Using Excel for invoicing may require compliance with the RSIF

The Directorate General of Taxes (DGT) has issued a relevant ruling for small business owners and professionals who manage their invoicing manually. The central issue lies in determining whether the use of basic digital tools, such as spreadsheets, triggers the obligation to comply with the Regulation on Computerized Invoicing Systems (RSIF).

What the DGT has ruled

The query focused on whether a professional who does not use specific software programs, but instead prepares invoices manually using Excel, is exempt from RSIF obligations. The Administration has clarified that the Regulation applies to those who use computerized invoicing systems for their economic activities.

The ruling establishes that if the issuance of invoices is entirely manual, there is no obligation under this Regulation. However, the use of spreadsheets, databases, or word processors may imply their consideration as a computerized invoicing system, in accordance with the provisions of Article 1.2 of the Regulation. In this case, the taxpayer must employ a system that meets the legal requirements or use the Tax Administration's application.

What it means for you

This pronouncement has a direct impact on both entities and self-employed professionals. If your economic activity relies on tools such as Excel for generating commercial documents, you could be subject to compliance with the technical regulations of the RSIF. It is not enough to not have dedicated management software; the use of any data processor for invoicing may be interpreted as the use of a computerized system.

What you should do

It is necessary to evaluate your current invoice issuance methodology. If your invoicing process relies on spreadsheets or databases, you must verify whether your system complies with the requirements demanded by RD 1007/2023 and current regulations. Given any doubt regarding the nature of your management tools, it is fundamental to assess each particular case to ensure that the economic activity complies with the requirements of Law 58/2003 and other applicable regulations.