Key data
| Regulation | Resolution of October 19, 2026, from the General Directorate of the AEAT, relating to tax inspection reports |
|---|---|
| Publication | October 28, 2026 |
| Entry into force | October 29, 2026 |
| Repeals | 2007 Resolution on inspection report models |
| Affected parties | Taxpayers subject to AEAT tax inspection and tax advisors |
| Category | Tax Updates |
| Year | 2026 |
If your company is being inspected by the AEAT or may be in the future, the procedure has just changed. The Resolution of October 19, 2026 from the General Directorate of the State Tax Administration Agency repeals the 2007 regulations on inspection report models and establishes a new, more flexible and digitalized framework, in force from October 29, 2026.
The change is not cosmetic: it affects how agreements and discrepancies with the tax authority are formalized, and opens the door for the entire process to be conducted remotely via videoconference.
What does this regulation establish?
The resolution introduces three structural changes compared to the previous 2007 regime:
1. Elimination of mandatory predetermined models
Until now, the AEAT was required to use fixed and predefined forms to draw up inspection reports. This obligation is now eliminated, in line with the elimination of article 176.4 of the General Regulation of tax management and inspection procedures, operated by Royal Decree 1070/2017. Reports will now be generated through the AEAT's own computer systems, with greater formal flexibility.
2. The three types of reports are maintained with their codes
The resolution consolidates the three types of inspection reports that already existed, now with explicit identification by code:
| Code | Type of report | Description |
|---|---|---|
| A01 | Conformity report | The taxpayer accepts the AEAT's regularization proposal |
| A02 | Non-conformity report | The taxpayer does not accept the proposal and may file objections |
| A11 | Report with agreement | There is prior agreement between the AEAT and the taxpayer on elements of uncertain valuation |
3. Electronic signature and remote videoconference modality
The most operationally relevant novelty: reports may be signed electronically, including the remote modality via videoconference. This option requires express consent from the taxpayer. That is, the taxpayer can reject this method and require the physical presence of the inspector.
Mandatory minimum content of reports
Regardless of type, all reports must include:
- Identification of the taxpayer
- Unique report number
- Legal mentions required by the General Tax Law (LGT) and its implementing regulations
Comparison: before and after
| Aspect | Previous regime (2007) | New regime (2026) |
|---|---|---|
| Report models | Predetermined and mandatory | Generated by AEAT computer systems, without fixed model |
| Signature | In-person | Electronic, even via videoconference |
| Videoconference | Not provided for | Permitted with taxpayer consent |
| Types of reports | Three types (without unified explicit coding) | Three types with codes A01, A02 and A11 |
| Regulatory basis | 2007 Resolution + art. 176.4 Regulation | 2026 Resolution (art. 176.4 already repealed by RD 1070/2017) |
Economic and operational impact
This change does not generate direct costs for companies, but it does have relevant operational consequences that can affect the outcome of an inspection:
- Greater agility in closing reports: electronic signature and videoconference reduce travel and coordination times, which can accelerate the resolution of inspection procedures.
- Risk of hasty signature: the ease of signing remotely can lead taxpayers to sign conformity reports (A01) without sufficient analysis. Once a conformity report is signed, the possibilities for challenge are very limited.
- Right to reject videoconference: taxpayer consent is a legal requirement. If you or your advisor prefer the physical presence of the inspector, you can require it without consequences.
- Impact on defense strategy: knowing the three types of report and their implications (especially the difference between A01 and A02) is key to deciding how to position yourself before a regularization.
Who does it affect?
- Companies and self-employed individuals subject to AEAT tax inspection procedures
- Tax advisors and managers representing taxpayers in inspections
- Chief Financial Officers (CFOs) and tax compliance officers in medium and large companies
- Law firms specializing in tax law assisting clients in inspection procedures
- Taxpayers with open inspection files or that may open from October 29, 2026 onwards
Practical example
A medium-sized company receives a notification of the start of inspection proceedings from the AEAT in November 2026. The assigned inspector proposes to sign the final report via videoconference to avoid travel.
Under the new regime, the company has two options:
- Accept the videoconference and sign the report electronically at a distance. If the proposal is reasonable and the tax advisor has already reviewed it, this method is perfectly valid and more agile.
- Reject the videoconference and require in-person signature. This is a taxpayer right and cannot be penalized.
If the company accepts the regularization proposal, it will sign a conformity report A01. If it disagrees, it will opt for a non-conformity report A02 and may file objections. If there are elements of uncertain valuation and prior negotiation with the AEAT takes place, closure can occur through a report with agreement A11, which offers penalty reduction.
The key: never sign a conformity report without the tax advisor having reviewed the liquidation proposal in detail. Electronic signature at a distance does not change the legal consequences of the report.
What should companies do now?
- Inform the financial and legal team that inspection reports can now be signed electronically and remotely. No one should sign anything without express authorization from the tax advisor.
- Review internal inspection response protocols to include the new videoconference possibility and establish who has authority to consent to or reject it.
- Know the three types of report (A01 conformity, A02 non-conformity, A11 with agreement) and their implications before an inspection occurs, not during.
- Ensure that the tax advisor is up to date with this regulatory change, especially if there are open or foreseeable inspection files.
- For any report signature proposal, request sufficient time for analysis, regardless of whether it is in-person or via videoconference. The agility of the new system should not translate into rushed decisions.
Frequently asked questions
What are the types of AEAT inspection reports in 2026?
The Resolution of October 19, 2026 consolidates three types: A01 (conformity report), when the taxpayer accepts the AEAT's proposal; A02 (non-conformity report), when they reject it and may file objections; and A11 (report with agreement), when there is prior agreement on elements of uncertain valuation. The codes A01, A02 and A11 are the official identifiers.
Can the AEAT force me to sign the report via videoconference?
No. Remote signature via videoconference requires express consent from the taxpayer, as established by the new resolution. If the taxpayer or their representative prefers in-person signature, they can require it without any negative consequences in the procedure.
What is the difference between signing an A01 report and an A02 report?
Signing a conformity report A01 means accepting the AEAT's regularization proposal, which greatly limits the possibilities for challenge later. The non-conformity report A02 allows the taxpayer to file objections and appeal the assessment. The choice between one and the other is a strategic decision that should be made with specialized tax advice.
When does the new regulation on inspection reports come into force?
The Resolution of October 19, 2026 came into force on October 29, 2026, one day after its publication in the BOE (October 28, 2026). It repeals the 2007 resolution that regulated inspection report models.
What information must an AEAT inspection report mandatorily include?
According to the new resolution, every report must include: the identification of the taxpayer, a unique report number and all legal mentions required by the General Tax Law (LGT) and its implementing regulations. Reports will be generated through the AEAT's own computer systems, without the need to comply with predetermined models.
Official source
Consult complete regulation at official source
Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-22592
