Law 11/2021, on measures for the prevention and fight against tax fraud, better known as the Anti-Fraud Law, has introduced significant changes in the invoicing systems used by companies across all sectors, including hotel establishments. Its compliance is not only mandatory but also fundamental to avoid substantial financial penalties. The Regulation of the Anti-Fraud Law (Royal Decree 1007/2023) establishes the requirements that must be met by the computerised invoicing systems used by businesses and professionals, in order to guarantee the integrity, conservation, accessibility, legibility, traceability, and unalterability of invoicing records.
This project applies throughout Spanish territory, with the exception of the regional territories (territorios forales) and companies included in the Immediate Supply of Information system (SII).
📅 When did it come into effect?
The Anti-Fraud Law was published on July 10, 2021, and its technological implications came into force on October 11 of the same year. However, it is from January 1, 2026, that all companies subject to Corporation Tax, and from July 1, 2026, the rest of companies and self-employed individuals, will be obliged to use software that guarantees the integrity of data, the impossibility of subsequent alteration of information, and the automatic sending of each invoicing record to the Tax Administration through the system for issuing verifiable invoices, also known as VeriFactu or VERI*FACTU, which is the most convenient option and the one recommended by the Administration.
⚖️ Who does this regulation affect?
The Law affects all companies and self-employed individuals who issue invoices in Spain, which includes hotels, hostels, tourist apartments, rural homes, restaurants and catering services associated with accommodations, as well as vacation property management companies. In short, no establishment that issues invoices is excluded from its scope of application.
🚫 What exactly does it prohibit?
One of the most relevant aspects of the Anti-Fraud Law is the express prohibition of the use of software that allows the manipulation of invoices. Likewise, the regulation requires that the system prevents the modification of data once an invoice has been issued, generates an invoicing record for each issuance or cancellation of invoices, and guarantees the integrity, accessibility, legibility, traceability, and unalterability of the records. It is not permitted to use programs that facilitate the deletion, alteration, or manipulation of fiscal information. The use of non-compliant software can lead to penalties ranging from €50,000 to €150,000 per fiscal year, even if no fraud has been committed, simply for possessing a system that could allow it.
⚖️ Differences between invoicing regulations
The Anti-Fraud Law has coincided in time with another legislative initiative regulating invoicing, the Create and Grow Law (Ley Crea y Crece). Although both regulate the same area, they present notable differences in both their objectives and their application: while the Anti-Fraud Law focuses on combating tax fraud by establishing specific requirements for invoicing software, the Create and Grow Law regulates, among other aspects, the implementation of mandatory electronic invoicing.
🏨 How does it affect tourist accommodations?
In the hotel sector, this regulation forces the review and, in many cases, updating of the PMS or hotel management system to ensure that invoice issuance complies with legal requirements, subsequent modification of invoicing records is prevented, and the system generates documents with unique and secure identifiers. This means that many old or customised programs, if they have not been updated in accordance with the law, will have to be replaced or adapted to avoid incurring penalties.