Submission of billing records: voluntariness and the VERI*FACTU system

The implementation of the new Billing Regulation (RSIF) has raised doubts regarding the mandatory nature of certain technical processes within business management systems. A recent ruling from the General Directorate of Taxes (DGT) has clarified the scope of connectivity and data submission in these systems.

What the DGT has ruled

The inquiry focused on whether businesses were required to have an internet connection at the location of their Billing System (SIF) to comply with current regulations. The DGT has determined that, while the computer system must guarantee the integrity and traceability of records, as well as have the capacity for electronic submission to the Administration, the automatic and secure submission of said records is voluntary.

This criterion is based on Article 15 of the Billing Regulation (RSIF). However, the authority clarifies that if the taxpayer decides to opt for automatic submission, their system may be considered a Verifiable Invoice Issuance System (VERI*FACTU).

What it means for you

For businesses and professionals using computer systems for billing, this implies that the automation of data transmission to the Administration is not a direct imposition in all cases. There is a clear distinction between complying with the system's integrity and traceability requirements and the decision to automate the transmission of information.

If a company opts for the VERI*FACTU system, the communication dynamics with the Administration change, as this model is designed for the verification of issued invoices. Therefore, the choice of the technological management model will have consequences for how one interacts with the Tax Administration.

What should be done

It is necessary to evaluate the current technological infrastructure and the company's management objectives. The decision to implement automatic submission or to adopt the VERI*FACTU system should be based on compliance needs and the technical capacity of the billing software. It is recommended to assess each particular situation to determine which billing system model best adapts to the business operations and the requirements of Royal Decree 1007/2023.