A draft law in relation to technical requirements for VERI*FACTU invoicing systems has been published in Spain

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. According to how it is stated, 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.

As a reminder, the ability to send invoice records to the AEAT is part of new strict IT, security, and tax requirements for developers and users of invoicing systems starting 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.

But, it is important to state that the legislation is still in draft form, subject to change, and still needs to be formally approved (we are awaiting the opinion of the Council of State).

A short overview of the process for sending invoice records

• 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 clearly defined categories of XML messages: one for the sending of "registration records" and another for the sending of "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 rule 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 a list of accepted and rejected invoice registration records, together with the rejection reason. In case of rejection, businesses must make the necessary corrections and re-submit the relevant records, etc.

Also, some technical details in relation to data standards and other requirements from the technical perspective have been published.