RESPONSIBLE DECLARATION OF THE INVOICING COMPONENT “MOSPRIT-FISCAL”

DRAFT for legal review — do not publish or sign. Convenience translation. The Spanish version (DR-2-mosprit-fiscal.es.md) is the operative document. Independent invoicing component (CF) within the meaning of art. 1.2.b) of Order HAC/1177/2024, invoked by the invoicing computer system «Mosprit» (see its responsible declaration). Fields in [brackets] are pending.

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

mosprit-fiscal

1.b) Identifying code of the computer system:

M2

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

0.3.0

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:

This is a cloud invoicing component (API), with no user interface, serving exclusively the invoicing computer system «Mosprit». Its functions are:

• Receiving from the main system, through automatic programmatic invocation, the data of each invoicing operation in JSON format.
• Transforming that data into the format required for the creation of the invoicing record (grouping of lines by tax rate, calculation of taxable bases and tax amounts, issue date).
• Coordinating the generation and remission of the invoicing record through the unfailing invocation of the external functional component Bilbabit (see 1.m), with an idempotency guarantee: the same invoice cannot give rise to more than one registration invoicing record, even in the event of retries caused by network failures.
• Synchronously returning to the main system the tax QR code, the fingerprint and the record identifier, and forwarding the AEAT’s responses to it.

The component does not store invoicing records: fiscal state resides in the main system and the records are remitted to the AEAT.

**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 component 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.

• 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: mosprit-fiscal 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]
• Email: [contact email]

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

• Website: [https://mos-prit.com/]
• Access to the history of responsible declarations for versions of this component: [https://mos-prit.com/legal/declaracion-responsable — page shared with the Mosprit product]

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:

• The issue date of the records is determined in the Spanish peninsular time zone (Europe/Madrid).
• Invoice lines are grouped by tax rate and taxable bases and tax amounts are calculated once per group, avoiding the accumulation of rounding errors; the total amount corresponds exactly to the amount charged.
• Every record-creation request carries an idempotency key derived from the document’s unique identifier, so that retries after network failures cannot generate duplicate records.
• The component offers no functionality for altering or deleting records; amendments and cancellations are processed exclusively through the records provided for by the regulations.