Intensified Penalties for Late Submission of SII (VAT) Records

The State Tax Administration Agency (AEAT) has intensified its verification procedures regarding the late submission of records through the Immediate Supply of Information (SII) system for VAT. 

Contrary to previous practice, these verifications are now resulting, in certain cases, in the actual imposition of penalties. 

SII Record Submission Deadlines 

In general terms, please be reminded that invoicing records must be submitted within the following deadlines: 

Invoices issued 

• Within 4 calendar days of the date of issuance. 

• In any case, the submission must be completed before the 16th day of the month following the settlement period in which the corresponding transactions were included. 

• If the invoice is issued in the month following the tax accrual, the information must be submitted within 4 calendar days from the issuance date and, in any case, before the 16th day of the month following the settlement period. 

Invoices received 

• Within 4 calendar days from their accounting entry. 

• In any case, before the 16th day of the month following the settlement period in which the corresponding transactions were included. 

Important: Saturdays, Sundays, and national public holidays are excluded from the calculation of the 4-day deadline. 

Penalty Regime 

Penalties for the late submission of the records are governed by Article 200 of Law 58/2003 (General Tax Law), in conjunction with the specific regulations of the SII (Royal Decree 596/2016). 

Infractions may result in: 

• A proportional penalty of 0.5% of the amount of the invoice subject to registration 

• A quarterly minimum of EUR 300 

• A quarterly maximum of EUR 6,000 

Recommendation 

Given the increase in these verification procedures, it is essential to review and, where necessary, strengthen internal invoicing, accounting, and tax reporting procedures. This will ensure strict compliance with SII deadlines and help avoid unnecessary financial contingencies.