TicketBAI: The Basque Country Runs Its Own System (and Bizkaia Adds Batuz)
If your tax domicile is in the Basque Country, Verifactu does not apply to you. TicketBAI does: three provinces, three tax authorities, signed XML for every invoice, and real-time transmission with no formal incident mode. Bizkaia layers Batuz on top.
TicketBAI: The Basque Country Runs Its Own System (and Bizkaia Adds Batuz)
Spain's fiscal map is not one system but several. Businesses with tax domicile in the Basque Country (Alava, Bizkaia, Gipuzkoa) are outside Verifactu's scope. Their framework is TicketBAI, the anti-fraud invoicing system run by the three provincial tax authorities (Diputaciones Forales), each with its own norma foral and its own technical nuances.
The Architecture
TicketBAI is software-based fiscalization with real-time reporting:
- Every business and self-employed professional must use certified invoicing software registered with the relevant provincial authority.
- For every invoice, the software generates a signed XML file (the TicketBAI file) containing the invoice data, a unique TBAI identifier, and chaining elements that link it to previous invoices.
- The file is transmitted to the provincial tax authority, in real time or near real time depending on the province.
- Every invoice carries a QR code and TBAI identifier, letting customers and inspectors verify it against the authority's records.
Unlike Verifactu, where transmission to AEAT is optional, TicketBAI transmission is the mechanism itself. The design assumes connectivity.
Three Provinces, Three Authorities
TicketBAI is one brand over three implementations:
| Province | Authority | Particulars |
|---|---|---|
| Bizkaia | Hacienda Foral de Bizkaia | Adds Batuz: the LROE (Libro Registro de Operaciones Económicas), an electronic ledger of operations reported on top of TicketBAI |
| Gipuzkoa | Hacienda Foral de Gipuzkoa | Immediate transmission model; invoicing software must be registered in the provincial registry |
| Alava | Hacienda Foral de Alava | TicketBAI transmission with its own technical specifications and timelines |
Certification, XML schemas, and submission endpoints are provincial. A software vendor supporting "TicketBAI" must support three registries and three sets of specifications. For multi-province operators, that means testing against each authority your entities report to.
Bizkaia's Batuz and the LROE
Bizkaia adds a second layer. Batuz is the province's broader fiscal control strategy, and its core instrument is the LROE: an electronic ledger in which businesses report their economic operations, invoices issued and received, in structured form to the Bizkaia authority.
The practical consequence: in Bizkaia, TicketBAI files feed the LROE reporting. Software must maintain the ledger structures, the chapter and book organization the province requires, and the submission cadence. A TicketBAI-certified tool from another province does not automatically satisfy Batuz.
The Connectivity Assumption
Verifactu includes a formalized incident mode: issue offline, synchronize when the connection returns. TicketBAI's design assumes constant internet connectivity for real-time transmission to the provincial authority. There is no equivalent formalized fallback mechanism.
Infrastructure planning follows from this:
- POS and invoicing systems need redundant connectivity where feasible
- Queuing and retry logic in software must handle transmission failures gracefully, with clear status to the operator
- Offline-heavy operations (markets, food trucks, rural sites) need explicit procedures agreed with the provincial authority
Interaction With the National Layer
| Obligation | Basque business status |
|---|---|
| Verifactu | Exempt (TicketBAI replaces it) |
| Crea y Crece B2B e-invoicing | Applies fully, by turnover deadline |
| SII | Separate obligation by turnover/voluntary enrollment |
| B2G (Facturae via FACe) | Applies when invoicing public administrations |
The Verifactu exemption covers the software anti-fraud layer only. The B2B exchange mandate of Crea y Crece (RD 238/2026) applies to Basque businesses like any others: structured formats, exchange platforms, 4-day status reporting.
The Software Angle
For vendors and in-house teams, the Basque layer means:
- Provincial certification. Register and certify the invoicing software with each relevant Diputación.
- Chained, signed XML per invoice. Same anti-fraud principle as Verifactu, different schema, signature, and endpoints.
- QR plus TBAI identifier on every invoice visualisation.
- Batuz/LROE support for Bizkaia entities. Ledger structures and reporting flows on top of the invoice files.
- Three test environments. A change in one province's specification does not imply a change in the others.
Common Misreadings
"Verifactu applies everywhere in Spain." No. Common territory only. The foral regimes govern the Basque Country and, through NaTicket, Navarra.
"TicketBAI is one system." It is three provincial implementations under one brand. Certification and specs are provincial.
"Exempt from Verifactu means exempt from e-invoicing." TicketBAI replaces Verifactu. Crea y Crece B2B e-invoicing still applies, on the national deadlines.
"Offline mode works like Verifactu." TicketBAI assumes connectivity. Plan infrastructure accordingly.
This material is information of a general nature and does not constitute legal or tax advice. For a specific situation, verify the current rules or consult a qualified adviser.