TicketBAI: complete guide to the Basque Country invoicing regulations

TicketBAI is the mandatory invoicing system in the Basque Country that guarantees the traceability of all economic transactions. In this guide we explain everything you need to know to comply with the regulations.

What is TicketBAI?

TicketBAI is a joint project of the three Provincial Treasuries of the Basque Country (Bizkaia, Gipuzkoa and Araba) and the Basque Government. Its main objective is to fight tax fraud through a system that ensures all invoices issued by businesses and self-employed professionals are declared to the tax authorities.

The system establishes a series of technical obligations that invoicing software used by taxpayers must meet, ensuring that:

• All issued invoices are reported to the corresponding Provincial Treasury.
• Invoices are chained together, preventing manipulation or deletion.
• Each invoice includes an electronic signature that guarantees its authenticity.
• Consumers can verify the existence of each invoice through a QR code.

Who does TicketBAI affect?

TicketBAI is mandatory for all taxpayers carrying out economic activities in the Basque Country, regardless of their legal form:

• Self-employed individuals (sole traders with economic activity).
• Limited and public limited companies.
• Co-ownership arrangements.
• Associations and foundations with economic activity.
• Professionals (lawyers, doctors, architects, etc.).

The obligation applies to all transactions subject to Value Added Tax (VAT) and Personal Income Tax (IRPF) or Corporate Income Tax regulations.

Implementation deadlines

Implementation deadlines vary depending on the provincial territory and type of activity:

Gipuzkoa

Gipuzkoa was the first territory to implement TicketBAI, with a progressive calendar that began in 2022:

• January 2022: professionals (IAE section 2 activities).
• April 2022: retail trade, hospitality and other services.
• June 2022: remaining activities.

Bizkaia

Bizkaia implemented TicketBAI (called Batuz in this territory) with the following calendar:

• January 2024: mandatory for all economic activities.
• The Provincial Council of Bizkaia integrates TicketBAI within its Batuz system, which also includes the obligation to keep the Economic Operations Record Book (LROE).

Araba

Araba was the last territory to implement the obligation:

• January 2025: mandatory for all economic activities.

Technical requirements of TicketBAI

Electronic signature

Each invoice must be electronically signed using a recognised digital certificate. Accepted certificates include:

• Legal entity certificates issued by the FNMT.
• Individual certificates (electronic DNI).
• Other certificates recognised by the Provincial Treasuries.

Invoice chaining

Each invoice must contain a hash (digital fingerprint) of the previous invoice, creating an unalterable chain. This mechanism ensures that:

• Invoices cannot be deleted without breaking the chain.
• Invoices cannot be inserted retroactively.
• Any tampering is detectable by the tax authorities.

XML file

Each invoice generates an XML file in a standardised format that must be sent to the corresponding Provincial Treasury. This file contains:

• Issuer and recipient data.
• Details of the invoiced items.
• Tax information (tax base, VAT rate, VAT amount).
• Electronic signature and chaining data.
• QR code for verification.

QR code

Each invoice must include a QR code that allows the recipient to verify that the invoice has been declared to the Provincial Treasury. This code contains a URL linking to the tax authority's verification service.

Penalties for non-compliance

Failure to comply with TicketBAI obligations can result in significant penalties:

• For not using compatible software: fines of up to 20% of turnover with a minimum of 20,000 euros.
• For each unreported invoice: penalties of up to 2,000 euros per invoice.
• For data manipulation: aggravated penalties of up to 30% of turnover.

How to comply with TicketBAI using Holded

Holded is a certified management software for TicketBAI that makes it easy to comply with the regulations across all three provincial territories:

Simple setup

1. Activate TicketBAI in your Holded account settings.
2. Select your provincial territory (Bizkaia, Gipuzkoa or Araba).
3. Upload your digital certificate for electronic invoice signing.
4. Start invoicing: Holded takes care of the rest automatically.

Full automation

• Automatic signing: each invoice is electronically signed transparently.
• Automatic chaining: Holded maintains the invoice chain without manual intervention.
• Automatic submission: XML files are sent to the Provincial Treasury in real time.
• QR code: generated and included automatically on each invoice.

Beyond TicketBAI

Holded not only helps you comply with TicketBAI but also offers a comprehensive platform to manage your entire business:

• Accounting: automate your accounting with bank connectivity and tax form generation.
• CRM: manage your clients and sales opportunities.
• Projects: track tasks, time and profitability.
• Inventory: manage your stock and supply chain.
• Human resources: payroll, time tracking and team management.

Frequently asked questions about TicketBAI

Can I still issue paper invoices?

Yes, but the software you use to record those invoices must comply with TicketBAI. In other words, even if you hand over a paper copy, the invoice must be electronically signed and reported to the Provincial Treasury.

What happens if my software is not TicketBAI-compatible?

You must switch to certified software before the deadline for your territory. Using non-compatible software can result in severe penalties.

Does TicketBAI apply to all my invoices?

Yes, TicketBAI is mandatory for all invoices you issue in the course of your economic activity, including simplified invoices (receipts).

Is TicketBAI the same as Batuz?

Not exactly. Batuz is the specific system of Bizkaia that includes TicketBAI plus the additional obligation to keep the Economic Operations Record Book (LROE). TicketBAI is the common component across all three provincial territories.

How does TicketBAI affect accounting firms?

Accounting firms must comply with TicketBAI both for their own invoicing and for managing their clients' invoicing. They need software that can handle multiple companies and submit invoices to the different Provincial Treasuries.