Always-Connected-to-the-Internet Environment

Question to the AEAT:
One of our software products has the ability to operate in offline mode.
It is on the central server where the VeriFactu file and the chaining of the records would be created, since the database is centralized.
If this software does not have a connection to the central server, would it be correct for it to continue invoicing and generating the QR code on its own without waiting for the response from the central server? Later, when it reconnects, it would send the invoice data for processing by the server.
This means the invoice issuance date and the FechaHoraUsoGenRegistro could differ if the disconnection lasts more than a day.
In these cases, is it enough to mark the submission with field “Incidencia” set to “S”?
Would the software have to stop invoicing if the component that generates the VeriFactu records is unreachable?

Answer:
The architecture described in the inquiry is not contemplated by the regulation approved by Royal Decree 1007/2023 and could imply non-compliance, especially if the desired modality is VERI*FACTU (i.e., immediate submission of billing records: RFs).

According to the description, the billing IT system (SIF) consists of two components:
- Component 1: software capable of entering billing data, issuing invoices, and generating the QR code. This software can work offline.
- Component 2: a database software located on a central server, which receives information from component 1, generates the billing records and their chaining, and from which the submission to AEAT would occur under the VERI*FACTU modality.

The fact that the chained record is generated systematically after the invoice is issued with its QR (given that component 1 may operate disconnected from component 2) is incompatible with the regulation.
Under Article 9 of the RRSIF (see below), the generation of the billing record must occur simultaneously or immediately prior to invoice issuance. While short delays (seconds) due to connection implementation may be acceptable, the proposed habitual and prolonged disconnection is not acceptable.

From the perspective of the regulation’s purpose, such disconnection may result in reprocessing invoices: invoices are issued on one side, and RFs are generated later. This could only be mitigated if the TPV contained all preconfigured RF information fully mapped to the Central Server—and such mapping is clearly documented and certified—and if the connection between components is permanent and guaranteed.

In addition, allowing disconnections “lasting more than a day” between components is unacceptable given the availability of 5G networks and cheap, reliable mobile connections today.
While the regulation considers possible connection errors between the SIF and AEAT, it does not contemplate internal SIF disconnections. This is especially critical when the component generating RFs and chaining is the one disconnected.

In conclusion, any multi-component architecture must guarantee permanent, stable, unavoidable interconnection. This becomes absolutely essential when the central system generates the billing records. Therefore, the SIF must ensure constant connectivity (short technical interruptions aside).

Article 9. Generation of the billing record (RF Alta).
Billing systems must automatically generate a billing record simultaneously or immediately prior to issuing each invoice.