Doctrine by topic · DGT Observatory

Readability: 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 13 rulings · 2014–2022

Current position

The preservation of invoices in electronic format is valid as long as the authenticity of the origin, the integrity of the content, and readability are guaranteed. It is not necessary to keep the paper support of digitized invoices if the chosen method allows access to the Administration without delay. In the case of paper invoices that are digitized for electronic receipt, the prior consent of the recipient is required.

The DGT's position remains constant in the requirement to guarantee the authenticity, integrity, and readability of invoices. Over the years, it has been specified that digitization can be carried out through any means that meets the requirements, not being limited exclusively to approved software. The doctrine has ultimately clarified the validity of digitization to dispense with paper and the need for consent in the conversion from paper to electronic format.

Turning points

  1. V0666-22

    Establishes that a digitized paper invoice received electronically is considered an electronic invoice, requiring the prior consent of the recipient.

Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.

Rulings on this topic

13
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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