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.
Certificate Types
According to this classification criterion, electronic certificates can be broadly divided into two categories:
Natural Person Certificates: These certificates include the identity of an individual (citizen). They are primarily intended for sole proprietors (autónomos) and are mainly used for professional or business-related administrative procedures.
Legal Entity Certificates: These certificates incorporate the legal identity of a company. Their use is intended for businesses or organizations with a recognized legal status.
Possible Errors During Document Validation
During the document upload process, Comply may reject the digitally signed certificate due to potential validation issues:
Company / Legal Entity Registration: If you are registering a company or corporate entity and the document is signed using a Natural Person Certificate instead of a Legal Entity Certificate (as the legal representative of the company).
Sole Proprietor Registration: If you are registering as a sole proprietor and the document is signed using a Legal Entity Certificateinstead of a Natural Person Certificate (required for individual representation).
The document you uploaded contains a signature that does not match the information provided. Please make sure that the details entered in the previous steps match the data on the digital signature.
Invalid Signature Format: If the document does not contain a valid certified digital signature and instead has been signed using Adobe Reader, Acrobat, or another PDF editing software by manually drawing a signature (a “scribble” or graphic signature). This type of signature does not have legal validity for the purposes of this procedure.