Electronic Invoicing,  Compliance

Ticket BAI – TBAI: The e-Invoicing system of the Basque Country in Spain

TicketBai Spain Tax Compliance

The Basque Government has undertaken a joint project to combat tax fraud, through the launch of Ticket BAI, a set of new technical and legal obligations that will affect the way invoices will be generated. This initiative aims to achieve greater control over the revenues of economic activities, especially those generated in the B2C environment.

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What is Ticket BAI?

TicketBAI also called TBAI is the new invoice reporting model created and shared by the three Basque provincial councils (Álava, Vizcaya y Guipúzcoa) and the Basque Government.

According to the Basque Government’s Department of Economy and Taxation the TBAI’s main goal is to “guarantee the declaration of all sales operations conducted by persons or entities that perform economic activities”. Despite it being a common project Ticket BAI is adapted to each provincial council’s laws, meaning that its implementation differs depending on the provincial council tax payers must report too.

Generally, as of the compliance deadline all sales must generate a file with tax information which must be submitted to the corresponding provincial council’s tax authority. Each sale must also generate an invoice with the TBAI code and TBAI QR code based on the reported file. The invoice must also include enough information so that final clients can cross reference the invoice to ensure them of its correct issuance.

Who is Impacted by Ticket BAI?

All physical and legal persons who perform economic activities in one of the three provincial councils comprising the Basque government who are subject to the IPRF or corporate tax.

What Operations Should be Generated Under the Ticket BAI Standards?

TicketBAI affects all invoices, whether they are simple or full invoices, electronic or paper, as well as receipts issued when there is no obligation to do so.

When Will Ticket BAI Compliance Become Mandatory?

TicketBAI is at a different stage of development in each Provincial Treasury. Álava, Gipuzkoa, and Biscay have published the technical requirements and implementation deadlines.


Has communicated  that it will incorporate itself to the TicketBAI system gradually. The initiative will be implemented by groups as of 2022.

  • January 1st: voluntary use.
  • April 1st: consultancies.
  • July 1st: professional activities and pharmacies.
  • December 1st: the rest of the taxpayers.


The Provincial Treasury of Gipuzkoa started a voluntary period in 2021. In 2022 and 2023, a mandatory adhesion calendar by sector will begin:

  • June 1, 2022: tax management professionals.
  • August 1, 2022: professional activities.
  • October 1, 2022: companies in the retail trade, hotel and lodging sector.
  • March 1, 2023: construction, real estate development, transportation and recreational, cultural and personal services.
  • May 1, 2023: manufacturing, wholesale trade, telecommunications, financial services and artists.


The Provincial Council of Vizcaya has decided to voluntarily launch the Ticket BAI system starting from January 1, 2022, and make it mandatory from January 1, 2024, for large companies.

In the case of Vizcaya, the Ticket BAI system is part of the Batuz project, which integrates a broader set of measures aimed at controlling tax fraud and improving assistance to taxpayers.

BATUZ, Tax Audit strategy

Batuz is the initiative of the Provincial Treasury of Vizcaya based on the use of new technologies to combat tax fraud. Its implementation will require all individuals conducting economic activities in Bizkaia to invoice using a system adapted to Ticket BAI.

Batuz consists of 3 initiatives:

  • Ticket BAI billing system.
  • Record of economic operations (LROE): Models 140 and 240
  • Preparation of VAT, Corporate Income Tax, and Income Tax drafts

Economic Operations Registry Books (LROE) 

The Economic Operations Registry Books – LROE are a tax declaration mechanism intended to reduce tax fraud related to companies’ economic operations.

As of January 2024, the declaration of LROEs must be conducted electronically and through the new TicketBAI invoicing system.

How Does Ticket BAI Work?

The Ticket BAI system creates a digital chain with issued invoices which are electronically signed. This method of declarations guarantees authenticity, integrity, and the non-repudiation of digital registries by impeding the deletion or manipulation of electronic invoices once they have been issued through a point of sale system (POS), personal computer, advanced vending machine, advanced scale, tablet or mobile phone.

Every time a sales operation is conducted an XML-TBAI file must be generated, signed and sent to the corresponding provincial council’s tax authority. The company must generate an invoice with the TicketBAI ID, the TBAI QR and sufficient information for the final client to prove that the invoice is correct.

One must consider the technical requisites and time limits for the issuance of information to each provincial tax authority.


Currently there has been no publication of the technical requirements. However, the provincial council’s website has stated that the TBAI files will be sent to Alava’s provincial council’s tax authority at the moment the invoice is created, meaning that the reporting will be online and in real time.


The provincial council’s tax authority demands that the XML TicketBAI file must be sent to the administration as soon as the e-invoice is generated.


In Vizcaya’s provincial council’s tax authority the TBAI XML will not have to be sent issuers will be obligated to store it an send it through the Economic Operations Registry Books (LROE).


Format: XML File

Information it must include 

  • Invoice information (parties, number, date, breakdown, description)
  • Electronic Signature
  • TBAI Identifier: a code used to identify the invoice in the sytem and ensures the relation between an invoice and the TBAI file. It is 39 characters long.
  • TBAI QR Code: bi-dimensional code that gives the recipient fiscal information   associated to the invoice in question.

Printed Format

The print format of the invoices must include the TBAI QR code with access to the QR reading web application and the TBAI identifier.

How will TICKET BAI affect the electronic invoice?

In order to be valid, electronic invoices must contain the TicketBAI ID. This ID can be in one of two standard formats: EDIFACT or FACTURA-e. If the invoice is in EDIFACT format, it must contain the FTX segment and TXD qualifier at the header level. If the invoice is in FACTURA-e format, it must contain the legal literals within the XML structure.

Compliance Requirements for the new Ticket BAI system

It will be necessary to have an invoicing software that is capable of performing the following functions:

  • Generate the XML TBAI file following each provincial council’s technical specifications.
  • It should be able to electronically sign the XML TBAI files.
  • It will have to automatically send the files to the provincial council through the established communications systems.
  • The invoices generated by the system for the final client must include a QR code (QR TBAI).

EDIWIN warranted TickeBAI software

EDICOM’s platform has been registered in the Ticket BAI warranted software list.

Meaning that it complies with the functional and technical specifications of each of the provincial councils (Guipuzcoa , Vizcaya and Álava) for the generation, issuance and delivery of the TBAIs and LROEs.

TicketBAI becomes yet another electronic invoicing and tax reporting solution that EDICOM offers in Spain. Adding itself to the SII and B2G FACE electronic invoice.

EDICOM coordinates GOVEIN2019 project (Action No: 2019-EU-IA-0046)


*The contents of this publication belong solely to EDICOM GROUP and do not necessarily reflect the opinion of the European Union.

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