- Short answer
- In Bizkaia you keep the LROE book: TicketBAI invoices enter it automatically, and it also covers your expenses.
- Filing for you
- Your representative, such as an advisor, can view entries; submitting them for you needs a separate authorization request
- TicketBAI exemption for closing down
- Doesn't lift the LROE duty, Batuz says
- How you keep it
- Software adapted to the rules, or the Diputación Foral de Bizkaia's app
Who has to keep the LROE book in Bizkaia?
Batuz, Bizkaia's system that also includes TicketBAI, puts the LROE on Bizkaia taxpayers with an economic activity, non-residents with a permanent establishment included (model 240), to record income and issued invoices, expenses and received invoices, and other tax-relevant operations.
You keep it in software adapted to the rules or the Diputación Foral de Bizkaia's app, within deadlines set by Decreto Foral 82/2020; the calendar's last wave, including corporate-tax-exempt entities and non-profits, began on January 1, 2026.
| You are | Your book | In force for retail from |
|---|---|---|
| Individual, comunidad de bienes, sociedad civil or other income-attribution entity (ERAR) | Model 140 | July 1, 2025 |
| Micro, small or medium company | Model 240 | January 1, 2025 |
| Company that isn't micro, small or medium | Model 240 | January 1, 2024, any activity |
Source: Batuz LROE page and Norma Foral 8/2023 calendar, archived April 11, 2026.
What goes in the book besides TicketBAI invoices?
Batuz says TicketBAI invoices enter the book automatically (how Shopify POS handles TicketBAI), and a TicketBAI exemption for winding down the business would not lift the LROE duty.
Both the 140 and 240 books have a chapter for received invoices, which model 140 calls "expenses and received invoices"; in Batuz's model 140 example, you log an expense without an invoice under "gastos sin factura" (expenses without invoice).
Can Comply or your tax advisor keep it for you?
Comply, an app that handles TicketBAI at Shopify POS, has you download a document authorizing DAP Consulting SL, its provider, to submit your TicketBAI files to Bizkaia's tax authority (Hacienda Foral). Comply's setup guide sets the limit:
It's limited exclusively to that electronic submission and doesn't grant general powers of representation.
Comply names the LROE as part of Batuz in Bizkaia, but its help pages and App Store listing we checked on October 6, 2026 don't say Comply keeps it; nor do the archived Batuz pages we read that day.
Your representative, such as an advisor, can view your entries; submitting them for you needs its own authorization request in ebizkaia, per the Batuz FAQ. Agree with your advisor who logs expenses and received invoices.
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