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V1925-25 15 October 2025 · SG de Tributos Criterion in force
IRPF · sistema informático de facturación

Use of Excel may trigger RSIF obligations

A professional asks whether the RSIF applies if using Excel for invoices instead of dedicated software. The DGT responds that no obligation arises if no computer system is used (manual invoices), but spreadsheet use could be considered a billing information system.

The question raised

The consultant wishes to know whether the RSIF is applicable to those small business owners or professionals who do not use computer programmes to any extent to issue invoices for their activity, using only the Excel programme for their manual preparation.

The DGT's ruling

The RSIF applies to those who use computerised billing systems for their economic activities. If the issuance of invoices is entirely manual, there is no obligation under this Regulation. However, the use of spreadsheets, databases, or processors may imply their consideration as a computerised billing system pursuant to Article 1.2 of the Regulation. In that case, the taxpayer must use a system that complies with the legal requirements or the application provided by the Tax Administration.

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