On October 28, 2024, Order HAC7/1177/2024, of October 17, was published, which completes the regulatory development of article 29.2.j) of Law 58/2003, of December 17, General Tax Law, in relation specifically to the Computerized Billing Systems of Business Owners and Professionals.

The publication of this Ministerial Order marks the beginning of the maximum period of 9 months in which manufacturers and marketers of billing systems for entrepreneurs and professionals must market products adapted to the regulations. This maximum period does not prevent the marketing of adapted computer billing systems from being started earlier, since manufacturers and developers of billing systems have been permanently informed of the content of the technical annexes of this Ministerial Order during its preparation.

The publication of this Ministerial Order constitutes compliance with the development established in the  Third Final Provision of Royal Decree 1007/2003, of December 5 , whose most notable objectives are:

• Strengthen the obligation to issue invoices for all operations carried out by business people and professionals.
• Ensure that all operations carried out are recorded in the computer system in a secure, non-manipulable, accessible manner and with a standard structure and format to facilitate the readability of the records, automated analysis and simultaneous submission to the tax authorities.
• Facilitate compliance with tax obligations, as has been seen in those countries where the obligation to submit data prior to, immediately after or after carrying out operations has been implemented.

Royal Decree 1007/2023 establishes requirements that reinforce the security and integrity of billing records. This regulation details the attributes that billing systems must guarantee with regard to the integrity, conservation and legibility of data. In addition, it introduces the obligation to include QR codes and specific phrases in invoices issued by these systems. The purpose is to ensure the traceability and authenticity of invoices issued electronically, allowing for better supervision and verification by the tax administration.

Using a computer system for multiple taxpayers

When the same invoicing system is used by several taxpayers, it must operate as if it were a separate system for each of them. This involves independently managing the records of each taxpayer, creating individual record chains, functioning autonomously as a “VERI*FACTU” system for each one and clearly displaying the identity of the taxpayer in each ongoing operation. In addition, when the system supports multiple users, it must display their current status (registration, deregistration, etc.) through explanatory messages.

Features of the VERI*FACTU system

The “VERI FACTU” system  allows direct connection to the electronic headquarters of the Tax Agency, automatically sending billing records at the time of their issuance. This method guarantees the administration real-time access to the economic activity of companies, and systems labelled “VERIFACTU” are presumed to comply with legal requirements.

Requirements for submitting information to the State Tax Administration Agency (AEAT)

In order for computer systems to send billing records to the AEAT, they must comply with the following specifications:

• Be connected to the Internet to communicate with the AEAT electronic services.
• Manage electronic certificates for authentication and signing of records.
• Send the records in the format and with the stipulated security guarantees, automatically or in response to requests.
• Properly process the responses received from the AEAT.

Guarantees of integrity and unalterability of records

The regulations require that systems ensure the integrity and unalterability of records by generating a fingerprint or “hash” for each record, facilitating rapid verification. Records must be electronically signed, and the system must verify both the signature and the chain of records when they are retained in the system. If a breach of integrity is detected, the system will trigger an alarm and generate an event log detailing the incident.

Submission of billing records to the AEAT

When sending billing records to the AEAT, computer systems must be electronically identified using valid certificates, complying with the minimum authentication requirements established for the scope of Public Administrations. The submission can be carried out directly by the taxpayer or by an authorized representative.

Responsible declaration of computer systems

Each billing system must include a responsible declaration, prepared by the producer, guaranteeing compliance with the current regulations. This declaration must contain structured information about the system, including its name, identification code, specific version, components and functions, as well as specifying whether it complies with the regulation and is compatible with “VERI*FACTU”. It must also include the contact details and identification of the producing entity.

Starting and quitting the VERI*FACTU system

Systems can begin to operate as “VERI FACTU” at any time, but must remain in this status until the end of the calendar year.  To renounce the use of  “VERI FACTU”, the taxpayer must notify the AEAT of the last date of operation as such, sending this information before the last day of the year in which they wish to renounce it.

Entry into force

The regulation comes  into force on 29 October 2024. However, both providers and taxpayers will have to adjust their systems to comply with this regulation  from July 2025.