As previously anticipated, changes were expected regarding the effective implementation dates of the new Regulation on the requirements to be met by invoicing systems and software. We would like to inform you that this change has now been officially published in the Spanish Official State Gazette (BOE) through Royal Decree 254/2025 of 1 April.
This Royal Decree amends Royal Decree 1007/2023, which approved the Regulation establishing the technical and functional characteristics that must be met by computer systems used in invoicing processes by companies and professionals. The objective of this regulation is not only to ensure the integrity, traceability, preservation and immutability of invoicing records, but also to enable their eventual automatic and secure submission to the Tax Agency.
The most significant change introduced by this new provision is the extension of the mandatory adaptation deadlines to the new requirements:
- For Corporate Income Tax taxpayers (Article 3.1.a of the Regulation): the deadline is extended until 1 January 2026.
- For all other taxpayers: the new deadline is 1 July 2026.
In addition, an important clarification has been introduced regarding transactions documented by self-billed invoices, i.e. invoices physically issued by the recipient of the transaction or by a third party on its behalf, in accordance with Article 5 of the Invoicing Regulation (Royal Decree 1619/2012). In this regard, the new Article 4 of the regulation approved by Royal Decree 1007/2023, as amended by Royal Decree 254/2025, establishes that if the recipient issuing the self-billed invoice is subject to the Immediate Supply of Information (SII) – in accordance with Article 62.6 of the VAT Regulations (Royal Decree 1624/1992) – the new Regulation shall not apply, even if the supplier or service provider (i.e., the party performing the transaction) is not subject to the SII.
This exception is justified by the fact that the systems used by taxpayers operating under the SII already ensure the traceability, integrity, and security of invoicing records, thereby mitigating the risks that the new regulation seeks to address. Therefore, the obligation to comply with the new requirements will only apply in cases where neither the physical issuer (the recipient) nor the system used is covered by the SII.
