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Billing Software Compliance with the Legislation

Billing Software must comply with current the legislation, and more specifically with:

  • Royal Decree 1619/2012, which regulates the content and formal requirements of invoices. Mandates that Billing Software comply with the following:

    • Issue invoices with the following legally required information:
      • Number and series.
      • Date of issue.
      • Date of operation, if different from the date of issue.
      • Issuer's tax identification number (NIF) and company name.
      • Recipient's tax identification number (NIF) and company name, when required.
      • Description of the transaction.
      • Taxable amount, applicable VAT rate, VAT amount.
      • Total amount.
    • Maintain sequential numbering:
      • The number cannot be changed manually.
      • The sequence must not have any gaps.
      • Different series are permitted, for example, by year, type of transaction, or location.
    • Allow invoice types:
      • Full.
      • Simplified.
      • Corrective. Corrective invoices have a new number, a reference to the original invoice, and the original invoice is NOT altered.
    • Do not allow deletion or modification of invoices.
    • Guarantee retention for at least 4 years (tax period) and access.
    • Ensure authenticity and integrity in electronic invoicing.

  • Royal Decree 1007/2023, which regulates how the software must behave to guarantee the integrity, traceability, and immutability of invoices. Mandates that Billing Software comply with the following:

    • Integrity and security of records, through chained hashes and electronic signatures. → It is managed by SDH.
    • Record format standards to facilitate data analysis and submission. → It is managed by SDH.
    • Software providers must visibly include a declaration of responsibility stating that the software complies with the regulations.
    • A record (according to AEAT specifications) must be generated for each invoice (issued, corrected, or cancelled).
    • Once generated, the record is unalterable and can only be corrected by creating a new record (corrective invoice).

WHEN SHOULD THE INVOICE BE ISSUED IN VERI*FACTU?

From RD 1619/2012:

Type Expedition time Example
Operations with individuals (B2C) At the time of carrying out the operation, that is, when the goods are delivered or the service is provided In-store sale → invoice at that same time
Punctual service → invoice upon completion of service
Transactions between businesses or professionals (B2B) Before the 16th of the month following the accrual of the VAT Service provided on March 10 → Issue deadline: April 15
Simplified invoices (tickets) At the time of the operation

When an invoice is issued, the Veri*Factu system must:

  • Automatically generate the billing record at the exact moment of issuance, with the exact date and time, and with a hash and chaining.
  • Send this record to the Spanish Tax Agency (AEAT) immediately or almost immediately. It does not wait until the end of the day or month.
  • Include a QR code and Text on the invoice indicating that it was issued in Veri*Factu mode.

In a SIF that includes SDH:

  • The Billing Software sends the invoice data to be issued to SDH.
  • If the invoice data is correct, SDH performs the chaining and provides the QR code.
  • The Billing Software prints the QR Code and Text.
  • SDH generates the billing record and sends it digitally signed to the Spanish Tax Agency (AEAT).
  • The Billing Software queries SDH to confirm whether the invoice has been accepted by the AEAT.

THE SOFTWARE CANNOT:

❌ Have a "hidden mode".
❌ Allow double accounting.
❌ Allow tax erasure.
❌ Alter records without leaving a trace.
❌ Redo numbering.

❌ You CANNOT issue an invoice "on a deferred basis." For example, issuing an invoice today with yesterday's date.
❌ You CANNOT change the date after issuance, for example, to reconcile accounting.

Veri*Factu detects:

❌ “I save receipts and then generate invoices”.
❌ “I change the date to make the quarterly calculation work”.

⚠️ Penalties for non-compliance:

  • Up to €50,000 per fiscal year for users.
  • Up to €150,000 per software for manufacturers.
  • Fines are cumulative.