Requirements for systems and software supporting the invoicing process
For their part, the requirements to be adopted by the computer or electronic systems and programmes that support the invoicing processes of companies and professionals, in compliance with the provisions of the new letter j) of section 2 of Article 29 of Law 58/2023 of 17 December, General Taxation Law, in the wording given by Law 11/2021, of 9 July, have been developed in Royal Decree 1007/2023, of 5 December, which approves the Regulation establishing and standardising the formats of invoicing records, published in the Official State Gazette on December 6, 2023.
The purpose of this Regulation is to regulate the technical requirements and specifications to be met by any computer or electronic system and programme, hereinafter referred to generically as a computer system, used by those who carry out economic activities when supporting the invoicing processes of the operations corresponding to their activity, to guarantee the integrity, conservation, accessibility, legibility, traceability and unchangeability of the invoicing records without interpolations, omissions or alterations that are not duly noted in the systems themselves, with information on all deliveries of goods and services, in accordance with the provisions of Article 29.j).2 of Law 58/2003, of 17 December, General Taxation.
The aim is to align such computer systems with tax regulations to ensure that every commercial transaction generates an invoice and an entry in the taxpayer’s computer system and to prevent the subsequent alteration of such entries, allowing, where appropriate, the simultaneous or subsequent remission of the information to the tax authorities.
The obligations for the operation of e-invoicing systems included in the Regulation affect all invoices or equivalent supporting documents, including in particular the simplified invoice, and all companies and professionals. However, the regulation includes some exceptions. Specifically, they will not apply to those obliged to the Immediate Supply of Information (SII), nor to some cases of the agriculture, livestock and fisheries regime, nor to a series of operations excluded from the obligation to invoice.
Taxpayers must have the computer systems adapted to the characteristics and requirements established in the aforementioned regulation and its implementing regulations in place by July 1, 2025.
The Tax Alert available on this website provides more detailed information on the content of this Royal Decree.
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Ángel Baena Aguilar Partner - Barcelona
