On 2 April 2025, Royal Decree 254/2025, of 1 April, amending Royal Decree 1007/2023, of 5 December, was published in the Official State Gazette (BOE). This regulation establishes the requirements to be adopted by the computer or electronic systems and programmes that support the invoicing processes of entrepreneurs and professionals, as well as the standardisation of invoicing record formats.
This amendment responds to the need to adjust the deadlines initially foreseen for its application due to the delay in the regulatory process and the late publication of Order HAC/1177/2024, of 17 October, which develops the technical and functional specifications of the invoicing systems. It also introduces adjustments to the regulation of taxpayers under the Immediate Supply of Information (SII).
The main amendments introduced by this Royal Decree are detailed below.
- Extension of deadlines for the adaptation of IT systems supporting the new invoicing processes:
- The deadline for compliance with the obligations set out in the regulation for corporate income taxpayers is extended until 1 January 2026.
- For all other taxpayers, the deadline is extended to 1 July 2026, allowing more time for those who do not make regular use of IT systems to adapt.
- Producers and marketers of computerised invoicing systems will have until 29 July 2025 to adapt their products and place them on the market.
Exception for SII taxpayers
Taxpayers who keep their invoicing records using the SII are exempt from compliance with the regulation when:
- Issue invoices materially generated by the recipient of the transaction.
- issue invoices through a third party in accordance with mandatory regulations.
This exception is based on the fact that the SII already provides the necessary guarantees of traceability and security in the invoicing records.
- Clarification on the responsibility for issuing invoices
The wording of Article 6 of the Regulation is amended to clarify that the responsibility for compliance with invoicing obligations lies with the taxable person carrying out the transaction, regardless of whether the invoice is physically issued by the recipient or by a third party.
Given the new implementation schedule, we recommend that companies take the following actions:
- Assess the impact of these changes on your IT billing systems.
- Coordinate with your software suppliers to adapt to the new requirements within the established deadlines.
- Review your internal procedures to ensure compliance, especially if you deal with third parties in the issuing of invoices.
- Check whether the SII exception applies to you and adjust your processes accordingly.
How can we assist you?
We recommend reviewing in-house e-invoicing systems to adapt them to the new obligations and initiate discussions with software developers to identify the solution that best suits your needs.
Salinas & Partners, with more than 30 years of experience in indirect taxation, is at your disposal for any questions or comments that may arise.