On November 6th, 2023, the Spanish tax authorities (AEAT) hosted a webinar tailored for software developers and vendors. During this session, they shared various updates regarding the Computerized Invoicing Systems (SIF), Veri*Factu, and the mandatory adoption of electronic invoicing. Let's delve into the essential highlights from the event.

Computerized Invoicing Systems (SIF) and Veri*Factu

The Anti-Fraud Law pertains to Computerized Invoicing Systems, commonly referred to as SIF (Sistemas Informáticos de Facturación in Spanish). Essentially, SIF include all management, invoicing or control programs or software that enable the issuance of invoices, such as ERP, PMS, POS, ISV... It is mandatory that the systems of those software vendors align with the Anti-Fraud Law. For further insights on how we can assist you in this regard, please click here.

In terms of regulatory updates, the tax authorities have communicated specific dates for the implementation of VeriFactu:

9 months from the publication of the Ministerial Order:

• That’s the deadline when software developers and vendors (SIF) must fully adjust their services to meet the technical requirements specified in the regulation. 
• Simultaneously, the Administration also commits to a 9-month period to prepare itself technically for the upcoming changes. Consequently, after this 9-month period, the service for receiving invoicing records from Verifiable Invoice Issuing Systems will be available at the servers of the National Tax Agency (AEAT).

July 1st, 2025: 

• This date marks the deadline for taxpayers to use operational Computerized Invoicing Systems (SIF) that are adapted to the characteristics and requirements outlined in the Regulation. It's important to note that the Regulation is still in draft form and has not been definitively published.

We are currently awaiting the publication of both the Regulation and the Ministerial Order.

Regarding technical development, they have outlined several changes in the draft designs for the registration, modification and cancellation of invoices in the Developer Portal.

The key modifications include:

• Substitute Registration: an option is introduced to make changes to an invoice record already transmitted to the AEAT. This process is applicable when there's a need to correct data not present in the invoice, impacting only the content of the XML file. For instance, rectifying an error in the VAT regime. It's worth noting that if any changes are required within the invoice itself, issuing a corrective invoice is recommended over using this option.
• Substitute Cancellation: the option to make changes to a cancellation invoice record is also introduced.
• Consequently, there will be a total of five invoice dispatch types: initial registration, substitute registration, initial cancellation without a prior record, initial cancellation, and substitute cancellation.
• The record layouts will undergo modifications to incorporate these changes and to provide clarity on the billing system during operation, specifying the type of record in each instance.

SIF: how to comply with the Anti-fraud Law and VeriFactu?

It's important to note, as highlighted by the National Tax Agency (AEAT) last week, that there are two avenues for taxpayers to adhere to the Anti-Fraud Law. Both approaches impact the management and invoicing software (SIF):

• All computer systems must ensure invoice registration in accordance with the standard. In this scenario, the systems themselves must meet security and control features at a higher level of rigor (ensuring preservation, immutability, and unalterability of records), and this responsibility falls under the purview of the certifying manufacturer.
• Additionally, the software should provide the capability to automatically send invoices to the AEAT in real-time, adhering to the standard, using a system for issuing verifiable invoices—essentially, a VeriFactu system. In this case, the presumed security requirements are met.

What are the requirements for software vendors to comply with the Anti-Fraud Law and VeriFactu?

Software developers and vendors (SIF) must fulfill three primary requirements. First, they must generate an invoice record for each issued invoice. Second, they must provide the option of sending these records in real time to the Tax Agency. Lastly, they need to ensure compliance with security and control features, particularly for invoicing records, along with the adoption of standard data formats.

During the discussion, the possibility of the AEAT offering taxpayers a basic invoicing platform was also considered. This platform, if implemented, would adhere to the same requirements outlined in the Anti-Fraud Law.

Here is a reminder of the key security and control features that SIFs must adhere to:

• Include a QR code on the invoice for easy verification at the AEAT
• Calculate the fingerprints of the content of the invoice records, chaining them together.
• Electronically sign the invoice records

Optionally, SIFs should provide the capability of sending invoicing records to the Tax Administration in real time using verifiable invoice issuing systems: Veri*Factu systems.

Mandatory B2B electronic invoicing in Spain

While we are still awaiting for the official publication of the technical requirements for the mandatory implementation of B2B electronic invoicing, the anticipated effective date for software vendors under the Crea y Crece Law is one year from the publication of these requirements.

In the session, the AEAT reiterated the primary aspects of the electronic invoice obligation in Spain for all B2B transactions:

• All private e-invoicing platforms are required to adhere to the provisions of the Royal Decree. They must establish interconnectivity among themselves and also integrate with the public e-invoicing solution (SPFE: public electronic invoicing system, in Spanish Solución Pública de Facturación Electrónica).
• Electronic invoices must conform to a structured format based on the semantic data model EN16931 set by the European Committee for Standardization. This format should be in one of the following syntaxes: CII, UBL, FACTURAE, EDIFACT.
• Electronic invoices must detail the status of each invoice, with a particular focus on payment reporting to enhance late payment monitoring. Payment information to the SPFE is mandatory, ensuring that the SPFE can transmit it, at the very least, to the State Observatory of Private Delinquency.
• The public e-invoicing solution (SPFE) can be utilized for both issuing and receiving invoices by the issuer and receiver, exclusively by one of them or, if they are not using it, a copy of the invoices issued through a private platform should be mandatorily sent to the SPFE.
• Other aspects covered include the modification of the Regulation governing invoicing obligations, means of issuing invoices, and ensuring the authenticity and integrity of electronic invoices, among others.

Although no specific updates were announced regarding the project status for SIFs and taxpayers, it did clarify the non-tax responsibilities that the AEAT will assume in the control of electronic invoicing. Here are the key points:

• Development of a Public Platform: the AEAT will be responsible for developing the Public Electronic Invoicing Solution (SPFE - Solución Pública de Facturación Electrónica). Invoices on this platform will use the Facturae format, and it will aggregate all B2B transaction invoices in Spain.
• Statistical Analysis: the AEAT will conduct a statistical analysis of the electronic invoices received in the SPFE. This analysis aims to monitor the impact of the new regulations on commercial defaulting. The AEAT will share this information with the State Observatory of Private Delinquency and the Ministry of Economic Affairs and Digital Transformation.
• Free application for small companies: the AEAT will provide small companies and professionals with a free application or form. This tool will enable them to issue electronic invoices and submit them to the public electronic invoicing solution (SPFE).

It's important to note that while the National Tax Agency (AEAT) will directly intervene in controlling compliance with the Anti-Fraud Law, this won't be the case for the Crea y Crece Law and the obligation to issue B2B electronic invoices.

Do software vendors (SIF) need to comply with both the Anti-Fraud Law and the Crea y Crece Law?

In the session, the AEAT emphasized that the objectives of both regulations serve distinct purposes. The Anti-Fraud Law is designed to prevent, mitigate, and diminish tax fraud, while the Crea y Crece Law prioritizes the digitalization of businesses and the Spanish Administration, along with combating late payments.

It was stressed that software vendors (SIF) must comply with both regulations, but they are to be treated as separate and independent initiatives. 

However, the AEAT expressed interest in aligning common elements between the two regulations to facilitate implementation by SIFs, such as a unified invoice identification and semantic elements. While they hinted at the potential for more shared technical requirements, they cautioned that this would need further modifications to the regulations.

Veri*Factu and mandatory electronic invoicing implementation

Are you a software vendor falling within the category of an Invoicing Information System (SIF)? This includes all software for management, billing or control, enabling invoice issuance (such as ERP, PMS, POS, ISV…). In that case, compliance with both the Anti-Fraud Law and the Crea y Crece Law is mandatory for you.

​​By integrating fiskaly's SIGN ES fiscalization software, you will ensure compliance with these two regulations, both the Anti-Fraud Law and the Crea y Crece Law. In addition, if your customers operate in the Basque Country, you will also comply with the mandatory tax reporting regulations of the regional tax authorities: TicketBAI. Thus, with just one integration, you will avoid having to integrate a different VeriFactu API, an API for electronic invoicing and a TicketBAI API for each regulation. Our SIGN ES API is fully documented and supported in 5 languages.

Are you the person who prefers trying things first? Do you want to get deeper on what your company needs? We understand that! Let's talk and try our API for free.