Every invoice issued by a compliant billing system (SIF) creates an issuance record that is chained to previous records through a hash or fingerprint. When that invoice contains a material error or should never have been issued, deleting it is not an option: the integrity of the system requires recording its cancellation by means of an annulment record.
Annulment versus correction
Two different mechanisms should not be confused. A corrective invoice amends a previous invoice that remains valid, adjusting amounts, data or tax. An annulment, by contrast, voids an issuance record that should never have existed or was generated by mistake, without replacing it with a new one. Each situation has its own treatment, and choosing the wrong one creates inconsistencies in the records and in the data reported to the tax authority.
The annulment record
The annulment record references the issuance record it voids and, like every other record, carries its own chained fingerprint. This way the integrity chain is not broken: it remains on file both that an invoice existed and that it was annulled, and when. An auditor reviewing the system can reconstruct the full sequence of issuances and annulments.
Traceability and retention
Annulment does not erase information; it completes it. Both the annulled record and the annulment record are retained, guaranteeing the traceability the rules require. This logic —adding rather than deleting— underpins the tamper-evidence the system is designed to achieve.
Best practices
It is advisable to document the reason for each annulment internally, verify that the system correctly chains the annulment record, and confirm that, where reporting to the tax authority applies, it reflects the operation. Compliant billing software automates the chaining and prevents a poorly managed annulment from compromising the integrity of the whole year.
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InvoSeal complies with RD 1007/2023 in VeriFactu and Non-VeriFactu mode from day one. Statement of Responsibility published.
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