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Spain

Policy module: src/events/compliance/policies/es.py:

  • SpainPolicy (ES), using FiscalizedInvoicingMixin, plus one organizer notice until the block starts;
  • BasqueCountryPolicy (ES-PV), TicketBAI, in force now (Basque Country);
  • NavarrePolicy (ES-NC), Spain's 2027 block with Navarre's own wording (Navarre).

Issues: #1059, #1086

Status

Upcoming restriction (from 1 January 2027): attendee invoicing.

Spain's invoicing-software rules (RRSIF, known as VERI*FACTU) become mandatory on 1 January 2027 for corporate-income-tax payers and 1 July 2027 for other in-scope taxpayers. When a third party issues invoices on the seller's behalf, the third party's own system must comply. Revel's attendee invoicing would make Revel that system, and it does not comply. Revel cannot tell whether an organizer is a corporate taxpayer, so the earlier date applies to every organizer established in Spain.

In force now in the Basque Country: attendee invoicing blocked (TicketBAI). The foral territories are outside VERI*FACTU and run their own systems; see Basque Country and Navarre.

What Revel does

  • Until 31 December 2026, attendee invoicing is allowed for organizers in Spain, as in any other country. The capability reported by the API reads allowed until then.
  • From 1 January 2027, attendee invoicing is blocked for organizers established in Spain:
    • switching to HYBRID or AUTO is refused (HTTP 422), with a translated explanation, naming Spain, that invoices must go through Verifactu;
    • generation is skipped (invoice generation, issuing an existing draft, including drafts created before the gate, and credit notes);
    • the API capability switches to blocked on that date;
    • every skipped invoice and credit note is recorded for the organizer to issue from its own RRSIF-compliant invoicing system (VERI*FACTU or NO VERI*FACTU mode), including credit notes for refunds of invoices Revel issued in 2026 (#1091, see Skipped documents).
  • Organizer-established only. A foreign organizer's event held in Spain is not affected.
  • Organizer notice (non-blocking), until 31 December 2026, for organizers established in Spain, shown next to the attendee-invoicing setting (key es_verifactu, topic attendee_invoicing): "From 1 January 2027, Revel stops issuing attendee invoices for organizers in Spain, because it can't meet Spain's invoicing-software rules (Verifactu), which start applying in 2027. If you use attendee invoicing, set up your own invoicing software before then." Organizers in the Basque Country don't get it (they are blocked already), and organizers in Navarre get their own wording (see below). It is gated on the policy's fiscal_invoicing_from, so it disappears on the day the block starts; from then on the block's own explanation takes over. It shows whatever the organization's invoicing mode, so organizers who might switch invoicing on also learn the date.
  • Existing settings: organizations in Spain are not switched to NONE by the data migration 0128_disable_blocked_attendee_invoicing. They keep their HYBRID or AUTO setting; from 2027 the generation gate skips their invoices by itself, and the capability and flags report it.
  • Online and offline payments are not restricted.
  • The common ticket content applies.

Basque Country (TicketBAI)

Organizers whose tax domicile is in Álava, Bizkaia or Gipuzkoa are under the foral TicketBAI regimes, not VERI*FACTU (RD 1007/2023, art. 1.3). TicketBAI is mandatory today in all three provinces: Álava since 1 December 2022, Gipuzkoa since 1 June 2023, and Bizkaia (where it is part of Batuz) since 1 January 2026. It also covers invoices a third party issues in the taxpayer's name: outsourcing the invoicing "en ningún caso le exime". A Revel PDF has no TBAI code or QR and is not sent to the foral treasury, so it is non-compliant today.

  • Detection: the organization resolves to ES and its city is in Spain with City.admin_name "Basque Country" (also accepted: "País Vasco", "Pais Vasco", "Euskadi", any case). Its jurisdiction is then ES-PV. A city elsewhere never overrides the declared country (an FR VAT ID with a Bilbao city stays FR). There is no override field: the city is the signal. What actually decides it is the Concierto Económico (Ley 12/2002): tax domicile in the Basque Country, with the €12M / 75% exception for large companies, which Revel can't see.
  • What Revel does: attendee invoicing is blocked from today, for organizers established there only (a foreign or Madrid organizer's event in Bilbao is unaffected):
    • switching to HYBRID or AUTO is refused (HTTP 422): "Revel can't issue invoices to your attendees in the Basque Country. The law there requires invoices to go through TicketBAI (Batuz in Bizkaia), and Revel isn't connected to it. Please issue invoices from your own TicketBAI-compliant invoicing software.";
    • generation, issuing drafts and credit notes are skipped and recorded under Documents to issue yourself with reason_code: fiscalized_invoicing and policy_country: "ES";
    • the org compliance object reads country: "ES", region: "ES-PV", attendee_invoicing: "blocked", and carries no es_verifactu notice.
  • Existing data: no Basque organizations existed when this shipped, so no data migration or organizer notification was needed.

Navarre-domiciled taxpayers are also outside VERI*FACTU (RD 1007/2023, art. 1.3). The Hacienda Foral de Navarra has announced its own system, NaTicket, without a start date. Revel keeps Spain's 2027 block for Navarre (jurisdiction ES-NC, detected like the Basque Country from admin_name "Navarre", "Navarra" or "Nafarroa") and only corrects the wording so it doesn't claim Verifactu:

  • notice until 31 December 2026 (key es_nc_naticket): "From 1 January 2027, Revel stops issuing attendee invoices for organizers in Spain, Navarre included. Navarre is bringing in its own invoicing-software rules (NaTicket), and Revel won't be connected to them. If you use attendee invoicing, set up your own invoicing software before then."
  • refusal from 1 January 2027: "Revel doesn't issue invoices to attendees for organizers in Spain, Navarre included. Navarre is bringing in its own invoicing-software rules (NaTicket), and Revel isn't connected to them. Please issue invoices from your own invoicing software."
  • Real Decreto 1007/2023 (RRSIF): scope (art. 3, art. 4, including invoices issued by third parties), VERI*FACTU mode (art. 16), producer certification (art. 13); deadlines in the Disposición final cuarta as amended by Real Decreto-ley 15/2025. BOE, RDL 15/2025, AEAT note on the extension
  • Orden HAC/1177/2024: technical requirements (per-taxpayer record chains, SHA-256 hash chaining, billing records, declaración responsable, QR code and legend). BOE
  • Real Decreto 1619/2012 (ROF): invoicing obligation (art. 2), third-party issuance needs a prior agreement (art. 5). BOE
  • Ley 58/2003 General Tributaria, art. 201 bis: sanctions for producing and for using non-compliant software. BOE
  • AEAT developer FAQ v1.3, §10: compliance falls on the system of whoever materially issues the invoices. AEAT, general questions
  • Real Decreto 1007/2023, art. 1.3: the RRSIF does not apply to taxpayers under the foral regimes of the Basque Country and Navarre. BOE
  • Ley 12/2002 (Concierto Económico): which taxpayers fall under the Basque foral treasuries. BOE
  • TicketBAI / Batuz (Basque Country): Álava FAQ 1.9, start dates, Álava, who is affected, Gipuzkoa calendar, Batuz FAQ (Q38: invoices issued by third parties)
  • NaTicket (Navarre): announced by the Hacienda Foral de Navarra, no start date yet.

Open questions

  • An ES VAT ID is a proxy: Canary Islands, Ceuta and Melilla sellers are outside the EU VAT area, and foral sellers also have ES IDs. Blocking all of Spain is the safe default.
  • The exact fine for users of non-compliant software (art. 201 bis.4) could not be confirmed.
  • How the producer adaptation date interacts with the RDL 15/2025 extension.
  • The Basque Country is detected from the organization's city, a proxy for tax domicile. An organizer with a Basque city but a common-territory domicile (or a large company under the Concierto's volume rule) is blocked anyway; one without a city is treated as common territory.
  • An invoice whose organization was deleted keeps only its seller country (ES), so it is judged by the common-territory rule, not TicketBAI.
  • When NaTicket gets a date, Navarre's block may need to move.
  • Regional espectáculos públicos laws: no platform-certification requirement found, not researched in depth.
  • A ticket is not a factura simplificada as long as the organizer issues invoices separately.

Later layers

  • Optional: implement a VERI*FACTU invoicing system (per-seller chained billing records, AEAT submission, QR and legend on the PDF, a published declaración responsable), only if there is demand. TicketBAI would be a separate product.
  • Confirm that existing revenue exports give organizers the per-sale data their own system needs. The Documents to issue yourself sheet lists the skipped documents with buyer, amounts and VAT (#1091).

See #1059.