Mandatory VAT and personal income tax registers

If you carry on an economic activity in Spain — as a freelancer or through a company — you must keep tax registers: for VAT, registers of invoices issued, invoices received, capital goods and, where applicable, certain intra-Community transactions (articles 62 to 66 of the VAT Regulations, RD 1624/1992); for personal income tax, the registers required by your assessment scheme under Order HAC/773/2019 (from three registers under simplified direct assessment to only one or two under objective assessment). The obligation applies even if you outsource your accounts to an adviser, and non-compliance is penalised under article 200 of the General Tax Law: fines from €150 to €6,000 for inaccuracies or omissions, and 1% of turnover for the year (minimum €600) for failing to keep or retain the registers. This guide explains exactly which registers apply to you, what every entry must contain, the deadlines and how to maintain them without spending hours on the task.

What tax registers are and why they are not “accounts”

Tax registers are ordered, chronological records of your transactions — invoices issued, invoices received and investments — that tax legislation requires you to maintain so the AEAT can check your self-assessments. They are not the same as commercial accounts:

• Commercial accounts (journal and inventory and annual accounts book): article 25 of the Commercial Code requires every commercial business owner to keep them, and in practice this affects all companies and freelancers carrying on commercial activities under normal direct assessment. They are legalised at the Commercial Registry.
• Tax registers: required by the legislation for each tax (the VAT Regulations and Order HAC/773/2019 for personal income tax). They are not legalised in any registry, but must be available if requested by the AEAT.

An SL that keeps accounts in accordance with the Commercial Code does not need duplicate personal income tax registers (it pays Corporate Income Tax), but it remains required to keep VAT registers. A freelancer under simplified direct assessment, by contrast, does not need full commercial accounts: their tax registers perform that role.

VAT registers: the four under the Regulations

Article 62 of the VAT Regulations (RD 1624/1992, in force in 2026) requires businesses and professionals who are taxable persons to keep the following registers:

Register	Who keeps it?	Legal basis
Invoices issued	All taxable persons who issue invoices	Art. 63 RD 1624/1992
Invoices received	All taxable persons who incur deductible VAT	Art. 64 RD 1624/1992
Capital goods	Those with capital goods subject to pro rata adjustment	Art. 65 RD 1624/1992
Certain intra-Community transactions	Those dispatching or receiving goods under art. 66 (transfers, work on movable goods and others)	Art. 66 RD 1624/1992

In practice, a typical freelancer or service company keeps the first two. The capital goods register becomes relevant when you apply the pro rata rule (activities with partially deductible VAT), while the intra-Community transactions register only applies to specific movements of goods within the EU, not merely because you sell services to European customers.

The register of invoices issued

Every invoice issued is recorded with its number and series, date of issue, the recipient’s name or company name and NIF, taxable amount, tax rate and tax amount. Corrective invoices are recorded separately. Summary entries for simplified invoices are allowed under specific conditions (same date and sequential numbering).

The register of invoices received

Invoices received are numbered in order of receipt and entered from the moment they are received and before the self-assessment deadline for the period in which you will deduct the input VAT. This is where most errors occur: expenses that arrive late, receipts without a full invoice that do not entitle you to a deduction, or incorrectly classified invoices from foreign suppliers.

Personal income tax registers: they depend on your scheme

For individuals with an economic activity, Order HAC/773/2019 (BOE of 17 July 2019, applicable from the 2020 tax year and in force in 2026) regulates which registers must be kept according to how net income is determined:

Personal income tax scheme	Mandatory registers	Legal basis
Normal direct assessment (commercial activity)	Accounts compliant with the Commercial Code (journal, inventory and annual accounts)	Art. 25 Commercial Code
Simplified direct assessment (and normal direct assessment for non-commercial activities)	Sales and income · Purchases and expenses · Capital goods	Art. 1 Order HAC/773/2019
Professional activities under direct assessment	Income · Expenses · Capital goods · Advances and disbursements	Art. 6 Order HAC/773/2019
Objective assessment (módulos)	Capital goods (if deducting depreciation) · Sales and income (if net income depends on turnover)	Art. 7 Order HAC/773/2019

Business vs professional: they are not the same

The distinction matters. A designer, lawyer or one-person consultancy (professional activities under Section 2 IAE codes) keeps four registers, including the advances and disbursements register: amounts a customer gives you in advance for expenses (advances) or payments you make on their behalf and recharge without a margin (disbursements). A shop or e-commerce business (a business activity) keeps the three registers under article 1.

The detail many overlook: the counterparty’s NIF

Since the 2020 tax year, Order HAC/773/2019 has required every entry in the sales and income and purchases and expenses registers to include the customer’s or supplier’s full name and NIF. A spreadsheet entry saying “Web income — €450” is not a valid tax register: it lacks the counterparty’s identity, invoice number, date of issue and itemisation of any personal income tax withholding.

What data every entry must contain

As an operating rule, every row in your registers should allow an inspector to reconstruct the transaction without asking you for anything else:

The AEAT publishes a standard electronic tax-register format on its website (spreadsheets with a predefined structure) that is also used to respond to requests: if the authorities ask for your registers, they will expect something with that structure, not a folder of PDFs.

Entry deadlines and how long to retain the registers

Keeping the registers “up to date” has a legal definition; it is not an optional good practice:

• General rule (personal income tax, article 10 Order HAC/773/2019): transactions must be entered before the filing deadline for instalment payments for the period (forms 130/131: by 20 April, July and October and, for the fourth quarter, by 30 January).
• Transactions without an invoice: within seven days of the transaction, if that deadline is earlier than the general one.
• Invoices received: in order of receipt, before the deadline for the self-assessment in which you deduct the VAT.

As for retention:

Obligation	Period	Source
Retain registers, invoices and supporting evidence for tax purposes	4 years (general limitation period)	Law 58/2003, General Tax Law (in force in 2026)
Retain commercial books and documentation	6 years from the last entry	Art. 30 Commercial Code (in force in 2026)
Capital goods subject to adjustment	4 years from the final pro rata adjustment (in practice, up to 9+ years from purchase)	Arts. 107–110 Law 37/1992 on VAT

SII: when registers are kept on the AEAT website

Since 2017, certain taxpayers have not kept their VAT registers “at home”: they keep them through the AEAT electronic office using the Immediate Supply of Information (SII), governed by article 62.6 of the VAT Regulations. This is mandatory for those that settle VAT monthly:

• Large companies: annual turnover above €6,010,121.04.
• Businesses registered with REDEME (the monthly VAT refund register).
• Groups of entities for VAT purposes.

Those required to use SII — and those joining voluntarily — submit the details of each invoicing record within a general deadline of four calendar days and, in return, are exempt from filing forms 347 (transactions with third parties) and 390 (annual VAT summary). For all other companies and freelancers, SII is optional: if your business grows to that threshold, the switch becomes mandatory, and your invoicing software should already generate records in the required structure.

Penalties: what is at stake if you do not keep the registers

Article 200 of Law 58/2003, the General Tax Law (in force in 2026), classifies breaches of accounting and record-keeping obligations as serious infringements:

Conduct	Penalty (article 200 LGT)
General failure to meet accounting and record-keeping obligations (residual rule)	Fixed fine of €150
Failure to keep or retain the required accounts, books and registers	1% of turnover for the year, with a €600 minimum
Inaccurate or omitted transactions, or accounts used with a meaning different from their proper one	1% of omitted or falsified debits, credits or entries — minimum €150, maximum €6,000
Delay in keeping registers electronically through the AEAT office (SII)	0.5% of the invoice amount, with a quarterly minimum of €300 and maximum of €6,000
Keeping different sets of accounts for the same activity that make the true position difficult to determine	€600 for each affected tax year

Beyond the direct fine, deficient registers have a greater indirect cost: in a review, every expense without a recorded and documented invoice is an expense the AEAT removes, together with its tax, late-payment interest and a possible penalty of 50% to 150% of the underpaid amount (articles 191 et seq. LGT).

VeriFactu and tax registers: what changes from 2027

Tax registers do not disappear under the new invoicing-system rules (RD 1007/2023 and the VeriFactu Regulations). What changes is the invoice’s traceability from origin: invoicing programs must generate linked and immutable invoicing records, with a digital fingerprint and QR code, and may submit them to the AEAT in real time (VeriFactu mode).

Key dates following Royal Decree-law 15/2025 (BOE 3 December 2025):

• 1 January 2027: mandatory for Corporate Income Tax taxpayers.
• 1 July 2027: mandatory for freelancers and other taxpayers (personal income tax).
• Those using SII are outside the scope of VeriFactu: they already submit their registers in near real time.

One important nuance: VeriFactu is not a certification granted to software by an official body. Compliance is evidenced by a responsible declaration from the producer (article 13 RD 1007/2023). Be wary of anyone selling an “official VeriFactu seal”: it does not exist.

The practical effect on your registers is positive: if every invoice originates in a system that records it in a linked sequence, the invoices-issued register is an automatic by-product, not a task. That is Frihet’s approach: every invoice you issue and every expense you record immediately feeds your invoices-issued, invoices-received, and purchases and expenses registers, with the counterparty NIF, VAT/IGIC itemisation and personal income tax withholding already structured — and you can export them whenever the AEAT or your adviser asks. The free plan includes up to 999 invoices per month, so “I will enter everything properly at the end of the quarter” stops being an excuse from the first invoice.

How to set up your tax-register system this week

You do not need an accounting department; you need a process that does not depend on your memory:

Tax registers are the silent infrastructure behind all your tax obligations: they feed forms 303, 130, 390, 347 and your income tax return. If the data is entered correctly once — when you invoice or receive the expense — everything else follows from it. If it is entered incorrectly or late, every quarter becomes an archaeological reconstruction.