Doctrine by topic · DGT Observatory

Document Retention: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 9 rulings · 2014–2022

Current position

The retention of invoices by electronic means requires guaranteeing the authenticity of the origin, the integrity of the content, and its legibility. It is not mandatory to maintain paper copies of invoices received electronically or those that have been digitized. The system must allow access to the Tax Administration without delay.

The DGT's position remains constant in the requirement to guarantee the authenticity, integrity, and legibility of documents. Throughout the rulings, it has been reaffirmed that digitization allows for the dispensing with paper originals and that internal management controls are valid means to ensure the integrity of the electronic invoice.

Turning points

  1. V3213-15

    Establishes that authenticity and integrity can be guaranteed through the usual management controls of the business activity and internal audit controls.

  2. V3253-16

    Clarifies that an invoice is electronic if it is issued and received in said format, including PDFs received by email, and that electronic retention does not require maintaining a paper copy.

Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9
V2502-19 17 Sept 2019

PDF invoices received via email can be kept without paper copies

SG de Impuestos sobre el Consumo
factura electrónicaconservación de documentosautenticidad del origenintegridad del contenidolegibilidad LIVA — Ley 37/1992 del IVA art. 164.1.3ºLIVA — Ley 37/1992 del IVA art. 164.2
Affects CompanyExpat · Non-residentIndividual
V3214-15 21 Oct 2015

Paper simplified invoices can be replaced by certified digitisation

SG de Impuestos sobre el Consumo
factura simplificadadigitalización certificadaconservación de documentosdeducción del impuestoacceso en línea LIVA — Ley 37/1992 del IVA art. 164.1.3ºLIVA — Ley 37/1992 del IVA art. 164.2
Affects CompanyExpat · Non-residentIndividual

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