TicketBAI Spain: eInvoicing rules in the Basque Country

A practical overview of TicketBAI in Spain, including provincial differences, compliance requirements and what companies need to prepare.

Understand how TicketBAI affects businesses across Araba, Bizkaia and Gipuzkoa

Key implementation dates

Keep track of key dates and einvoicing mandates in Spain

Araba

  • From 1st of January 2022, TicketBAI has been made available for use on a voluntary basis.  
  • Starting from April 2022, TicketBAI becomes mandatory for entities issuing invoices to the Provincial Council of Álava
  • As of 1st of July 2022, mandatory use of the TicketBAI system for B2C medical and personal hygiene products’ suppliers
  • 1st of October 2022 – all other taxpayers

Gipuzkoa

  • From 1st of July 2022, TicketBAI becomes mandatory for tax management and service providers
  • Starting from September 2022 –Retail, Hospitality, Construction, and Transportation
  • As of 1st of November 2022, mandatory use of the TicketBAI system for Industry, Wholesale, Education, and Healthcare
  • 1st of June 2023 – All Other Sectors (including SMEs and self-employed)

Bizkaia: Batuz + LROE

  • From 1st of January 2022, TicketBAI has been made available for use on a voluntary basis.  
  • January 2024 – Large companies & specific high-revenue businesses
  • January 2026 – SMEs & self-employed individuals

Araba TicketBAI Requirements Overview

Implementation​

Voluntary Start: Apr 1, 2022
Phased Start: Apr 1, 2023 – Oct 1, 2023 Fully Mandatory: Jan 1, 2024

Tax Authority​

Diputación Foral de Araba / Arabako Foru Aldundia

Format

XML following TicketBAI requirements

Digital Signature

Mandatory advanced electronic signature

Archiving

5 years

Other Spanish regulations

VeriFactu, FACe, Ley Crea y Crece, SII.

Bizkaia TicketBAI and Batuz Requirements Overview

Implementation​

Voluntary Start: Jan 1, 2022 Phased Start: Jan 1, 2024 Fully Mandatory: Jan 1, 2026

Tax Authority​

Diputación Foral de Bizkaia / Bizkaiko Foru Aldundia

Format

XML following TicketBAI requirements​

Digital Signature

Mandatory advanced electronic signature​

ZUZENDU​

System implemented for the correction of rejected or erroneous TicketBAI records​

BATUZ​

Comprehensive system that includes TicketBAI and the Economic Operations Record Book (LROE)​

LROE

Economic Operations Record Book where taxpayers must electronically document their economic activities and report them to the tax authority​

Archiving

5 years​

Other spanish regulations

VeriFactu, FACe, Ley Crea y Crece, SII.

Gipuzkoa TicketBAI Requirements Overview

Implementation​

Voluntary Start: Jan 1, 2022
Phased Start: Jul 1, 2023 – Oct 1, 2023 Fully Mandatory: Jan 1, 2024

Tax Authority​

Diputación Foral de Gipuzkoa / Gipuzkoako Foru Aldundia

Format

XML following TicketBAI requirements​

Digital Signature

Mandatory advanced electronic signature

Archiving

5 years​

Other spanish regulations

VeriFactu, FACe, Ley Crea y Crece, SII.

Want to find out how Code10 can help your SAP system comply with TicketBAI regulations in the Basque Country?

Frequently asked questions

Guggenheim Museum Bilbao representing TicketBAI digital tax compliance in the Basque Country

Who is required to comply with TicketBAI in the Basque Country?​

All businesses and self-employed professionals operating in Araba, Gipuzkoa, and Bizkaia must comply with TicketBAI. The implementation Schedule varies by province and industry sector

What is the difference between TicketBAI and Batuz?​

TicketBAI is the electronic invoicing system required in the three Basque Country provinces, while Batuz is a broader compliance system specific to Bizkaia, which includes TicketBAI, the LROE, and pre-filled tax returns.​​​

Person reviewing invoice representing TicketBAI tax compliance in the Basque Country
Calculator with paid and due documents representing TicketBAI tax compliance in the Basque Country

How does the LROE (Economic Transactions Ledger) work in Batuz?​

Businesses in Bizkaia must record all economic transactions in the LROE, which is then submitted to the tax authorities. This allows the automatic generation of tax return drafts by the administration​​​.

What happens if I issue an incorrect invoice under TicketBAI?

TicketBAI invoices cannot be modified directly once issued. Instead, corrections must be made using the Zuzendu system, which allows businesses to send an amended record while maintaining traceability of changes​​​​

Tax document with crumpled papers representing TicketBAI compliance challenges and corrections
Judge gavel on desk representing legal consequences of non-compliance with TicketBAI regulations

What are the penalties for non-compliance with TicketBAI or Batuz?​

Failing to comply with TicketBAI requirements can result in fines of up to 20% of the invoice amount, with a mínimum penalty of 20.000€ per infingement. Repeated non-compliance may lead to higher fines and tax audits​​.

Will an invoice be accepted if it doesn’t follow TicketBAI’s format?

No, the invoice then would be rejected. The invoices sent to TicketBAI must respect the predefined format. Businesses must use certified invoicing software that meets TicketBAI’s technical and security requirements, including electronic signatures and real-time invoice reporting.

Invoices, calculator, and laptop representing TicketBAI tax compliance and financial management

Our Approach to SAP Integration and TicketBAI Compliance

The introduction of mandatory TicketBAI in the Basque Country represents a significant shift for VAT-registered companies operating in the domestic market. Notably, SAP does not provide a standard solution for TicketBAI, meaning that any business expanding into the Basque market from abroad relies on specialized providers like Code10 to bridge this gap. This means that ERP systems must be capable of generating, validating and transmitting compliant invoice data in a fully automated and secure way.

At Code10, we address this gap through a combination of SAP integration and advanced eCompliance capabilities delivered through our eCompliance Hub. We rely on SAP’s existing functionalities wherever feasible and introduce custom developments to meet specific regulatory requirements. Our approach ensures structured invoice generation, format validation and secure transmission through certified communication protocols, enabling organizations to meet Basque obligations efficiently and with full technical reliability.

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