Tax Agency: Frequently Asked Questions (FAQ) - VERI*FACTU Systems (Verifiable Invoice Issuance Systems)

To comply with the obligations set forth in the Regulation governing the requirements of billing systems (RRSIF), approved by RD 1007/2023, of December 5, two modalities are allowed: VERI*FACTU (verifiable invoice issuing systems) and non-verifiable invoice issuing systems.

Additionally, in accordance with article 7.b) of the RRSIF approved by RD 1007/2023, of December 5, the Tax Administration will also design a last resort web application, which will have the status of VERI*FACTU and will make it available to entrepreneurs who lack SIF , in which case the requirements of RRSIF will also be met.

Regulations/Doctrine:

Articles 7 and 15 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 answer to this question is found in Articles 15 and 16 of the Regulation, which in turn mention Articles 7, 8.2 and 14.2.

In summary, the key difference is that the SIF «VERI*FACTU» sends online – through an Internet connection, continuously, securely, correctly, completely, automatically, consecutively, instantly and reliably – to the Tax Agency all billing records corresponding to the invoices issued by the SIF, while a system for issuing non-verifiable invoices does not send them, but stores them, obliging itself to guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of the records, without interpolations, omissions or alterations for which the proper annotation is not left in the systems themselves throughout the tax prescription period.

Online submission by the SIF “VERI*FACTU” is a way of complying with the Regulation that makes the implementation – more complicated and costly – of other security features unnecessary, while exempting users from responsibilities for the conservation and custody of the records. In order to comply with the requirements of the Regulation, non-verifiable invoice issuing systems must also incorporate other control measures, including event registration, electronic signature of billing and event records, allowing the possibility of exporting billing and event records, offering verification of various requirements (fingerprint, signature, linking, etc.) of billing and event records, managing alarms, etc.

Regulations/Doctrine:

Articles 7.b), 8.2, 14.2, 15 and 16 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 formats of the billing records ( RRSIF ), approved by Royal Decree 1007/2023, of December 5.

The option will be deemed to have been tacitly made by the fact of systematically initiating the sending of billing records to the electronic headquarters of the AEAT . This option will be extended at least until the end of the calendar year in which the first voluntary submission of billing records has actually taken place.

Regulations/Doctrine:

Article 16.5 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.
Article 17 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.

A company can join VERI*FACTU whenever it wants. Once you have joined this modality, you must remain at least until the end of the calendar year.

If you start the year using a non-verifiable invoice issuing system, you can change to VERI*FACTU at any time and must remain in this mode until at least the end of the calendar year.

Regulations/Doctrine:

Articles 15 and 16.5 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.
Article 17 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.

No, the obligation to prepare the Register Books of Issued Invoices (regulated in article 63 of the Value Added Tax Regulations, approved by RD 1624/1992, of December 29) is maintained, as it is a different and independent obligation from that established by Regulation SIF , which regulates the way in which computer billing systems must operate in the issuance and maintenance of billing records for the creation or cancellation of invoices.

Nor is it exempt from the submission of information models such as those mentioned, without prejudice to the streamlining that may arise from assistance in preparing them.

Yes, the manufacturers of Billing Computer Systems can offer VERI*FACTU-only applications (verifiable invoice issuing systems), “dual” applications that allow the user to choose between VERI*FACTU and non-verifiable invoice issuing systems, or even “triple” applications that allow the above and, where appropriate, use it in the SII mode.

On the contrary, the production of systems that only issue non-verifiable invoices is not permitted since the RRSIF approved by RD 1007/2023, in its article 8.1 second paragraph, requires the systems to have the capacity to send.

In any case, the decision to manufacture and market one system or another corresponds to the manufacturers themselves based on commercial needs, since the standard does not require the manufacture of systems with options.

Regulations/Doctrine:

Articles 8.1, 15 and 16 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 exceptional cases such as those mentioned above, or other similar ones, the remission periods would be extended until the outage is restored or service is reestablished. The Ministerial Order that develops the Regulation approved by RD 1007/2023 gives more details on how to proceed in this regard (periodic resubmissions, “Incident” mark in the header of the Records submission, etc.).

In these cases of incidents, there is no fixed maximum period established for sending, which must be retried periodically until the incident is corrected by incorporating the "S" in the "Incident" field in the sending.

Incidents such as those mentioned, which affect the referral to the AEAT , DO NOT mean in any case that the company's billing should be interrupted. This should continue normally and the systems will be able to send the records “a posteriori” (retrying the submission periodically as explained in the previous paragraphs). Obviously, if the power outage is a problem and the systems cannot operate, the decision to continue operating/billing will be up to the business owner, but in such a case the billing information must be recovered and sent as soon as possible.

Each user must have their Billing Computer Systems adapted to the regulations that govern them. But that doesn't mean you should have just one SIF. It is permissible to have several SIFs, especially when business needs justify it (several non-interconnected business centers, several differentiated product lines, etc.). In this case, the SIFs must comply with the regulations, but the option for one or the other modality is not joint for the person required to invoice, who may have a SIF in the VERI*FACTU modality and another in the non-verifiable invoice issuing system modality. It must be understood that each of these systems will NOT be able to interleave operations in the other modality, that is, the VERI*FACTU system will always act as such (always with shipping) and the system for issuing non-verifiable invoices will always act as such (always with secure record keeping).

It should be noted in this regard that part of the benefits derived from the use of VERI*FACTU type solutions cannot be produced for those taxpayers who do not have ALL their operations in this modality (for example, assistance services such as downloading records, precursor to the registration book, lower requirements...).

Regulations/Doctrine >:

Articles 7, 15 and 16 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.
Ministerial Order developing the technical, functional and content specifications referred to in 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 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.

The VERI*FACTU modality does not require the electronic signature of the billing records to be sent, nor does said signature constitute a mandatory field in the structure of the billing registration record. Precisely, one of the advantages of using VERI*FACTU is the absence of this obligation.

On the other hand, it will be mandatory if the tickets were sent in response to a request and/or if they were stored in the SIF (billing system) itself by not using VERI*FACTU.

Regulations/Doctrine :

Article 16 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 fact that all the modules mentioned belong to the same ERP suggests the interconnection of said modules in a centralized billing system (or at least consolidated and centrally controlled). In that case, all records must be linked in the only SIF with a single link, regardless of the series or number of the invoices to which they correspond.

However, if they were unconnected or partially unconnected modules, for example, because they generate the mandatory logic (high billing records, QR codes, etc.) in a decentralized manner and without being linked in real time or controlled by the only ERP (to which the records are sent once a month), it can be understood that they are SIFs that are different from each other. In this case, the chaining (and, where appropriate, the sending) occurs for each SIF, which operates in isolation from the others and, therefore, does not know what another module is doing. In this case, each of the SIF must individually comply with the requirements of the RRSIF approved by RD 1007/2023, of December 5.

First of all, it must be said that for SIF producers, "VERI*FACTU" SIFs are easier to produce than non-verifiable invoice issuing systems, since they have far fewer technical and security requirements to implement.

As regards its use by the person obliged to issue invoices, the main advantages of using SIF «VERI*FACTU» instead of non-verifiable invoice issuing systems are the following:

They are exempt from the responsibility – and, where applicable, from carrying out the tasks – of storing and/or exporting and keeping the billing records and event records accessible and legible for years. It can therefore be made easier to use, whilst providing greater peace of mind regarding compliance.
As a result of the previous point, you will not have to worry about receiving requests from the Tax Agency to subsequently deliver billing records of your invoices issued with SIF "VERI*FACTU", with the consequent savings in time and costs of all kinds (specialized personnel, economic...) linked to the processing necessary to comply with this type of management. Indirectly, this can speed up the processing of tax refunds that are requested.
They will not be obliged to ensure that, at all times, the clock used by the SIF to date the billing and event records has the exact time (within a margin of error of one minute).
By means of the “QR” codes that are incorporated into invoices (including simplified invoices), which will also include the phrase “Invoice verifiable at the electronic headquarters of the AEAT ” or “VERI*FACTU”), your clients will be able to verify that these invoices have been registered with the Tax Agency, which is a guarantee of transparency and quality in the degree of tax compliance. This aspect could be publicized and argued as a distinctive element of “quality and tax compliance.”
Electronic services provided by the Tax Agency will be available to them to facilitate the submission of the invoice register books issued, completing them based on the information already provided when submitting the billing records, as well as assistance in the preparation of self-assessments.

Regulations/Doctrine:

Various articles of the regulation that establishes 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 invoice issue date must coincide with the date the billing record was generated. Both dates should generally correspond to the date on which the Billing Record is sent. However, there may be specific situations where the date of generation of the record does not coincide with the date of sending (for example, an incident when sending that requires retrying later, change in summer/winter time, etc.).

More details can be found in the validation rules that affect the fields of the billing record and the referral message to AEAT .

If no response is received after a submission, the billing records must be resubmitted until a response is received.

It should be emphasized that these "sends" and "responses" correspond to machine-to-machine communications, which are managed by the SIF and by the electronic headquarters of the AEAT , therefore, in general, they are transparent to users.

Regulations/Doctrine:

Ministerial Order developing the technical, functional and content specifications referred to 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 billing records, approved by Royal Decree 1007/2023, of December 5, and in article 6.5 of the regulation that regulates billing obligations, approved by Royal Decree 1619/2012, of November 30

To send the Billing Records, any of the current identification methods accepted by the AEAT can be used, including representation, power of attorney and social collaboration, using a qualified certificate from the third party who holds the status of representative, power of attorney or social collaborator.

Yes, the AEAT plans to implement a service that allows the download of all billing records issued by a taxpayer and communicated through the VERI*FACTU system. The download of records issued by suppliers of the same taxpayer is also planned to the extent that they are also VERI*FACTU.

All billing records sent in the same batch must correspond to the same taxpayer. In the event that the same SIF serves multiple companies, the system must make separate shipments.

The way in which the client receives the invoice issued by a SIF is no different from those issued by other systems; That is, it is regulated by the Regulation governing billing obligations, approved by Royal Decree 1619/2012. Thus, those who receive it from other businessmen or professionals for the operations of which they are recipients and which are carried out in the development of the aforementioned activity, as well as other persons and entities that do not have the status of businessmen or professionals are obliged to keep them (Articles 1, and 19 to 23). The way in which the invoice can be issued and received will depend on whether it is paper or electronic invoicing, and in this case whether it is structured or unstructured. The RRSIF does not limit the above possibilities in any way.

On the other hand, if the question refers to billing records (invoices):

The AEAT will offer services that allow billing records to be downloaded to the person who sent them.
Likewise, the AEAT will offer services that allow the recipient to download them (obviously, only those billing records that their suppliers have sent to the AEAT through SIF VERI*FACTU).
Finally, the invoice recipient will be able to compare the QR code with the proof of the billing record in the electronic headquarters of the AEAT and, where appropriate, the coincidence of the information sent by the SIF of the supplier.

Article 29.2.j) of the General Tax Law applies to computer systems used to support accounting, invoicing and management processes, so all of them are required to guarantee the 6 requirements on the records used (that is, on the information and data handled by each one) and, therefore, not allow interpolations, omissions or alterations for which the proper annotation is not left in the systems themselves.

However, this mandate is generic for all applications except in the case of Billing Systems. For them, it is specified how to comply with this mandate, which is done through the Regulation that regulates the Requirements of Billing Systems (RRSIF) approved by RD 1007/2023, of December 5, which develops the requirements that must be implemented in the billing computer systems to comply with article 29.2.j) of the LGT .

Regulations/Doctrine:

Article 29.2.j) of the General Tax Law Law 58/2003, of December 17, introduced by Law 11/2021, of July 9.

The immediacy of sending to VERI*FACTU is part of the security system of billing records, so it applies in all cases. On the other hand, the verification of the transaction by the customer using the QR code, characteristic of VERI*FACTU systems, can only be carried out if the shipment occurs immediately. Therefore, in such a case, simplified invoices must be sent immediately, respecting the technical times required by the information flow control established by the Electronic Office.

Regulations/Doctrine:

Articles 15 and 16 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.

Frequently asked questions (FAQ)

VERI*FACTU Systems (Verifiable invoice issuance systems)

What possibilities does the RRSIF raise regarding what a Billing Computer System should be like?

What is a VERI*FACTU system and how is it different from a non-verifiable invoice issuing system?

When and how can you opt for the VERI*FACTU system?

Is it possible to change from the VERI*FACTU mode (verifiable invoice issuance system) to the non-verifiable invoice issuance system mode, and vice versa? Or, on the contrary, are there limitations to these changes?

Does the maintenance and preservation of the registration billing records and the cancellation billing records exclude the obligation to prepare the Record Book of Issued Invoices? And what about the presentation of information models 347/349?

Can a SIF function solely as a system for issuing verifiable invoices? Can computer systems be manufactured that can meet the requirements of RRSIF and SII ?

In the case of VERI*FACTU systems, if there is a power outage or a computer failure, an internet connection problem, or the AEAT Electronic Office service is temporarily inoperative, how should information be sent to the AEAT ? Should billing be stopped?

Merchants with multiple terminals, each of which is a SIF , can they behave differently? For example, it is possible to have 2 payment terminals, one with the VERI*FACTU system and then another with a non-verifiable invoice issuing system.

Although the regulation specifies that it is not necessary in VERI*FACTU, can billing records be sent electronically signed?

In the SIF installed in an ERP there are “n” different modules (each one with a different billing series) that issue invoices: Is it necessary to link all invoices using a single link for the entire company? Could a billing record chain be created for each module?

What are the advantages of using a SIF «VERI*FACTU» instead of a non-verifiable invoice issuing system?

Regarding the immediacy of the submission of billing records in VERI*FACTU, should the issue date [creation] of the billing record coincide with the communication date?

What should you do if you send a set of billing records, but for some technical reason you do not receive a response confirming that they were received correctly?

Is it possible to use a third-party electronic certificate for identification [authentication] for the submission of records or is it mandatory to use the taxpayer's electronic certificate for the invoices issued?

Will the AEAT provide the service of downloading all invoices submitted by a taxpayer if they use a VERI*FACTU system?

In a VERI*FACTU system, can billing records from different user companies of SIF be included in batches of shipping billing records, or should each batch only include invoices from the same user company?

What will the process of receiving invoices be?

Are computer applications that record invoices imported from a VERI*FACTU system subject to the same obligations of the Royal Decree?

A system that has several stores distributed throughout Spain and is making sales through simplified invoices, does it have to send the VERI*FACTU information immediately, or is it possible to send it, for example, when the stores close?