European e-Invoicing, e-Tax Compliance

Ticket Bai Spain’s New Invoicing and Tax Compliance System


Three regional tax authorities (Gipuzkoa, Biscay and Álava) and the Basque government have undertaken a joint venture to combat tax fraud by launching the TICKET BAI system, a set of technical and legal requirements that will change the way invoices are generated.

The initiative aims to achieve greater control over tax revenue generated by business activities, especially in the B2C area.

From the moment it goes into effect all sales will generate a file with tax information that will be sent to the regional tax authorities. An invoice with a special code and a QR code will also be generated based on this tax file. The invoices will have all the information required for end customers to determine whether the invoice has been issued correctly.

Although this is a joint venture, the three regional tax authorities and the Basque government are presently in varying stages of development. Gipuzkoa and Biscay have published technical requirements and deadlines, while Álava has only indicated the date of implementation. Navarre’s tax authority has indicated it will not be taking part in the initiative for the moment.

Who’s affected by Ticket BAI?

All physical and legal persons that conduct business activities under the jurisdiction of these three tax authorities and the Basque government.

What transactions must be processed according to Ticket BAI standards?

Ticket BAI affects all invoices, simplified and full, in printed or electronic format, as well as receipts issued when an invoice is not mandatory.

How will Ticket BAI affect e-invoicing?

E-invoices must have a Ticket BAI identification code. However, the method through which this information is to be presented has not yet been established.

How does Ticket BAI work?

Every time a sales transaction is carried out, an XML-TBAI file is generated, which is signed and automatically sent to the corresponding tax authority. The seller then generates an invoice with a Ticket BAI identification code and a QR code including all information needed for end consumers to verify that the invoice is correct.

How should businesses prepare to comply with the new system?

They will need invoicing software that can perform in the following operations:

  • Generate an XML TBAI file following the technical specifications of each regional tax authority.
  • Electronically sign XML TBAI files.
  • Send files automatically to the tax authorities via the established telecommunications system.
  • Generate invoices for end customers with QR codes for consultation.

When will Ticket BAI go into effect?


The Gipuzkoa tax authority has established a progressive schedule of mandatory adhesion to be rolled out according to business activity and self-employed persons for business taxes.

  • January 1st 2021: Tax preparation service providers, as laid out in Article 9 of Provincial Order 582/2014 of 5th November  (PDF).
  • 1st May 2021: This primarily affects professional activities.
  • 1st October 2021: This affects the retail, hotel and catering sectors as well as other professional activities.
  • 1st March 2022: This primarily affects construction and real estate development, transport, and other sectors related to recreational, cultural and personal services.
  • 1st October 2022: This primarily affects the manufacturing, wholesale, telecommunications, and financial sectors, as well as artists.

So far, the Álava tax authority has only indicated that it will implement the Ticket BAI system gradually. The rollout will be staggered in groups and will take place between April 2021 and January 2022. Details on how businesses will be classified have not yet been provided.


The Biscay provincial council has decided to implement the Ticket BAI system on a voluntary basis as of 1st Octubre 2020, becoming mandatory on 1st January 2022.

In Biscay, the Ticket BAI system is part of the BATUZ project, which includes a broader set of measures aimed at combating tax fraud and improving taxpayer services.

Business transaction ledgers 

In addition to the Ticket BAI system, Biscay and Gipuzkoa will require self-employed individuals and companies to keep a ledger of business transactions (libro registro de operaciones económicas, LROE) at the electronic headquarters of the Biscay provincial council.

The impact of the Immediate Disclosure System (Sistema Inmediato de Información, SII) on business transaction ledger declarations has not yet been clarified.

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