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Technical development of the Royal Decree that regulates the "Verifactu" regulation

As is known, on December 6, 2023, Royal Decree 1007/2023, of December 5, was published in the BOE, approving 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; all of this in direct development of the new letter j) introduced in article 29.2.j) of the LGT, by means of law 11/2021, of July 9, on the prevention and fight against tax fraud.

The third Final Provision of the aforementioned Royal Decree establishes that this Royal Decree will be followed by the Ministerial Order of Finance for technical development, from which the developers of computer programs must submit to its provisions within a maximum period of 9 months. They must also include a “responsible declaration” of compliance with this regulation on their products. The aforementioned Ministerial Order is currently being processed and it details technically the aspects included in the Regulation that are necessary, and in particular, the following:

  1. The technical and functional specifications of the billing computer system.

  2. The conditions of the subsidiary use computer application developed by the Tax Agency.

  3. The structure, format and technical characteristics of the invoice registration record data.

  4. The structure, format and technical characteristics of the cancellation record data.

  5. Requirements for the fingerprint or 'hash' and the electronic signature of the previous records.

  6. The structure, format and characteristics of the information in the responsible declaration or self-certification of software manufacturers.

  7. Technical specifications for the voluntary submission of 'Veri*factu'.

  8. Tools to integrate billing records into accounting books. And the technical characteristics of the information to be added to the high billing register to complete the content and structure of the book of issued invoices, and the sales and income register books, and income, and to consider said obligation fulfilled by keeping it at the Headquarters of the Tax Agency.

  9. The deadlines and how to opt out of 'Veri*factu'.

The most important content of the Ministerial Order is found in its Annexes I and II, where any company specialising in the manufacture and marketing of electronic invoicing programmes will find the essential technical details of the structure of the invoice registration and cancellation files, and the event log, as well as a whole set of details relating to how to implement the standardisation of information and its readability, as well as its inalterability, traceability and safe storage requirements.

The single, standardised billing data model that emerges from these technical details represents a milestone in terms of standardisation at the national level. In the medium term, all computer systems will converge to this model, including those used by taxpayers not directly obliged to comply with this Regulation. Additionally, this same 'Veri*factu' data model will be the starting point for another, more complete data model, which will be used for the implementation of electronic invoicing, once it is approved and the transitional periods regulated in the draft B2B Electronic Invoicing Regulation are completed, which is being processed in development of article 12 of Law 18/2022, on the creation and growth of companies.

The countdown clock has already started and entrepreneurs and self-employed workers are called upon to digitalize the management of their businesses in a simple, affordable and profitable way. The Tax Agency will help throughout this process by providing the necessary information and facilitating auxiliary programs and 'last resort' systems to those entrepreneurs who do not need complete systems.