For Comply to submit your invoicing records to the Spanish Tax Agency through the Immediate Registration Information System (SIIR), you must formally grant representation to DAP Consulting SL as a social collaborator. This authorisation must be made using the official representation form approved by the AEAT, signed exclusively with a qualified digital certificate.
What is the Representation Authorization Form?
It is a standardised document approved by the Resolution of 18 December 2024 of the AEAT’s Directorate General, which allows DAP Consulting SL to act on your behalf to submit invoicing files through the Spanish Tax Agency’s Electronic Office.
Note: this document is mandatory to operate with Comply, in both test and production mode.
What type of signature and certificate is required?
Only a qualified electronic signature is accepted, made with an official digital certificate issued by a recognised authority. The type of certificate you need depends on the legal form of your business:
Natural person certificate (FNMT): carries the identity of a citizen or natural person. It is intended for self-employed individuals and designed for professional procedures.
Legal entity representative certificate (FNMT): carries a legal identity. It is intended for companies with their own legal personality.
In both cases, the certificate is free of charge and valid for 4 years.
The following are not accepted:
Handwritten or scanned signatures.
Signatures made by clicking, accepting terms, or any other informal method.
Simple electronic signatures not linked to a qualified certificate.
Tip: if you do not have a digital certificate yet, you can request one free of charge from the FNMT website.
How to sign the document
You can sign the representation form with any of these programs:
Adobe Acrobat Reader (version with digital certificate support)
Once signed digitally, you must upload the file to Comply from the corresponding step of the activation flow.
Requirements for the signed file:
Format: PDF.
Qualified electronic signature based on a recognised digital certificate.
The signature must be visible in the document.
The date of the signature must appear on the document.
Documents signed manually or with software that does not use valid digital certificates are not accepted.
Possible errors during document validation
Comply may reject the signed document for any of these reasons:
You are registering a company and the document is signed with a natural person certificate instead of a legal entity representative certificate.
You are registering a self-employed individual and the document is signed with a legal entity certificate instead of a natural person certificate.
The data in the document does not match the data entered in previous steps. Check that the information is identical.
The document contains an uncertified signature: a signature drawn with Adobe Reader or another PDF editor has no legal validity for this procedure.
Regulatory reference
This procedure is regulated by the Resolution of 18 December 2024 of the AEAT’s Directorate General, published in the BOE no. 308.