Doctrine by topic · DGT Observatory

Retention of Invoices: 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 · 2015–2022

Current position

Taxpayers may retain invoices in electronic format as long as the method guarantees the authenticity of the origin, the integrity of the content, and its legibility. It is not mandatory to retain the paper medium if digitization is carried out in a manner that meets these guarantees and allows access to the Administration without delay. The electronic format may be that which is compatible with the taxpayer's computer systems.

The DGT's position has remained stable over time, focusing its requirements on the guarantee of authenticity, integrity, and legibility. Throughout the rulings, it has been reaffirmed that digitization can be carried out by means other than approved software and that the use of a digital signature is not the only method to ensure the validity of the electronic document.

Turning points

  1. V2891-18

    Clarifies that PDF invoices received by email are electronic invoices and that authenticity can be guaranteed by any admitted means of proof, without the mandatory use of a digital signature.

  2. V2176-22

    Confirms that it is not necessary to retain the paper copy of invoices that have been subject to digitization for their electronic retention.

Analysis based on 8 of 9 rulings with a stated position. Updated 29 September 2026.

Rulings on this topic

9

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