This post summarises the key points of the recent Spanish regulations on electronic invoicing, focusing on Royal Decree 1007/2023 and its implications for businesses and professionals. The new regulations, driven by Law 18/2022 (Ley Crea y Crece) and the Anti-Fraud Law, seek to modernise invoicing processes, improve tax compliance and fight fraud.
01) Main Objectives of the New Regulations
Digitalization and Modernization: Promote the adoption of digital billing systems in SMEs, micro-enterprises and self-employed workers, abandoning obsolete techniques.
“By combining both private and public objectives of digitalisation, this royal decree aims to achieve the modernisation of the digital provision of SMEs, micro-enterprises and self-employed workers, as well as an improvement in tax compliance and the fight against non-compliance.”
Improving tax compliance: Facilitating tax management, control and verification by the Administration, and assistance to taxpayers.
“In this sense, this Royal Decree represents a decisive step in the longer-term process of reforming the management of tax information and, with it, taxpayer assistance services, with the aim of ultimately facilitating administrative simplification for taxpayers.”
Fight against tax fraud: Make data manipulation and tax evasion more difficult by requiring secure and unalterable computer systems.
“In fact, the practical examination of these computer systems has shown that, on occasions, they facilitate, through digital tools specifically designed for tax evasion or fraud, the concealment of the true economic and tax reality of their users…”
Standardization: Establish common formats for billing records, facilitating their readability and analysis.
02) Key Requirements for Billing Computer Systems
Royal Decree 1007/2023 details the technical specifications that computer billing systems must meet:
Integrity and Inalterability: Records cannot be modified or deleted without leaving a trace. Any correction must be an additional record.
«The computer system must guarantee: a) The integrity and inalterability of the billing records so that, once generated and recorded, they cannot be altered without the computer system detecting and notifying of this.»
Traceability: Records must be linked and verifiable in their creation sequence. Data must be dated.
“The traceability of billing records, which must be linked so that their trail can be verified by following their creation sequence from the first to the last.”
Conservation, Accessibility and Legibility: Records must be stored for the legal period, and be accessible and legible in electronic format.
“The conservation, during the period provided for in Law 58/2003, of December 17, General Tax Law, as well as the accessibility and legibility, of all billing records generated by the computer system itself.”
Responsible Declaration: Software producers must certify, by means of a responsible declaration, that their systems comply with the legal requirements.
«It will be the responsibility of the person or entity producing the computer system to certify, by means of a responsible declaration, that the computer system complies with the provisions of article 29.2.j) of Law 58/2003, General Tax Law, as well as with the provisions of this Regulation…»
Digital Fingerprint and Electronic Signature: Records must include a digital fingerprint (hash) and electronic signature to ensure their authenticity.
“The computer systems indicated in article 7 of this Regulation must add a fingerprint or “hash” to the registration and cancellation billing records…”
03) VERIFACTU: The Verifiable Invoice Issuance System
Concept: It is a system that allows the automatic and immediate sending of billing records to the AEAT, guaranteeing compliance with the regulations by design.
“Those computer systems… that, complying with all the obligations imposed by this Regulation… are used by the taxpayer to effectively send by electronic means to the State Tax Administration Agency… all billing records generated will be considered “Systems for issuing verifiable invoices”…”
Optional but Advantageous: Its adoption is voluntary, but it implies a lower level of obligations for the taxpayer.
Benefits: Greater transparency, reliability, customer confidence (with QR code generation and tracking possibility).
“Verifiable invoices: greater prestige and reliability and generation of customer confidence: QR generation, tracking possibility…”
04) Two Modalities: VERIFACTU vs. NO VERIFACTU
Companies can choose between two modalities:
Verifactu : Automatic sending of billing records to the AEAT. Fewer obligations for the user.
No Verifactu : Local registration and storage of invoices, to be submitted only if required by the AEAT. It involves more obligations to guarantee the integrity of the records.
05) Mandatory Content of Billing Records: Billing records must contain detailed information such as:
- Sender and receiver data.
- Invoice number and series.
- Dates of issue and operation.
- Invoice type (complete or simplified).
- Operation overview.
- Total amount.
- VAT information.
- Computer system code.
- Date and time the record was generated.
- Fingerprint of the previous registration.
06) Implementation Deadlines
- Producers and distributors of those SIFs (Computerised Invoicing Systems) must offer their products fully adapted to the regulations within a maximum period of nine months from the entry into force of the ministerial order developing the technical specifications of the requirements imposed on SIFs. Deadline: 29/07/2025.
- Companies and self-employees who issue invoices to those affected by the regulation must have their computerised invoicing systems (SIF) up and running, adapted to the characteristics and requirements established therein and in its implementing regulations, before 1 January 2026, if they are subject to corporate tax, and 1 July 2026 for all others
07) Scope of Application
Subjects: Applies to entrepreneurs, professionals and entities that carry out economic activities (IRPF, IS, IRPFNR with permanent establishment) . Does not apply to those who already keep their records through the SII.
“This Regulation shall apply to taxpayers…who use computerized invoicing systems…”
Territory: Applicable throughout the Spanish territory, with exceptions in special tax regimes (Basque Country and Navarre) and specifications for the Canary Islands, Ceuta and Melilla.
Exceptions: Certain operations are excluded, such as those under the special agricultural regime and some operations exempt from invoicing.
08) Possibility of Voluntary Submission by the Recipient: The recipient of the invoice can send information to the AEAT by scanning the QR code, facilitating control and transparency.
09) Conclusion: The implementation of electronic invoicing in Spain is a significant change that seeks to promote digitalization, efficiency and transparency in business operations. Although there are challenges and concerns, the new regulations present opportunities to modernize business practices and improve tax compliance.
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