Application of RRSIF and Veri*Factu in accordance with RD 1007/2023 and RD 254/2025

As part of the measures adopted by the Spanish Tax Agency (AEAT) to strengthen the prevention of tax fraud, the Regulation on the Requirements of Invoicing Computer Systems has been approved through Royal Decree 1007/2023, complemented by Ministerial Order HAC/1177/2024. This regulation introduces a set of technical, functional, and control requirements that invoicing systems used by businesses and professionals must comply with starting in 2026.

At the same time, the VERI*FACTU system is defined as a voluntary and immediate method for submitting invoicing records to the AEAT. The overall aim of the regulation is to ensure the reliability and integrity of issued invoices, eliminating the possibility of alteration, omission, or subsequent manipulation.

Legal framework

1. General Tax Law (LGT): Articles 29.2.j) and 201 bis, introduced by Law 11/2021.
2. RRSIF Regulation: RD 1007/2023, amended by RD 254/2025.
3. Ministerial Order: HAC/1177/2024, which develops technical and operational aspects.
4. AEAT electronic office: Provides additional information and related services.

Obligated parties

The RRSIF applies to:

• All businesses and professionals issuing invoices under the common tax regime in Spain.
• Corporate Income Tax, Personal Income Tax (economic activity), and Non-Resident Income Tax taxpayers with a permanent establishment in Spain.
• Partially exempt Corporate Income Tax entities, for taxable and non-exempt income-generating operations.

Excluded:

• Subjects under the Immediate Supply of Information system (SII).
• Companies without a permanent establishment in Spain.
• Foral territories (use their own system: TicketBAI).

Entry into force

• From January 1, 2026, for companies subject to Corporate Income Tax.
• From July 1, 202,6, for self-employed and other obligated parties.
• The AEAT will implement validation and submission systems before July 29, 2025, allowing for early adaptation.

Invoicing computer systems (SIF)

SIFs are the programs or platforms used to generate and store invoices. There are two types under the regulation:

1. Invoice issuance system with verifiable invoices (VERI*FACTU)

Features:

• Issuance of invoicing record with digital fingerprint (hash).
• Immediate submission to the AEAT.
• Mandatory inclusion of a QR code on the invoice.
• No electronic signature or event log required.
• Users have access to automated assistance and record consultation services.
• Provides greater legal certainty, transparency, and simplifies compliance requirements.

2. Invoice issuance system with non-verifiable invoices (NO VERI*FACTU)

Features:

• Requires an electronic signature and an event log.
• Mandatory local system retention for four years.
• Does not allow direct voluntary submission.
• No access to automatic verification services or invoice cross-checking by the customer.

Taxpayers under the SII (Immediate Supply of Information) system are exempt from using Invoicing Computer Systems.

System functional and technical requirements

All SIFs must meet the following principles:

• Traceability: Chronological chaining of invoicing records.
• Integrity: Information immutability via hash calculation.
• Non-repudiation: Unquestionable identification of the issuing system, via electronic signature (except in VERI*FACTU).
• Retention: Local or external storage for the legally required period.
• Accessibility and Legibility: File Export in Standardized Formats.

In the case of non-VERI*FACTU systems, it is also mandatory to maintain an event log, automatically recording technical issues, restorations, exports, and other relevant actions.

VERI*FACTU system features

• Voluntary and immediate submission of invoices to the AEAT in a structured format.
• Automatic QR generation on each invoice for public verification.
• Clients can verify whether the invoice has been reported by scanning the QR code, reducing the risk of doubt or fraud.
• Verifiable invoices are stored in the AEAT electronic office, accessible by the issuer, recipient (if also using VERI*FACTU), and their authorized advisor.

Adaptation tools

• Free AEAT application: Available via its electronic office. Especially useful for freelancers and small businesses without software investment capacity.
• Digital Kit program: Public grants for acquiring or upgrading software in compliance with the RRSIF.
• Private software systems: Must be adapted to technical specifications and, where applicable, certified by developers.

Exclusion when not using computer systems

According to the regulation and AEAT guidelines, the Regulation on the Requirements of Invoicing Computer Systems (RRSIF) only applies when computer systems are used to issue or process invoices.

Therefore:

• Businesses or professionals issuing invoices manually—either handwritten or using pre-printed invoice books—are not required to comply with the RRSIF, as long as no computer system is used to generate, store, or process those invoices.
• Manual issuance alone does not trigger RRSIF compliance, unless those invoices are later managed through programs that generate tax books or process the information automatically.
• Consequently, exclusively manual invoicing is explicitly excluded from the RRSIF scope, and no technical adaptation is required unless IT tools that affect fiscal processes are incorporated.

This exclusion does not exempt compliance with general tax obligations, nor prevent voluntarily adopting compliant IT systems to improve traceability and activity control.

Analysis of the VERI*FACTU system

Main Advantages (PROS)

• Fiscal transparency: real-time submission to the AEAT, reducing errors and suspicion of fraud.
• No need to retain technical records once submitted.
• Legal certainty: lowers the risk of penalties or requests.
• Free access to the invoicing tool provided by the AEAT.
• Automatic verification via QR code by the client.
• Long-term savings by reducing inspections or information requests.

Main Disadvantages (CONS)

• Need for digitization: purchase of equipment or training if unprepared.
• Dependence on internet connection and the AEAT electronic office.
• Initial costs if opting for private software instead of the free version.
• Operational adaptation: internal process changes and staff training.
• Possible technical interruptions requiring monitoring and deferred submission.
• Potential inflexibility for mobile sales or informal business models.

Alternative

Taxpayers under the SII system are not required to use an Invoicing Computer System. Therefore, an alternative to avoid this obligation is to request inclusion in the SII (Immediate Supply of Information) and submit issued and received invoices to the AEAT within the established deadlines. This option avoids the need to file Form 347 and Form 390.

Penalties for non-compliance

• Non-compliant software: very serious infringement (Art. 201 bis LGT) – fixed fine of €50,000 per program and fiscal year.
• Invoices without QR / hash: formal infringement (Art. 201 LGT) – €150 per invoice, up to €6,000 per quarter.
• Obstructing the AEAT: proportional fine of 2% of turnover (minimum €20,000).

Conclusion

The new regulatory framework on invoicing represents a structural shift in how businesses and professionals must manage their tax obligations. Adopting the VERI*FACTU system not only anticipates legal compliance but also offers major advantages in terms of control, efficiency, and transparency.

Therefore, early planning of the transition is strongly recommended, evaluating the most suitable tools based on each company’s invoicing volume, technological capacity, and type of activity. Note that failure to comply with RRSIF obligations may result in severe administrative penalties as outlined above.