Doctrine by topic · DGT Observatory

Management Controls: 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 8 rulings · 2014–2019

Current position

The electronic invoice must guarantee the authenticity of its origin, the integrity of its content, and its legibility. These requirements may be satisfied through any means of proof admitted in Law, including business activity management controls that allow for the creation of a reliable audit trail. The use of an advanced electronic signature or Electronic Data Interchange (EDI) is optional, as they are not the only valid means.

The position of the DGT has remained constant over time. Since 2014, the administration has recognized that management controls that allow for a reliable audit trail are valid means to guarantee the authenticity and integrity of the invoice. No changes have been introduced regarding the nature of these controls or their legal validity.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8
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

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