Today, the Spanish Government published the Ministerial Order HAC/1177/2024 in the Spanish Official Gazette. This Ministerial Order sets out the technical, functional, and content requirements that must be adopted by the electronic systems and programs that support billing processes. The Ministerial Order also standardizes the formats of the billing records, as approved by Royal Decree 1007/2023 (SIF/VERI*FACTU).
The final version of this Order is almost identical to the draft version submitted to the European Commission regarding the information procedure on technical standards and regulations and regulations relating to information society services, provided for in Directive (EU) 2015/1535.
Technical Specifications and Requirements set out in the Ministerial Order include:
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System Integrity and Security:
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Integrity and Immutability: Systems must calculate and verify the hash of each invoice record to ensure data integrity.
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Electronic Signatures: All invoice records must be electronically signed using qualified electronic certificates.
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Event Logging: Systems must log significant events, such as the detection of anomalies or the export of records, to ensure traceability.
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Data Management and Accessibility:
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Data Conservation: Systems must ensure the secure storage and accessibility of all invoice records.
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Traceability: Invoice records must be linked in a chronological chain, with each record referencing the previous one to maintain a clear audit trail.
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Compliance and Certification:
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Standardized Formats: Systems must use standardized formats for invoice records to facilitate readability and compliance.
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Certification: Systems must be certified to ensure they meet the required technical and functional specifications.
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The SIF/VERI*FACTU Regulation does not apply to taxpayers under the scope of the SII, therefore, these requirements will only affect medium and small taxpayers with annual turnover below 6M Euros who are not obliged to use SII. Taxpayers within the scope of the SIF/VERI*FACTU Regulation will have to issue all their invoices using a compliant billing system from 1 July 2025. However, due to the delay in the publication of this Ministerial Order, some changes to the timeline set out in the Royal Decree 1007/2023 are expected in order to push this deadline out a few months.
This comprehensive order represents a significant step towards enhancing the reliability and transparency of electronic invoicing processes, ensuring compliance with tax regulations, and facilitating better data management for businesses.
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