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 QR code matching service can be performed from any device that has a camera and has access to QR code recognition to obtain the URL and connection to the website.

To carry out the above process, the use of the AEAT APP is recommended, although not essential. The AEAT APP is a guarantee when it comes to ensuring that the "QR" incorporated into the invoice and read is not irregular.

As a general rule, QR codes on printed (or displayable) invoices must appear at the beginning of the invoice, before the content of the invoice begins. Therefore, it will always be the first “QR” code that will appear on the invoice. If a vertical orientation format is used to organize and arrange the invoice content, the QR code will be placed above it, close to the top margin, preferably centered or, if not, close to the top left margin. If you are using a horizontal (landscape) format for the invoice, the QR code will be placed to the left of the invoice, preferably close to the top left margin (or, if not, centered with respect to the top and bottom margins of the invoice). It is about homogenizing its location so that its location is predictable. However, it is expected that if there are obstacles that make this location inconvenient, another location may be adopted, provided that it is clearly visible and distinguishable from any other code or QR code used. If there is any pre-printed element on the paper to be used to print the invoice and which, therefore, is not generated from the SIF (such as the company logo, assuming that the rest of the information is generated by the SIF), the pre-printed part, not having been generated by the SIF, could be kept in its place, leaving the QR located as the first element of the “rest” of the invoice that is generated by the SIF.

The tax QR code should only appear once, at the beginning of the invoice and before its content. Therefore, if the invoice takes up more than one page, it must appear on the first page and not on the following pages.

The approach of placing it at the beginning of the invoice aims to align with the spirit of article 29.2.j) of Law 58/2003, of December 17, General Tax Law, introduced by article of Law 11/2021, of July 9, on measures to prevent and combat tax fraud, since this gives maximum visibility to the tax QR, being a fundamental pillar of the model. This ensures that it is visible, its location is standardised and made predictable, favouring its use and contributing to citizen awareness and collaboration and transparency in the tax compliance of those who issue invoices, which also contributes to promoting their good image.

Regulations/Doctrine:

• Ministerial Order that develops the Regulation establishing 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.

As for the size of the QR code, in order to standardize it more widely on all invoices and ensure standard readability, it must be within the required range of dimensions (which coincides with that adopted in the specifications by the Provincial Treasuries in the TicketBAI Project), and cannot be smaller or larger.

This size should be within the following range:

• cannot be less than 30x30 mm

• cannot be larger than 40x40 mm.

This range is considered to be the most suitable, to accommodate the content that must be included in the QR code, and to facilitate its reading by devices capable of doing so.