Key questions on new requirements of invoicing software and hardware
Certain business owners and professionals—whether individuals or companies—must adapt their invoicing systems and software ("SIFs") in the coming weeks, to meet the new and approved technical specifications implementing the obligation under article 29.2.j) General Tax Act.
The deadlines for business owners and professionals to adapt these systems to meet the new obligations are as follows:
- January 1, 2026 for companies (corporate income tax taxpayers), and;
- July 1, 2026 for all other users of SIFs (personal income tax taxpayers, non-resident income tax taxpayers with permanent establishments, and tax transparent entities.
In the framework of this adaptation of SIFs, there are two options under the new regulations from which to choose one:
- basic option of "non-verifiable invoice issuing systems" or "NO VERI*FACTU" systems, or
- the option of "verifiable invoice issuing systems" or "VERI*FACTU" systems, in which the SIF is also used for automatically sending online to the Spanish tax agency all invoicing records corresponding to the invoices issued by the business owner or professional.
These new obligations must not be confused with the mandatory electronic invoicing that will be imposed on transactions between business owners and professionals (B2B transactions). They must also not be confused with the system for keeping VAT records through AEAT’s electronic office ("SII-VAT"), although there is a relevant exemption in the adaptation of SIFs in case they are affected by the SII-VAT.
In this Legal Flash, we will analyze key and recurring issues in this matter.
For more information, please contact our Knowledge and Innovation Area specialists.