TicketBAI and Verifactu for EV chargers: what Spanish law requires

If you charge drivers for energy in Spain, every payment is an invoice. And since Verifactu and TicketBAI came into force, every invoice must be registered with the tax authority at the moment it is issued. Most charge point management software doesn't do this — it hands the problem back to you. Here is what the rules require, and what it means if you operate chargers in Spain.

The concrete problem: a QR charging session is a simplified invoice

A driver pulls up, scans the QR code, pays by card and leaves. You have just made a sale to a customer who never identified themselves. In Spanish tax law that is a simplified invoice. It isn't optional — it is a sale of goods (energy) for which you received payment, and it has to be recorded.

What changed is when. It used to be enough to accumulate sales and declare them later. Now both Verifactu and TicketBAI require the record to be generated, signed and chained at the moment of issue, not at the end of the quarter. A car park with four chargers in rotation can easily produce hundreds of simplified invoices a month. Nobody is doing those by hand.

Which one applies: it depends on where you pay tax, not where the charger is

This is the most common misunderstanding. The regime that applies is set by your own tax domicile as the operator, not by the physical location of the charge point:

TicketBAI — Basque Country only, and in three separate implementations: Bizkaia, Gipuzkoa and Álava. Each provincial tax authority has its own timetable, its own receiving service and its own technical quirks. In Bizkaia, TicketBAI also sits inside Batuz alongside the LROE ledger of economic operations.
Verifactu — common territory, meaning the rest of Spain. It is the state-level system deriving from the Anti-Fraud Law and the regulation setting requirements for invoicing software.
Navarre has its own foral regime and its own system, which is not TicketBAI.

So an installer based in Gipuzkoa managing chargers for a hotel in Burgos falls under Gipuzkoa's TicketBAI. A Madrid company with chargers in Bilbao falls under Verifactu. What matters is who issues the invoice.

What each record actually demands

Although they are different systems, both share the same underlying architecture — which is why one design can satisfy both:

Sequential numbering per series, with no gaps.
Chaining: each record embeds the hash of the previous one, so the whole chain visibly breaks if an invoice is later deleted or altered.
Electronic signature with the issuer's certificate.
Submission to the authority — immediate under TicketBAI, and immediate under Verifactu if you opt into the reporting mode.
Verification QR code printed on the receipt itself so the customer can check it.

The part everyone underestimates is the chaining. It forces the invoicing system to hold state between one invoice and the next, and to keep that state consistent even when two sessions end simultaneously on different chargers. It is not a nicely formatted PDF — it is a counter with a lock on it.

Why your CSMS probably doesn't handle it

International charge point management platforms are built for a generic European market. Adapting the billing engine to rules that only affect Spain — and within Spain, four separate regimes — rarely justifies itself on their roadmap. What usually happens is one of three things:

They hand you a CSV of sessions and tell you to invoice from your accounting package. That works, until you have 300 sessions a month.
They sell you an integration with an external invoicing gateway, paid separately and kept in sync by you.
They simply never mention it, and the operator discovers the problem after months of taking payments.

How AskaCharge handles it

Fiscal registration lives inside the platform, not in a bolt-on module. When the charging session closes and the payment is captured, the system generates the sequential fiscal number under a database-level lock, builds the F2 simplified-invoice record, signs it, chains it to the previous hash and submits it — to Verifactu or to the relevant provincial authority, according to the territory configured on your brand — storing the receipt with its hash and verification QR. The driver gets their receipt and you did nothing.

If submission fails because the authority is unreachable or a certificate has expired, it retries hourly for roughly a day. If it still cannot go through, the system alerts the brand administrator rather than failing silently. The driver's payment is never affected either way — this only concerns the fiscal receipt.

What you need to have ready

Your digital certificate — legal entity or representative, or a device certificate if you pay tax in the Basque Country.
Your tax details — issuer's NIF and registered address.
Your tax territory: common territory, Bizkaia, Gipuzkoa or Álava.

After that it is transparent. And to be explicit about the limits: today we cover Verifactu and the three Basque provincial authorities. Navarre is not supported yet — if you pay tax there, this doesn't serve you.

Why this is a commercial advantage, not just an obligation

If you are an installer managing chargers for hotels, campsites or restaurants in the Basque Country, tax compliance is the argument that closes the deal. A hotel owner in Gernika will not be impressed by OCPP. They will be impressed that when a guest charges in their car park, the invoice is signed and filed with the Bizkaia tax authority on its own, and their receptionist never has to issue anything by hand or reconcile anything at month end.

It is, quite literally, the administrative work that large platforms hand back to the customer. Being able to take it off their desk is what sets you apart.