On October 17th 2024, Spain published a ministerial order detailing strict technical and functional requirements invoicing and accounting systems must meet. It primarily affects small and medium-sized businesses, mandating technical upgrades to software systems for certifying and securely submitting invoices and event logs to the Spanish tax authority.

Additionally, the Order introduces changes to Royal Decree 1619/2012, by introducing QR code requirement and a procedure for invoice recording.

Timeline

The effective date for the application of these rules are currently set for July 1, 2025. However, a potential delay is expected.

Impact

Taxpayers impacted by these requirements are small and medium size businesses who are currently not obliged to comply with SII (invoice data reporting obligation). Namely, businesses with a revenue threshold under EUR 6.000.000 and not in scope of SII must comply with billing software requirements.

Billing software must comply with the following rules on a high level:

• Data Integrity and Immutability: Ensure invoicing records are unaltered and secure, using hashing and electronic signatures for verification. The order specifies that electronic signatures used in billing software must be qualified. This means they must be generated using a qualified electronic certificate from a trusted provider, ensuring a high level of security and legal validity.
• Traceability: Maintain a continuous, traceable chain of invoicing records with time-stamped links to previous entries, ensuring chronological order and completeness.
• Accessibility and Legibility: Guarantee records are readable and in standardized formats, with easy retrieval for audits or submissions to the tax authority.
• Certification Compliance: Obtain certification that the software meets all regulatory standards set by the Spanish tax authority.
• QR Code and Additional Elements: Include a QR code on each invoice, allowing verification of the record on the Spanish tax administration’s portal, along with any required identification phrases.
• Event Logging: Record all key system activities (e.g., start-up, exports, error detections), and preserve event logs to maintain operational transparency.
• Structured Data Submission: Enable the system to securely submit structured data files to the tax authority, especially for systems under "VERI*FACTU" compliance or in response to requests.