Frequently asked questions (FAQ)

Those who meet the following four requirements will be able to obtain the status of reliable operator:.

1. to be registered in the REDEF,
2. have an extraction volume during the previous calendar year of at least 1 billion liters of gasoline, diesel and biofuels intended to be used as fuel,
3. having carried out operations as a wholesale operator during the previous 3 years, and
4. meet the financial solvency requirements.

Recognition of trusted operator status can be requested from 1 January 2026.

Applications may be submitted through the AEAT electronic headquarters and the resolution of the same will be notified from 1 February 2026, the date on which the transitional regime provided for in the sole transitional provision of Order HAC/1496/2025, of 17 December, ends, and from which all operators who do not have the status of reliable or of authorized economic operator, must guarantee the payment of the VAT corresponding to certain fuels that leave the non-customs deposit regime referred to in the third paragraph of article 19.5 of Law 37/1992, of 28 December, on Value Added Tax. Notwithstanding the foregoing, the favorable resolution may be notified prior to that date.

It can be submitted from 1 January 2026, which will allow the AEAT to assess its suitability before the end of the transitional regime provided for in the sole transitional provision of Order HAC/1496/2025, of 17 December.

It should be noted that, in accordance with the provisions of section eleven of the annex to Law 37/1992, of December 28, on Value Added Tax, those operators who have the status of AEO are exempt from the obligation to guarantee VAT and, therefore, they can never be held jointly liable for any possible non-payment of VAT to those tax warehouses that allow the extraction of hydrocarbons included in article 19.5 of Law 37/1992, of December 28, to Authorised Economic Operators.

Notwithstanding the above, an AEO may not be registered in REDEF and, if it is not, the tax warehouse from which the extraction is made will be secondarily liable for any VAT non-payments that may occur associated with said extractions.

Therefore, those tax warehouses that do not want to assume joint and several or subsidiary liability regarding the payment of VAT linked to the abandonment of the non-customs warehouse regime referred to in the third paragraph of article 19.5 of Law 37/1992, of December 28, must not only verify that the operator has the status of AEO but also that it is registered in REDEF.

The Register of Trusted Operators is integrated into and forms part of the REDEF, since one of the requirements to obtain the status of a trusted operator is to be registered in the REDEF, so all trusted operators must be part of the REDEF. However, both records are independent and are consulted separately through separate query applications.

In this case it will not be necessary, since among the requirements for granting the status of reliable operator provided for in the Law is being included in the REDEF, therefore, if an operator has the status of reliable it will necessarily be registered in REDEF.

The stipulated validity period for these requests will be 10 calendar days, after which these requests will not be valid and, therefore, cannot be authorized by the tax warehouses. In these cases, if the use of a guarantee has been chosen, the amount of the guarantee that has been withheld will be released, and if the advance payment system with form 319 has been used, the refund of the payment made can be requested by means of a request for rectification of the corresponding self-assessment.

Once the AEAT (Spanish Tax Agency) issues authorization for a specific withdrawal, the deadline for carrying out the effective removal from the tax warehouse will be 5 calendar days, after which the authorization will expire and cannot be used.

In the event that the guarantee system used for that failed withdrawal had been the guarantee, the retained guarantee will be released once the tax warehouse confirms that that withdrawal has not actually taken place; If the advance payment was made using form 319, a refund of the payment made can be requested by requesting a correction of the corresponding self-assessment.

The deadline will be 5 calendar days from the date of departure of the goods.

You can deduct the sum of boxes 36 of all forms 319 corresponding to fuel deliveries guaranteed by advance payment that are included in the self-assessment.

That is, the amount of the advance payment corresponding to the State.

No. You must request the correction of form 319.

You must deduct the entire advance payment in form 303/322.

The one provided for in the annex of Order HAC/1497/2025, of December 17.

No, it will only be usable when the State Tax Administration Agency has inspection competence regarding the extractor.

In any case, the Administration that will be in charge of the registration and custody will be the one that holds the inspection competence –in the case raised, the AEAT– regardless of whether the taxation is shared or not.