What are the new Computerised Invoicing Systems (CIS) and when do they come into force?
Royal Decree 1007/2023, of 5 December, approved the requirements to be adopted by the computer or electronic systems and programmes that support the invoicing processes of entrepreneurs and professionals, which are known as computerised invoicing systems or SIFs (also commonly known as VERI*FACTU, although this is only one of the SIFs contemplated). Its implementation has been delayed due to the lack of publication of the regulation, but the conditions for its implementation have now been established. The specific details and regulations governing this new electronic invoicing system were established in the ‘Crea y Crece’ law, enacted in September 2022.
It will be compulsory for all companies and self-employed workers who have a business activity and invoice digitally or with software used for this purpose. This covers invoices to companies, simplified invoices to consumers and any other electronic means of issuing documents supporting income. It does not affect, for example, the entrepreneur who invoices income on paper and does not keep an electronic or digital record. Companies that keep their VAT records through the Tax Agency’s electronic headquarters (SII-VAT) are not affected.
The Invoicing System will affect all revenue invoices issued. It does not matter whether the client company is a national company, an intra-Community operation or an export operation.
According to the published regulation, invoicing system providers will not be able to market any software that does not comply with the requirements of the SIF from 1 July 2025.
On the other hand, entrepreneurs will be obliged to use it from 1 January 2026, in the case of those who pay Corporate Tax (Limited Companies, Public Limited Companies, Civil Partnerships, etc.), while the deadline for the self-employed and those who pay Personal Income Tax will begin on 1 July 2026.
The main features of these systems are aimed at reinforcing the traceability and control of the invoicing of business income.
Among the two possible SIFs contemplated in the regulation, VERI*FACTU is included in the development of the Anti-Fraud Law. This has been promoted by the Tax Agency, and those who decide to use it will send invoices issued to the Tax Agency on a voluntary basis and in real time when they are issued.
What are the requirements for invoices under the new system?
– All invoices will carry a ‘tax’ QR code, on which the details of the invoice and the issuer can be read.
– They must have a ‘hash’ or digital fingerprint that provides information on the date and time the invoice was issued. This code prevents invoices from being modified.
– In addition, the system must ensure invoice traceability, preventing invoices from being substituted or not all invoices issued from being declared for tax purposes.
– Entrepreneurs who do not opt for a VERI*FACTU system and voluntarily send all invoices to the Tax Agency in real time must keep and ensure the integrity and unalterability of their invoice records for four years. Invoicing software shall be designed for this purpose.
– All invoices issued must be electronically signed by the entrepreneur.
The mandatory requirements to be met with the invoices issued shall not exempt or eliminate any other obligations concerning the keeping of accounting books and compliance with tax obligations. Therefore, even if the VERI*FACTU system is used, these obligations will remain the same.
