Bizkaia: What is Batuz LROE?

Kelly Muniz
May 31, 2023

The Ledger of Economic Operations (Libro Registro de Operaciones Económicas), also known as LROE, is a main compliance element of the Batuz tax control system. This system is under implementation in the province of Bizkaia, located in the autonomous Basque community in Spain.

Taxpayers under the Batuz mandate must comply with both TicketBAI and LROE obligations. While TicketBAI applies to invoice issuance, LROE rules require taxpayers to electronically record and report data on income, expenses and other fiscally relevant information to the tax authority in a structured format.

Regardless of size or business volume, individuals engaged in economic activities and organizations must meet LROE requirements if subject to Bizkaia regulations on Personal Income Tax, Corporate Tax or Non-Resident Income Tax for permanent establishments. The rule will come into effect on 1 January 2024 and includes taxpayers currently subject to Bizkaia’s SII (Immediate Supply of Information) mandate.

What is LROE reporting?

LROE is the electronic ledger where taxpayers must document several economic activities and report such financial information to the tax authority. Individuals engaged in economic activities report this information via model 140, while companies use model 240.

For compliance with LROE, taxpayers must record and transmit their sales, purchases and other financial data in a structured XML format according to legal technical specifications. Taxpayers can send the data in the ledger either through webservices or manually uploaded via the portal provided by the Bizkaia Tax Authority.

The LROE structure

The structure of LROE information for companies and non-resident taxpayers with permanent establishment (model 240) is comprised of the following:

  1. Chapter of invoices issued
  2. Chapter of invoices received
  3. Chapter of investment goods
  4. Chapter of certain intracommunity operations
  5. Chapter of other information with tax significance
  6. Chapter of accounting movements

Certain chapters also contain subchapters. The chapter of issued invoices, for example, has a subchapter of issued invoices with guarantor software which requires transmitting data from invoices generated using TicketBAI.

In the case of Bizkaia, as taxpayers do not need to submit the TicketBAI XML (generated with the invoice) directly to the tax authority, they will send this data via the LROE subchapter in a specific TicketBAI field.

Batuz LROE submission deadlines

The deadline to submit the LROE files to the tax authority varies according to the type of taxpayer under the obligation.

The general deadline is quarterly. Taxpayers must report the data from when the transaction is carried out until 25 April, 25 July, 25 October, or 25 January – depending on the specific quarter.

The deadline for companies under the Bizkaia SII obligation to submit LROE records is four days from the operation’s completion, in line with the general SII deadline. The SII obligation will be considered fulfilled by submission of the LROE.

Penalties for non-compliance

Failure to comply with the requirement to keep and submit LROE records electronically will result in a monetary fine. The proportionally calculated penalty is 0.5 percent of the transaction amount the taxpayer failed to report, with a quarterly minimum of 600 EUR and a maximum of 12,000 EUR.

What’s next for compliant taxpayers?

By using the TicketBAI invoicing system and reporting the LROE, taxpayers will provide information to the tax authority so that it can fulfil the third element of the Batuz tax control system.

The third element of Batuz entails the preparation of pre-filled VAT draft returns and Corporate and Personal Income declarations, which will be available for taxpayers in Bizkaia from 2024 forward.

Need more information about Batuz LROE or tax in Bizkaia? Contact our team of experts today.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Kelly Muniz

Kelly Muniz is a Junior Regulatory Counsel at Sovos. Based in Stockholm and originally from Brazil, Kelly earned a Bachelor’s degree in Law in her home country, where she worked as a licensed lawyer. She also holds a Master’s degree in EU Business Law from Lund University in Sweden.
Share this post

EMEA VAT & Fiscal Reporting
September 18, 2023
Intrastat Thresholds: Current Exemption Values

Intrastat thresholds are value thresholds which decide if companies in an EU Member State qualify to file a return to tax authorities, based on their intra-community trading. These thresholds change annually, prompting businesses to conduct an annual recalculation to know their obligations. This blog contains all the Intrastat reporting thresholds for 2023, as well as […]

EMEA VAT & Fiscal Reporting
September 18, 2023
Intrastat Guide: Reporting, Numbers, Thresholds

Intrastat is an obligation created in 1993 that applies to certain businesses that trade internationally in the European Union. Specifically, it relates to the movement of goods – arrivals and dispatches – across EU Member States. The requirements of Intrastat remain similar across the EU, though certain Member States have implemented rules differently. As a […]

EMEA VAT & Fiscal Reporting
August 22, 2023
OSS VAT Returns: Deadlines, Exclusions and Penalties

Sovos’ recent observations of audits by EU Tax Authorities are that Tax Officers are paying more attention to the contents of One Stop Shop (OSS) VAT Returns. They have challenged, and even excluded, companies from this optional scheme. OSS VAT returns must contain details of supplies made to customers in each Member State of consumption […]

E-Invoicing Compliance Latin America
August 17, 2023
Chile: Changes in the Electronic Ticket for Sales and Services

The Chilean Internal Revenue Service (SII) recently published version 4.00 of the document describing the format of electronic tickets for Sales and Services. The electronic ticket (or Boleta Electrónica) is an electronic receipt issued for the sale of goods or services to individuals, consumers or end users. The document includes basic information about the transaction, […]

E-Invoicing Compliance EMEA
August 10, 2023
France: B2B E-Invoicing Mandate Postponed

Update: 15 September 2023 In a recent meeting of the Communauté des Relais, the tax authority released additional details surrounding the previously communicated postponement of the B2B e-invoicing mandate in France. This delay is a result of the tax authority listening to feedback from French businesses who have struggled to meet the original timeline. It’s […]