Spain’s tax authority issues draft technical requirements for VERI*FACTU invoicing systems

The AEAT has published an initial draft document establishing the technical requirements necessary to send invoice records generated by VERI*FACTU certified invoicing systems (Sistemas Informaticos de Facturacion y Sistemas) to the tax authority via web services. The technical document solely focuses on the web services to send invoice records on a voluntary basis, but the AEAT will be issuing separate technical documentation relating to web services allowing for the sending of invoice records upon request from the AEAT and for sending records to the AEAT in real time.

• The submission of billing records will be made electronically through the exchange of XML messages through SOAP v1.1 web services.
• There will be two defined categories of XML messages - one for the sending of “registration records” and another for sending “cancellation records”. 
• The maximum number of invoice records per individual submission is 1,000.
• Once the XML message has been sent, the AEAT will automatically carry out a validation process, validating both the XML format and applying business rules. If the message passes the XML format level validations, the business rules validation will be carried out, returning a response message, confirming whether the records have either been accepted or rejected by the AEAT. Where the XML fails the format validation, a SoapFault message will be returned containing the specific error.
• The XML response message sent back by the AEAT will contain the list of accepted and rejected invoice registration records together with rejection reason. The secure verification code will also be reported in the response (CSV format) to evidence the reporting. Where records have been submitted in bulk, responses will be sent back on both a global basis (either Full acceptance, Partial acceptance, or complete rejection) and individual record basis (either Accepted or Rejected).
• In case of rejection, businesses must make the necessary corrections and re-submit the relevant records. 
• Where a business is submitting cancellation records, this will be carried out using a specific XML message for cancellations containing a common header and the list of all the records that the businesses want to cancel. Each billing record will be uniquely identified by the fields contained in the IDFactura tag.

• The XML file must be encoded using UTF 8 and comply with the rules described in the different schemas that set out the format standards and mandatory fields. There will be a requirement for the business to guarantee the consistency of the source data within the invoicing system. 
• Each schema is organised into DataGroups containing Data Elements. Both the input and output messages will be fully described in the respective XML schemas (full technical details and definitions to be provided at later date).
• Businesses or their representatives, must use an electronic certificate which will be authenticated when data is submitted. In addition, all Tax Identification Numbers (NIFs) must be validated against the AEAT’s centralised database.

The ability to send invoice records to the AEAT as outlined above, is part of new strict IT, security and tax requirements for developers and users of invoicing systems from July 1, 2024. This includes requirements for e-invoicing software developers and solution providers to certify that their systems comply with these new standards and requirements. Invoices generated must include a QR code, and the narrative "Invoice verifiable at the electronic headquarters of the AEAT" or "VERI*FACTU" where the system sends the invoicing records directly to the AEAT. The legislation is still in draft, subject to change, and it still needs to be formally approved (we are awaiting the opinion of the Council of State).

There have already been modifications made to the proposed invoicing regulations set out in the Royal Decree, including the removal of the proposed alphanumeric identification code. Invoices (both complete tax invoices and simplified invoices) must include a QR code that contains some specific invoice data. However, if the invoice is electronic (i.e. an e-invoice), the QR code can be replaced with the actual content it represents. 

The proposed effective date of these new requirements closely aligns with the launch of mandatory B2B e-invoicing in Spain which was recently confirmed when the Boletín Oficial del Estado (the Spanish Gazette) officially published the Law Crea y Crece that mandates Spanish companies and professionals to issue and receive e-invoices to and from each other from 2024. 

Avalara has an e-invoicing solution that can help companies stay compliant in over 60 countries including the upcoming Spanish e-invoicing mandate starting in 2024 as well as issuing compliant e-invoices using the existing FACeB2B platform in Spain.  

Watch our latest European e-invoicing update webinar that includes updates on upcoming new mandates and changes in several European countries including Spain.