To enable Comply to transmit your invoicing records to the Spanish Tax Agency (AEAT) via the Immediate Registration Information System (SIIR), you must formally authorize DAP Consulting SL as your legal representative under the framework of social collaboration. This authorization must be granted through the official representation form issued by the AEAT and must be digitally signed using a qualified electronic certificate.
What is the Representation Authorization Form?
The representation form is a standardized document approved by the AEAT through its Resolution dated December 18, 2024. It authorizes a third-party service provider (in this case, DAP Consulting SL) to act on your behalf for the electronic submission of invoicing data files through the AEAT’s Electronic Headquarters.
This document is a legal requirement in order to operate Comply in production mode.
What Type of Signature is Required?
Only qualified electronic signatures are accepted. These signatures must be applied using an official digital certificate issued by a Certification Authority recognized by the Spanish Ministry of Industry and Tourism.
The following forms of signature are not accepted:
Handwritten or scanned signatures
Click-to-accept or checkbox-based confirmations
Simple electronic signatures not linked to a qualified certificate
Which Digital Certificates Are Valid?
The following types of digital certificates are accepted:
Qualified individual digital certificate (e.g., issued by FNMT)
Digital certificate for legal entity representatives
The certificate must be:
Valid (not expired)
Not revoked
Issued by a certification authority listed in the Spanish Trusted List (TSL)
How to Sign the Form
You may apply your qualified electronic signature using one of the following compatible applications:
AutoFirma (provided by the AEAT / Government of Spain)
Adobe Acrobat Reader (with support for digital certificates)
Both tools allow you to apply a qualified electronic signature to a PDF document. Once the document has been digitally signed, you must upload the signed file to Comply during the designated step in the SIIR activation flow within the app.
Technical Requirements for the Signed Document
Format: PDF
Signature: Qualified electronic signature based on a recognized digital certificate
Non-compliant files will be rejected, including:
Manually signed PDFs
Documents signed with tools that do not support valid digital certificates
Regulatory Reference
This process is regulated by the AEAT Resolution of December 18, 2024, published in BOE No. 308, which approves standardized documentation for granting representation in the context of invoicing record submissions via electronic systems.