When paper is allowed
Article 22 permits manual invoices carrying a QR code, and it is specific about when. It is not a convenience for a busy service or a broken printer. The conditions it lists are:
- The Electronic Invoice Registration System is not functioning.
- The Authority has notified taxpayers, through public media, that the system is down for a known reason or through force majeure.
- The sales register software runs offline and its stock of registered backup invoices is exhausted, with no more obtainable.
- The nature of the business is such that not issuing an invoice during the interruption would mean losing the sale.
The last of those is the one a restaurant relies on. A diner who has finished a meal is not going to wait at the door while a line comes back, and the directive accepts that rather than pretending otherwise.
The 72 hours
This is the duty attached to the paper. Within 72 hours after the problem is resolved and the connection to the Authority’s Electronic Invoice Registration System is restored, every transaction executed on a manual QR invoice has to be registered in that system, quoting the invoice number.
Three details in that sentence decide whether a restaurant complies. The clock starts when the connection returns, not when the invoice was written, so a three-day outage does not consume any of it. Every invoice is registered individually and against its own number, so twenty paper invoices are twenty registrations. And the whole batch shares one deadline, which is what makes a long outage dangerous: the work grows while the time to do it stays at 72 hours.
What that means on a Saturday night
The failure mode is not the outage. It is the Monday after one. Service continues on paper, the line comes back at some point that nobody notices precisely, and the stack of invoices sits by the register until somebody has an afternoon. By then the 72 hours may have run, and nothing in the building has said so.
What prevents that is unglamorous: write down each invoice as it is issued rather than reconstructing the stack afterwards, know the moment registration became possible again, and count what is still outstanding against that moment rather than against a feeling of how long ago it was.
Who has to do it
The duty is the taxpayer’s. A supplier can build a system that records each paper invoice, times the deadline and files them when the specification for filing exists, but the obligation to register sits with the business that made the sale, and it is the business that answers for a missed one.
Filing itself is done in the Authority’s own Electronic Invoice Registration System, and the reference it returns is the proof the invoice was registered. Keep those references with the invoices they belong to. A registration nobody can evidence is, on an inspection, a registration that did not happen.
A working practice
- Record every paper invoice as it is written: its number, the total, the tax on it, and the time.
- Note when the connection came back. That moment starts the clock for every invoice in the outage.
- Register each one in the Authority’s system, quoting its number, and keep the reference you get back.
- Keep the paper. The invoice the customer holds and the record you registered from should agree.
This is a summary written for restaurant owners, not legal advice. Article 22 is the authority on itself, and your accountant or the Ministry of Revenues is the authority on how it applies to your business.