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A Chamber of Commerce inquired whether it is valid to issue electronic invoices in PDF format sent via email without a digital signature. The Directorate-General for Tax (DGT) responded that this is possible provided the issuer can guarantee the authenticity of the origin and the integrity of the content through their own management controls.
Question raised: Validity of the proposed electronic invoicing system insofar as the files in PDF format are not digitally signed.
The electronic invoice must guarantee the authenticity of its origin, the integrity of its content, and its legibility. These requirements may be guaranteed through an advanced electronic signature, electronic data interchange (EDI), or any other means of proof admitted under Law, such as the usual management controls of the business activity that allow for the creation of a reliable audit trail. Prior validation of the system before the AEAT is an optional and not mandatory option.
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