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V0409-26 26 February 2026 · SG de Tributos Criterion in force
IRPF · sistemas informáticos de facturación

Manual invoicing systems not covered by IT invoicing regulation

The DGT confirms that manual invoicing is not subject to the IT invoicing regulation, but warns that the use of spreadsheets or databases may trigger compliance obligations.

The question raised

Question raised

The DGT's ruling

If the issuance of invoices is manual (handwritten), the Regulation on computer-based invoicing systems does not apply. However, the use of spreadsheets, databases, or processors may entail the obligation to comply with said Regulation if they are considered computer-based invoicing systems due to their processing and storage capacity. In such a case, the obligated party may use a system that complies with the regulations or the application of the Tax Administration.

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