Frequently asked questions (FAQ)

This question refers to the computer resources necessary to carry out such compliance and the answer is found in article 7 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.

It can be summarized as follows: you should use a computerized billing system (SIF) adapted to the RRSIF , which could be:

• SIF existing on the market, free or paid: Article 7.a). It could be installed on the premises of the person issuing the invoices ( on-premise ), remotely, or in the cloud ( cloud ).
• SIF developed internally by the invoice issuer: Article 7.a).
• The basic billing application that the Tax Agency will offer free of charge on its electronic site, as long as its functionalities and conditions of use meet the needs of whoever is going to use it: Article 7.b)

Finally, it is recalled that there is the possibility of delegating to a third party or to the recipient of the operation the material issuance of the invoices, which must be carried out in compliance with RRSIF . There are other FAQs that deal with this aspect.

Although it is not mentioned in the RRSIF , it should be noted that the deadline for submitting applications for SEGMENT III (between 0 and 3 employees) of the DIGITAL KIT has been extended until 10/31/2025. This Program is funded by the Recovery, Transformation and Resilience Plan and aims to promote the “SME Digitalization Plan 2021-2025”. The maximum amount of aid per beneficiary will be two thousand euros (€2,000). And among the financeable solutions is Process Management, which includes Billing Computer Systems.

On the other hand, the SIF Regulation (approved by RD 1007/23) provides in its article 7.b) the creation of a computer application that will be developed by the tax administration and that will serve to comply with Regulation SIF in its VERI*FACTU mode. This application could also be used in the future to facilitate the issuance of B2B electronic invoices.

In short, you should:

• Guarantee the integrity, conservation, accessibility, legibility, traceability and inalterability of the billing records that you are required to generate for each invoice issued, in the terms of RRSIF and its OM , generating an invoice registration file for each of those issued. In addition, a QR code must be printed under specifically regulated conditions.
• Have the ability to communicate with the AEAT for their referral.
• Furthermore, if personal data is processed, it must comply with the measures provided for in the legislation on data protection, for which it must dissociate or separate access to tax information from other types of confidential information, so that the Tax Agency can access the former.
• Finally, the SIF must record certain events that occur in it (unless it is a SIF operating in VERI*FACTU mode).

Specific details on how these requirements are to be implemented are clarified in other FAQs.

Regulations/Doctrine:

• Article 29.2.j) of Law 58/2003, of December 17, General Tax Law.
• Articles 7 and 8 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.

Yes, but with certain conditions. In article 7.a) 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, such a possibility is provided for as long as the billing records of each taxpayer are differentiated and the requirements demanded in RRSIF are met separately for each of the taxpayers. That is, the system must behave as if it were a SIF "own" and independent for each OEF .

This means that you must separately manage the billing records and, where applicable, the event records of each OEF included in the SIF , complying with the requirements set forth in articles 7.a) and 8 of the RRSIF , with independent linking for said records of each OEF . Likewise, it must be able to allow the operation of the SIF in the "VERI*FACTU" mode independently for each OEF . Additionally, you must clearly and at all times display the identifying information of the OEF to which the operation being carried out at any given time corresponds. Furthermore, in the event that you are actually supporting the billing of more than one OEF , regardless of the operational status they are in, whether high, low or any other, you must indicate this with an explanatory message that can be consulted quickly, easily and intuitively. 

Regulations/Doctrine:

• Articles 7 and 8 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 2 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. Any functionality or mechanism of the SIF that allows billing records to be altered once the invoice or the trail of operations has been generated constitutes a breach of the requirements demanded by the regulation.

For these purposes, alteration of billing records means the concealment or elimination of any billing record originally generated and recorded by the computer system, or the concealment or modification, in whole or in part, of the data of any billing record originally generated and recorded by the computer system, or the addition of simulated or false billing records other than those originally generated and recorded by the computer system.

Any need to correct or cancel the mandatory data recorded must be carried out using the procedures regulated in the regulation and its ministerial order, generating at least one additional billing record afterwards, so that the originally recorded and corrected data remain unchanged.

Regulations/Doctrine:

• Articles 8.2.a) and 8.2.b) 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 limitation is given by the operation of entering the information contained in the form. It is logical that this subsidiary use application is used by micro-entrepreneurs or professionals with a limited number of invoices issued per year.