VERI*FACTU and the New Billing Systems Regulation: Key Questions before 2026

As we have reported, the now imminent entry into force of the new Regulation on Electronic Billing Systems (RRSIF) and the VERI*FACTU model will introduce significant changes in how companies and professionals must issue, record, and store their invoices.

These obligations aim to strengthen the integrity, traceability, and security of billing information, as well as improve transparency in economic transactions.

Given the numerous questions the regulations are generating—both for software users and for developers and compliance officers—this document simply aims to summarize, in a classic question-and-answer format, the latest clarifications issued by the Tax Administration prior to its mandatory implementation in 2026.

To which computer systems and commercial documents does the regulation establishing the requirements for invoicing computer systems apply and affect?

• Computer Systems

This only applies to systems used for issuing invoices.

Conversely, it does not apply to other computer systems used to issue other types of supporting documents for the delivery of goods or the provision of services.

• Affected Commercial Documents

The only documents affected by this regulation are invoices, both "full or standard" and simplified. It does not affect any other type of supporting document for the delivery of goods or the provision of services.

However, although the strict requirements of VERI*FACTU do not apply to pro forma invoices or draft invoices, the requirements of the General Tax Law do apply. The use of systems that generate preparatory documents for invoices or simplified invoices is not considered legal and is subject to penalties if the computer system itself lacks control mechanisms for the storage of these preparatory documents in a manner properly linked to the invoices or billing records that are ultimately issued, ensuring they are recorded and stored within the system.

• Affected Groups

With the expansion made in question 4, initially and as explained, only those required to issue invoices will be affected.

However, if a group is not required to issue invoices but does issue some invoices using a Sif Invoicing System (SIF), then VERI*FACTU would apply.

Therefore, groups that do not issue invoices or issue them all manually, i.e., without using a Sif Invoicing System (SIF), will not be affected.

For example:

a) If only operations are carried out under the special scheme for agriculture, livestock, and fishing or the simplified VAT scheme, the Regulation would not apply, as these are all generally excluded from the obligation to issue invoices. However, compliance with the Simplified Invoicing System Regulation (RRSIF) will apply when using a Sif Invoicing System for the voluntary issuance of invoices related to operations exempt from the obligation to issue invoices. For these exceptional transactions, the system provided for this purpose by the Spanish Tax Agency (AEAT) on its website may be used, in accordance with Article 7.b) of the RRSIF (Regulations on the Simplified Tax Regime for Small and Medium-Sized Enterprises).

b) However, a pharmacy operating under the equivalence tax regime will be required to issue invoices because, when determining its economic activity according to the direct estimation method for Personal Income Tax (IRPF), it must issue invoices (Article 26 of the Regulations on Invoicing Obligations), regardless of its VAT regime.

What features does Royal Decree 1007/2023, which approves the regulations establishing the requirements for electronic invoicing systems, add to invoices and simplified invoices?

Royal Decree 1007/2023 incorporates a tax QR code to facilitate the communication of certain data to the Tax Agency.

Furthermore, if the SIF (Integrated Tax System) that issued the invoice is operating in the VERI*FACTU mode, the phrase "Invoice verifiable at the AEAT (Spanish Tax Agency) electronic office" or VERI*FACTU must also be included.

What is considered a billing information system?

A billing information system (BIS) is defined as the set of hardware and software used to issue invoices that accepts the input of billing information by any means, stores this information, and processes it to generate other related products.

A billing information system (BIS) is used to issue invoices by performing the following actions:

• Accepting the input of billing information by any method.

• Storeing billing information.

• Processing billing information to produce other results, such as the preparation of VAT ledgers, personal income tax ledgers, accounting records, or any other document used for compliance with tax obligations.

Therefore, the use of spreadsheets (Excel, Numbers, etc.) or word processors (Word, Apple Pages, etc.) will not affect the BIS if the word processors or spreadsheets are used exclusively for:

• Entering invoice data.

• Issuing and printing invoices.

• Maintaining billing information.

Conversely, it will be subject to the regulations and considered a billing system if, in addition to the functions mentioned above, it is used to process the billing information contained in the program to directly generate VAT ledgers, personal income tax ledgers, accounting records, or any other output used for voluntary compliance with tax obligations.

For example, if a user uses an Excel spreadsheet to generate simple lists of issued invoices, including totals or the use of other calculation rules, the regulations will not apply. However, if they use it by programming a macro to generate the ledger of issued invoices, their spreadsheet will be considered a billing system and, therefore, must comply with the requirements of the regulations.

The Tax Agency may verify whether word processors or spreadsheets used for issuing invoices meet the criteria of a billing system based on the capabilities and tools they use.

Who is affected by the regulations establishing the requirements for electronic invoicing systems?

Businesses and professionals—both individuals and legal entities—established in Spain who issue invoices, provided they meet the following four conditions:

• They do NOT invoice exclusively manually (without the aid of a SIF system). In other words, they must use a SIF system (as defined in the preceding point) to issue invoices.

• They are NOT subject to the requirements of the SII (Immediate Supply of Information), either mandatorily or voluntarily.

• They do NOT have their tax domicile in the Basque Country or Navarre. This is because, according to regional regulations, the obligation is defined based on the tax collection authority for direct taxation, which is determined by the tax domicile. In fact, in the historical territories of Gipuzkoa, Bizkaia, and Álava, a system known as "TicketBAI" is being implemented in its various forms, with content similar to the VERI*FACTU system of the Regulation on Computerized Billing Systems.

• That they do NOT have a resolution in force stating that it is not applicable.

I am a self-employed individual who rents out homes and business premises: do I need to adapt my invoicing system to the regulations that establish the requirements for such systems?

With regard to Personal Income Tax (IRPF), it is necessary to determine whether the rental activity constitutes an economic activity or, conversely, is a source of income from real estate capital.

If the activity is not considered a business activity (according to IRPF criteria, not VAT), it will not be considered an economic activity and will not need to be adapted to VERI*FACTU.

In the case of joint ownership, the same criteria apply.

However, if it is a tourist apartment rental and additional services are offered, the rental income is considered income from economic activities, and therefore, the invoices issued must comply with the SIF system.

What is the difference between the SII (Immediate Supply of Information) and the regulations that establish the requirements for electronic invoicing systems? Does the computer system of a company included in the SII have to comply with the requirements of the regulations that establish the requirements for electronic invoicing systems?

These are different regulations with distinct obligations. The SII involves maintaining VAT ledgers through the Tax Agency's electronic portal. Meanwhile, the regulations that establish the requirements for electronic invoicing systems require that these systems implement certain security measures.

The scope of both systems is mutually exclusive; that is, those who comply with the SII are not required to comply with the regulations.

For this reason, a taxpayer can voluntarily opt for the SII and not apply the obligations of the regulations that establish the requirements for electronic invoicing systems by using the option provided in the census declaration form 036.

A store issues simplified invoices and at the end of the day generates a summary invoice of all sales. What should be done with these simplified invoices?

Simplified invoices are subject to the RRSIF (Regulations for Simplified Tax Regimes) and, in the case of VERI*FACTU systems, must be reported to the Spanish Tax Agency (AEAT). This is independent of whether a summary invoice or statement is generated at the end of the day as a summary, for the purpose of recording the day's sales in a single accounting entry or for business management.

Are online stores affected?

Yes. The conventional or virtual method by which goods are offered or delivered, or services are provided, is irrelevant to the mandatory application of the regulations included in the Regulation on Requirements for Electronic Billing Systems (RRSIF).

A group of companies with the same SIF (Tax Identification Number), where one is registered under the SII (Immediate Supply of Information) system and another is not, must the company registered under the SII comply with the regulations that establish the requirements for electronic invoicing systems?

The regulations consider taxpayers individually (not as groups) with regard to their invoicing obligations. Therefore, even if they belong to the same group of companies, they must comply with their invoicing obligations according to their individual status.

Are invoices issued by businesses or professionals residing in Spain to businesses or individuals abroad subject to the obligations established by the Regulation on the Requirements for Electronic Invoicing Systems (RRSIF), approved by Royal Decree 1007/2023?

Yes. All transactions for which businesses and professionals (natural or legal persons) are required to issue invoices in accordance with current regulations (especially the Regulation on Invoicing Obligations approved by Royal Decree 1619/2012) are subject to the RRSIF. This includes both exports and intra-Community supplies of goods and international or intra-Community services.

Are invoices issued by businesses or professionals not resident in Spain subject to the obligations established by the regulations governing the requirements for electronic invoicing systems (RRSIF), approved by Royal Decree 1007/2023, if they are issued in Spain?

Only when the non-resident business has a permanent establishment in Spain.

Can compliance with the requirements of the regulation establishing the requirements for electronic invoicing systems be delegated to a third party?

Yes. The material fulfillment of the obligations of the regulation, with the requirements set out in Article 5 of the ROF (Regulations for Electronic Invoicing), can be delegated to the recipient of the transaction or to a third party.

When the invoice is physically issued by the recipient of the transaction ("self-invoicing"), who generates the invoice registration to comply with the regulation establishing the requirements for electronic invoicing systems? How do they record the invoice in their respective VAT ledgers?

With regard to the obligations imposed by the RRSIF (Regulations for Electronic Invoicing Systems), if the supplier has delegated the physical issuance of the invoice to their client, it is the client who, in addition to physically issuing the invoice, must generate the invoice registration required by the RRSIF. However, if the client maintains their invoicing ledgers using the SII (Immediate Supply of Information) system, they are exempt from complying with the obligations established in the RRSIF for these transactions.

Can the same electronic invoicing system (SIF) be used to handle the invoicing of several entities required to issue invoices (OEF)?

Yes, but with certain conditions. This is permitted provided that each taxpayer's invoicing records are kept separate and that the requirements stipulated in the RRSIF are met separately for each taxpayer. In other words, the system must function as if it were a "dedicated" and independent SIF for each OEF.

A company has two billing centers, one central and one at a different location, which are not connected to each other. How can the sequential billing sequence be maintained between both centers?

If all the aforementioned computer systems independently issue invoices, each with its own QR code, both systems will be considered independent electronic billing systems (EIBS).

To issue their own invoices, they do not need to know which invoices are being issued by other EIBS of the same company, as they are independent for this purpose and do not need to be "connected or communicating" with each other.

A company has two billing centers, one central and one at a different location, which are not connected to each other. Is it possible for one of the systems to be a VERI*FACTU system and the other not?

Yes, since both EIBS can comply with the standard in different ways.

However, if only one SIF (Tax Information System) is available, it cannot be used for some invoices and not others: it must be used for all activity, and therefore VERI*FACTU will be used for all invoices issued by that company.

How should an invoice (billing record) with errors generated in a billing system be corrected?

A billing record with errors must be corrected by generating a new billing record and, if applicable, submitting it to the VERI*FACTU systems.

According to the record design published in the Ministerial Order and already available on the AEAT (Spanish Tax Agency) website, this new billing record must have "Record Type" = "Substitute" and the "Corrects Error" indicator set to "Y". This does not affect traceability.

What data in a billing record can be modified without affecting its integrity and immutability? Can data that is not part of the digital fingerprint be modified?

Any data that the billing regulations do not require the issuance of a corrective invoice can be rectified.

At what level should the traceability required by the regulations and the order "requirements for electronic invoicing systems (SIF)" be implemented: taxpayer (OT), store, point-of-sale terminal (POS)...?

When a taxpayer operates with several POS terminals—whether in one or several establishments—and each one issues or manages its own invoices independently, each POS terminal is considered an independent SIF according to the regulations. Therefore, each POS terminal must have its own invoice registration chain (RF). Thus, the taxpayer will have as many chains as POS terminals used.

In the case of businesses with multiple terminals, each of which is a SIF, it is possible to have two payment terminals: one with the VERI*FACTU system and another with a system for issuing non-verifiable invoices. Therefore, a business can operate with several different SIFs if its needs require it. However, each system must be consistent with itself:

• The VERI*FACTU SIF must always send the RFs.

• The non-verifiable SIF (Invoice Management System) must retain its records without cross-referencing.

What cannot be done is to mix different methods within the same SIF.

In the case of a SIF that manages the invoicing of multiple taxpayers (for example, a SIF used by an accounting firm to handle the invoicing of several OTs (Taxpayer Identification Numbers) that are its clients), a separate chain must be created for each taxpayer whose invoicing it manages.

In the invoice information system (SIF) installed in an ERP system, there are "n" different modules (each with a different invoice series) that issue invoices: is it necessary to link all invoices using a single chain for the entire company? Could a separate chain of invoice records be created for each module?

The fact that all modules belong to the same ERP system implies their interconnection within a centralized system. Therefore, all records must be linked in a single SIF, regardless of the invoice series or number.

However, if the modules are independent and do not share internal functions, they can be considered separate SIFs and generate their own chains and, if applicable, their own submissions.