The Bizkaia Provincial Council has published Provincial Decree 22/2026 and Provincial Order 219/2026, formalising structural changes to the Economic Operations Registry (LROE) for Corporate Income Tax entities filing under Model 240. The changes are effective retroactively from 1 January 2026.
Two-Subcategory Structure Now Anchored in Law
The LROE issued invoices chapter is now formally divided into two subcategories at the regulatory level:
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Subcategory 1.1 — With guarantor software: invoices certified through the TicketBAI guarantor system.
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Subcategory 1.2 — Without guarantor software: invoices issued by entities holding a valid TicketBAI exemption, or whose operations qualify under the carveout established by Provincial Decree 100/2025.
TicketBAI Exemption Now Requires a Formal Application
Non-profit and partially exempt Corporate Income Tax entities wishing to use the TicketBAI exemption introduced by Provincial Decree 100/2025 must now submit a formal application via the Bizkaia Tax Authority’s electronic portal, accompanied by a responsible self-declaration confirming compliance with the four statutory requirements. The exemption ceases in any period where those requirements are not met and must be re-applied for from the following period.
Tailored Compliance Model for Non-Profits and Partially Exempt Corporate Tax Entities
Provincial Decree 22/2026 introduces a dedicated compliance model for entities partially exempt from Corporate Income Tax under Article 12 of the Corporate Income Tax Regional Law and entities under the non-profit special fiscal regime.
These entities now operate under three specific rules for their VAT-exempt activities:
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Issued invoices are recorded in Subcategory 1.2, without TicketBAI certification.
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Received invoices for exempt-activity purchases no longer require registration. Invoices for any taxable activity remain subject to full registration.
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New Subcategory 6.5 requires aggregate reporting of VAT-exempt supplies and purchases to or from any single counterparty exceeding €1,000 per calendar year, unless those invoices are voluntarily registered in full in the standard invoice chapters. Water, electricity, fuel, and insurance operations are excluded.
These reliefs do not apply to entities subject to the Immediate Supply of Information (SII) VAT obligation — large companies, VAT groups, and monthly VAT refund entities retain full standard registry obligations.
Impact on Businesses
Corporate Income Tax entities in Bizkaia that are non-profits or partially exempt should review whether they qualify for the formal TicketBAI exemption and, if so, submit the required application through the Bizkaia Tax Authority’s electronic portal. Those entities must also assess their registry configuration for Subcategory 1.2 and Subcategory 6.5 reporting.
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