Compliance with the Veri*factu Ordinance

According to Royal Decree 1007/2023 of 5 December (the, so called, “Veri*factu Ordinance”), companies that operate in Spain, in case of non-resident only when having a permanent establishment for direct tax purposes, are obliged to use an invoicing software that complies with the technical standards regulated therein:

 New functionalities required for the invoicing software:

 

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Companies within the scope of the Veri*factu Ordinance must use an invoicing software which has certain functionalities it details, namely:

  • Obligatory invoicing registers: A register of issued invoices and a register of annulations which contain are to be time stamped and electronically signed.
  •  E-reporting capability: Be able to report electronically to the tax authorities all the entries generated to the obligatory registers in a continuous, secure, accurate, automatic, consecutive, instantaneous, and trustworthy way.
  •  Conservation of registers: The obligatory registers must be maintained during the lapsing period foreseen in the General Tax Law and be accessible and legible. They must also have a procedure for the downloading and secure storage of all the entries, allowing them to be exported in a legible electronic format to an external storage system.
  •  Log of incidences: Keep an accessible automatic real-time register of internal events and incidences.

Dead-line: 

The original deadline for using a compliant invoicing software is the 1st July 2025, however a postponement is expected 

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until 1st January 2026 for companies subject to Corporate tax (the 1st July 2026 in any other case, i.e. entrepreneurs subject to the Personal Income tax and non-resident companies operating through a permanent establishment for Non-Resident Income tax purposes).

 Software developers and software distributors must adapt their products to the Veri*Factu Ordinance by 1 July 2025.

Possible adaptation issues: 

The use of a compliant invoicing software may not represent a problem when the company uses any of the standard ERP or accounting applications commercialized in the Spanish market, since the providers are obliged to conform their products to the standards of the Veri*factu Ordinance.

The situation may not be so straightforward for Spanish subsidiaries or branches of multinational companies, in certain cases

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namely:

  •  The invoicing application that is used is not flexible enough to adapt to the specificities resulting from the changes in the local technical invoicing regulations of a country, such as the Spanish Veri*factu Ordinance.
  •  The adaptation may involve a consumption of time or resources that should not be in line with the IT priorities of the company.

 

Our services

We can help companies which may have problem to adapt their invoicing software to the Veri*factu Ordinance in any of the following ways:

Identifying the best line of action to adapt to the Veri*factu Ordinance: 

We can help the company in the process to decide as to the best line of action, among the existing possible alternatives:

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  • Upgrading the internal invoicing software so it is enhanced with those features that are required by the Veri*factu Ordinance.
  • Integrating an external compliant invoicing solution.
  • Externalizing the invoicing function with a third-party compliant service provider.
  • “Opting out” of the scope of the Veri*factu Ordinance, by applying for voluntary compliance with the SII.

In our opinion, the line of action to be adopted by the company as regards the adaptation of its invoicing software to the Veri*factu Ordinance requires an analysis which focusses, not only in the specific domestic regulations, but also takes into account a wider scenario that considers the future impact resulting from the changes that are taking place at an international level in the areas of e-reporting and e-invoicing (i.e. as may be the case in Europe when the plan ViDA is implemented).

Making the invoicing software compliant with the Veri*factu Ordinance: 

We your invoicing software compliant for the case that you have problems escalating its invoicing software with the new features required

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Either via licensing or as SAAS, we can enhance your invoicing software with the following required functionalities:

  •  Generation of the register of issued invoices and register of cancellations.
  •  Real time e-reporting capability of the entries to said registers to the Spanish Tax Agency, for the case that the company what its invoicing software to be qualified as a “Veri*factu system”.

Making the invoicing software a “Veri*factu system”: 

To be qualified as a “Veri*factu system” the invoicing software must report electronically at the site of the Spanish Tax Agency in a real time basis all the entries to the register of issued invoices and register of annulations. We can enhance your invoicing software with such functionality, either via licensing or as SAAS.

A ”Veri*factu system is releases from some of obligations otherwise required …

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An invoicing software which complies with the requisite of reporting in a real-time basis the data of its registers to the tax authorities is allowed to include the mention “Verifiable system” or “Veri*factu system” (“Sistema verificable” o “Sistema Veri*factu”), and excluded from complying with the following requisites which otherwise would apply, namely:

  •  The tax authorities cannot request a copy of the invoicing registers.
  •  The entries to the registers need not to be electronically signed.

“Opting out” of the Veri*factu Ordinance:  

Given the incompatibility of both obligations, companies meeting the conditions to be within the scope of the Veri*factu Ordinance and so obliged to use compliant invoicing software would have the option to “opt-out” of it by exercising the option to voluntary application for the Spanish e-reporting system (the so called SII or “Suministro Inmediato de Información”).

We can help you to file the voluntary application for the Spanish SII and provide a “SII outsourcing service” so to comply with the SII reporting obligations on your behalf. See more about the scope of our service here

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The scope of this service will include:

 – aking care of the SII reporting obligations on behalf of the company based on its ERP VAT standard reports, once they have been previously mapped in our reporting solution ComplianceSII.

Dealing with the errors and corrections resulting from the SII reporting.

 – Checking the consistency of data of the different data sources involved:

  • ERP accounts.
  • SII registers.
  • Monthly VAT returns.

See more about our other services in this area here

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