RESPONSIBLE DECLARATION OF THE INVOICING COMPUTER SYSTEM “MOSPRIT”

DRAFT for legal review — do not publish or sign. Convenience translation. The Spanish version (DR-1-mosprit.es.md) is the operative document — the declaration is a Spanish legal instrument addressed to the AEAT and its users/buyers. Fields in [brackets] are pending confirmation.

1.a) Name of the computer system to which this responsible declaration refers:

Mosprit

1.b) Identifying code of the computer system:

M1

1.c) Complete identifier of the specific version of the computer system:

1.0.0

1.d) Components, hardware and software, of which the computer system consists, together with a brief description of what it does and its main functionalities:

Mosprit is cloud-based (SaaS) restaurant and hospitality-venue management software, with no local installation, accessed through a web browser. Its main functionalities are: digital menu and diner ordering via a QR code at the table, kitchen and bar order management, staff and shift management, and table settlement with issuance of the corresponding invoice (ordinary or simplified).

The system consists of the following components:

• Cloud web applications (diner interface, venue staff dashboard) and a central cloud API that manages data and processes, including invoicing.
• An optional local auxiliary printing component, which only transports documents already generated by the central system to the venue’s printer; it plays no part in generating invoices or invoicing records.
• For the generation and remission of invoicing records, the central system unfailingly invokes the external functional components described in section 1.m).

At the moment each invoice is issued, the system generates the corresponding invoicing record within the same transactional unit (see 2.c), synchronously obtains the tax QR code and incorporates it into the invoice delivered to the recipient.

This software allows several invoicing streams to be managed independently within it (different taxpayers and, where applicable, different establishments of the same taxpayer), complying separately with the regulations mentioned in section 1.k) for each of them, as if, in practice, they were distinct invoicing computer systems.

**1.e) Indication of whether the computer system has been produced in such a way that, for the purposes of complying with the Regulation, it can only operate exclusively as «VERI*FACTU»:**

S - Yes

1.f) Indication of whether the computer system allows use by several taxpayers, or by a single user to support the invoicing of several taxpayers:

S - Yes

**1.g) Types of signature used to sign invoicing and event records where the computer system is not used as «VERI*FACTU»:**

Since this is an invoicing product that can only be used exclusively in the «VERI*FACTU» modality, no express electronic signature of the generated invoicing records is performed, as the regulations consider them signed upon being correctly remitted to the electronic services of the Tax Agency with due authentication by means of the appropriate qualified electronic certificate.

1.h) Name and surname of the natural person producing the computer system:

Adi Shkëmbi

(Natural person registered as a sole trader — «Person Fizik» — in the Commercial Register of the Republic of Albania, Qendra Kombëtare e Biznesit.)

1.i) Identification of the person producing the computer system:

• Identification number: M52125030J (NUIS/NIPT)
• Identification type: [04 – Official identification document issued by the country or territory of residence / to be confirmed by adviser]
• Country issuing the identification: AL – Albania

1.j) Complete postal contact address of the person producing the computer system:

Rruga Frederik Shiroka, Njësia 5/385/ND, Kulla Nr. 1, Hyrja Nr. 4, Tirana, Albania.

1.k) The person producing the computer system to which this responsible declaration refers states that said computer system, in the version indicated herein, complies with the provisions of article 29.2.j) of Law 58/2003, of 17 December, General Tax Law; with the Regulation establishing the requirements to be adopted by computer or electronic systems and programs that support the invoicing processes of businesses and professionals, and the standardization of invoicing record formats, approved by Royal Decree 1007/2023, of 5 December; with Order HAC/1177/2024, of 17 October; and with the electronic office of the State Tax Administration Agency for everything that completes the specifications of said order.

1.l) Date and place at which the producing person signs this responsible declaration:

[date of signature], Tirana (Albania).

1.m) Third-party Functional Components (CF): CF used, version, functionality assumed, interaction between components.

Functional Component 1: mosprit-fiscal

• External Functional Component used (name of the computer system): mosprit-fiscal
• Version of the computer system: 0.1.0
• Functionality assumed: transformation of invoicing data into the required format and coordination of the generation and remission of invoicing records through the Bilbabit component.
• Interaction between components: Mosprit unfailingly and automatically invokes, via a cloud API, the mosprit-fiscal component at the moment each invoice is issued, with an idempotency guarantee (one invoice cannot give rise to more than one registration invoicing record). mosprit-fiscal has its own responsible declaration.
• Producer: Adi Shkëmbi (same producer as the CPF, with its own development cycle and versioning).
• Identification: M52125030J (Albania). Contact email: [contact email].

Functional Component 2: Bilbabit (Verifacti)

• External Functional Component used (name of the computer system): Bilbabit
• Version of the computer system: 1.0.1 (verify the current version at the time of signature via Verifacti’s responsible-declaration endpoint)
• Functionality assumed: generation and remission of the invoicing records.
• Interaction between components: the mosprit-fiscal component makes calls via a cloud API to Bilbabit with the data required to create invoicing records. Bilbabit generates the invoicing record and immediately returns the QR. Bilbabit then proceeds to remit the invoicing record to the AEAT with its social-collaborator certificate. Bilbabit provides the AEAT’s response through webhooks and/or a specific endpoint.
• Legal name: Bilbabit SL
• NIF: B75777847
• Contact email: soporte@verifacti.com

ANNEX

2.a) Other means of contact with the person producing the computer system:

• Telephone: [+355 68 288 7684 — confirm public contact phone]
• Email: [contact email — a product-domain address is recommended instead of a personal one]

2.b) Internet addresses of the person producing the computer system:

• Website: [https://mos-prit.com/]
• Information about this product: [https://mos-prit.com/ — product page]
• Access to the history of responsible declarations for versions of this product: [https://mos-prit.com/legal/declaracion-responsable — create before signature]

2.c) The computer system complies with the various technical and functional specifications contained in Order HAC/1177/2024, of 17 October, and in the electronic office of the State Tax Administration Agency, in the following way:

In addition to what is mandatory in certain cases (such as the fingerprint algorithm to be used), other implementations employed are:

• Use of the transactional technology of the database management system to consolidate, in a single transactional unit, the issuance of the invoice and the generation of its corresponding invoicing record: the assignment of the invoice number and the recording of the invoicing record are committed or rolled back together, so that no invoices can exist without their invoicing record, nor invoicing records without their invoice.
• The tax QR code returned upon creation of the record is incorporated into the invoice before delivery to the recipient.
• In the event of an incident preventing immediate remission (temporary unavailability of the service), the record remains pending and is remitted automatically as soon as the service is restored, marked with the incident indicator provided for by the regulations; under no circumstances does the operation allow invoices to be issued without the generation of their record.
• Users of the system have no functionality allowing invoices to be issued without remission of the invoicing records, nor to alter records already generated; corrections and cancellations are carried out exclusively through the amendment, corrective or cancellation records provided for by the regulations.

[Legal review: assess whether an access mode for the Tax Administration to tax-relevant information should additionally be described, per the AEAT example, bearing in mind that in the VERI*FACTU modality the records are held by the AEAT.]