Using spreadsheets for invoicing requires compliance with the Veri*Factu Regulation

Managing invoicing through common digital tools raises doubts about the scope of the new regulatory framework. The Dirección General de Tributos (DGT) has specified the scope of the Regulation approved by Royal Decree 1007/2023 regarding the use of non-specialized software.

What the DGT has ruled

The query concerned the possibility of continuing to issue invoices manually using spreadsheets or whether it was mandatory to use a program that meets the requirements of the Veri*Factu Regulation. The Administration's criteria are as follows:

• If the issuance of invoices is strictly manual, the Regulation does not apply.
• The use of spreadsheets, databases, or word processors may imply that the activity is considered to be carried out through computerised invoicing systems, according to article 1.2 of the Regulation.
• In this case, the taxpayer is obliged to use a system that complies with the legal requirements or to use the application offered by the Tax Administration.

What this means for you

This criteria directly affects self-employed professionals who, to streamline their management, use tools such as Excel or databases to generate their commercial documents. If your invoicing method is not purely manual (pen and paper) and employs any type of digital medium for data processing, the Tax Agency may consider that you are using a computerised invoicing system.

This implies that the use of a spreadsheet does not exempt you from complying with the technical requirements introduced by Royal Decree 1007/2023. If the digital system used does not guarantee the integrity, preservation, and traceability of the data in accordance with the regulations, the taxpayer is in a situation of non-compliance.

What you should do

It is necessary to evaluate the current invoice issuance method to determine if it fits into the category of a computerised system. If digital tools are used to generate documents, it must be verified that the software employed complies with the requirements of the Veri*Factu Regulation. In the event that current tools do not offer the guarantees required by Law 58/2003 (LGT), you must proceed to implement an invoicing system that guarantees the information security required by the Administration.