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Electronic Format: 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 · 2014–2026

Current position

The issuance of invoices may be carried out on paper or in electronic format, unless a specific regulation mandates the use of a particular medium, as is the case with the Public Administration. For an electronic invoice to be valid, the authenticity of its origin, the integrity of its content, and its legibility must be guaranteed. In the case of invoices originally issued on paper that are digitized, the prior consent of the recipient is required.

The DGT's position remains constant in requiring the guarantee of the authenticity, integrity, and legibility of the document. Throughout the rulings, it has been specified that the digitization of paper documents is valid provided that the recipient's consent is obtained and the integrity of the content is ensured. No change in criterion is observed, but rather a reiteration of the security requirements and the freedom to choose the medium.

Turning points

  1. V0666-22

    It is established that an invoice originally issued on paper and digitized will be considered an electronic invoice if the recipient has given their prior consent.

Analysis based on 8 of 8 rulings with a stated position. Updated 15 November 2026.

Rulings on this topic

8

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