62% of Spanish SMEs and self-employed professionals still have no plan to align their invoicing with VeriFactu, according to a TeamSystem study from November 2025. The confusion is compounded by conflicting dates circulating online — 2025, 2026, 2027 — so which one is correct? This guide cuts through the regulatory noise using official sources: what VeriFactu actually is, who is affected and from when following the latest postponement, what technical requirements apply, what fines are at stake, and — most importantly — how to turn this compliance obligation into a genuine opportunity to automate your entire invoicing cycle.
What Is VeriFactu and Who Does It Affect?
VeriFactu is the popular name for the Reglamento de Requisitos de los Sistemas Informáticos de Facturación (RRSIF — Regulation on Requirements for Invoicing Computer Systems), approved by Real Decreto 1007/2023. In practical terms: if you issue invoices using software, that software must ensure every invoice is recorded in a complete, unalterable, and traceable way — with a chained digital fingerprint and a tax QR code. The Spanish Tax Agency's (Agencia Tributaria — AEAT) goal is to close the door on so-called "dual-use software" capable of concealing or manipulating sales records.
The regulation affects the vast majority of Spain's business community. Economic press estimates based on AEAT data point to approximately 4.6 million taxpayers — self-employed professionals and SMEs alike. If you pay Corporate Income Tax (Impuesto sobre Sociedades), Personal Income Tax (IRPF) with business activity, or you are an entity under the income attribution regime, and you invoice using software, VeriFactu applies to you.
Four main groups are excluded:
- Companies enrolled in the SII (Suministro Inmediato de Información — Immediate Supply of Information system), which already send their VAT records to the AEAT in near real time.
- Foral territories: the Basque Country has its own system (TicketBAI) and Navarre has its own regional framework. Note: a company registered in a foral territory with operations in the common territory may be subject to both regimes.
- Businesses that use no invoicing software whatsoever and invoice entirely on paper by hand.
- Certain transactions already exempt under the invoicing regulations.
When Does VeriFactu Become Mandatory? The Real Deadlines After the Postponement
As of today, no self-employed professional or company is yet required to invoice under VeriFactu. This is the short answer that many articles still get wrong, because the timeline has changed twice:
| Regulation | Companies (Corporate Tax) | Self-employed and others |
|---|---|---|
| RD 1007/2023 (original schedule) | 1 July 2025 | 1 July 2025 |
| RD 254/2025 (first postponement) | 1 January 2026 | 1 July 2026 |
| RD-ley 15/2025 (current schedule) | Before 1 January 2027 | Before 1 July 2027 |
The second postponement came with Real Decreto-ley 15/2025 (published in the Official State Gazette — BOE — on 3 December 2025) and is the schedule currently in force, as confirmed by the AEAT's own information note. The intermediate 2026 dates that still appear in many guides were repealed before they ever took effect.
One deadline that has already passed applies to software manufacturers and distributors. Since 29 July 2025, only invoicing systems already adapted to the regulation — with their declaración responsable (manufacturer's responsible declaration) — may be placed on the market. The practical implication: any invoicing software you purchase today should already be compliant. If your provider cannot demonstrate this, treat it as a red flag.
The absence of a current obligation does not mean waiting is wise. Voluntary submission of records to the AEAT is already operational, and adapting invoicing processes integrated with ERP, accounting, and payment systems takes months, not weeks. Companies have five months; self-employed professionals have eleven.
How It Works: Invoicing Records, Chained Hash, and QR Code
The regulation does not change what an invoice is — it changes how your software generates and stores it. Each time you issue (or cancel) an invoice, the system must create an invoicing record in XML format with a chained digital fingerprint (hash) linked to the previous record. That chaining makes any subsequent alteration detectable: if someone deletes or modifies an invoice, the chain breaks.
In addition, every invoice issued by a compliant system includes a tax QR code (between 30×30 and 40×40 mm, as specified in Orden HAC/1177/2024) containing the AEAT's verification URL along with the issuer's NIF (tax ID), invoice number, date, and total amount. The recipient can scan it and verify the invoice directly with the tax authority.
Beyond that baseline, the regulation offers two operating modes:
- VERI*FACTU mode (verifiable): your software automatically submits each invoicing record to the AEAT at the moment of issuance. In exchange, you are exempt from electronically signing the records and from maintaining a software event log. Invoices include the legend "Factura verificable en la sede electrónica de la AEAT" (Invoice verifiable on the AEAT's electronic headquarters).
- Non-verifiable mode: you do not submit anything to the tax authority at the point of issuance, but your system must apply stronger internal controls: electronic signing of each record and a software event log, all preserved and available to the administration on request.
An important nuance that many articles get wrong: in VERI*FACTU mode, the AEAT does not "approve" your invoices. Submission is informational; there is no prior validation or invoice-by-invoice sign-off.
There is also no such thing as "AEAT-certified software." What the regulation requires is a declaración responsable from the manufacturer — a document in which the manufacturer affirms under its own responsibility that the system complies with the regulation, including the system name, its identifying code, components, and version. Request this from your provider: it is your primary documentary guarantee.
What Do SMEs and Self-Employed Professionals Need to Do to Comply?
Adapting to VeriFactu is less about administrative red tape and more about process decisions. These are the steps we recommend, in order:
- Confirm whether you fall within scope: do you invoice using software? Are you enrolled in the SII or operating in a foral territory? If you invoice exclusively using Word or Excel templates without invoicing functions, you are in principle outside the regulation — though the Dirección General de Tributos (Directorate-General for Taxation) has already flagged grey areas: a spreadsheet with macros or invoice lists may qualify as invoicing software. Continuing to invoice "manually" in 2027 is legal, but it forfeits any efficiency gains.
- Inventory your invoicing systems: many SMEs discover at this stage that they issue invoices from two or three different tools (ERP, point-of-sale, standalone spreadsheets). Every tool acting as an invoicing computer system must comply.
- Request the declaración responsable from your providers and their adaptation roadmap if not yet published.
- Choose your mode: for most SMEs, VERI*FACTU is the straightforward option — fewer internal technical requirements and a transparency signal to clients. The non-verifiable mode makes sense in specific situations (for example, limited connectivity or internal data governance policies).
- Consider the AEAT's free application: since October 2025, the Tax Agency has offered a free VERI*FACTU invoicing application on its website, with no invoice limit, accessible via Cl@ve or digital certificate. For a self-employed professional issuing a handful of invoices per month, it is a viable option. Its limitations appear quickly, however: it does not integrate with your accounting system, your ERP, or your payment processes, and it does not manage client and product catalogues with the depth of a professional tool.
- Use this as an opportunity to automate: if you are going to overhaul your invoicing, do it once and do it right. Automating electronic invoicing means invoice issuance, VeriFactu recording, accounting entries, and payment reconciliation can all run as a single, uninterrupted flow with no manual intervention.
The starting picture leaves ample room for improvement: according to a December 2025 study by Qonto and IO Investigación covering 304 finance managers, only 2 in 10 Spanish SMEs already met the requirements. Among companies with fewer than 50 employees, the share that were not yet ready reached 82%. The gap by company size is notable: 37% of companies invoicing more than €1 million already comply, versus 13% of those invoicing less than €100,000.
Penalties: Up to €50,000 per Tax Year
The penalty regime has been in place since Ley Antifraude 11/2021 (Anti-Fraud Law), which introduced Article 201 bis into the Ley General Tributaria (General Tax Law — LGT), and the stakes are significant:
- For the end user: possessing or using non-compliant (or manipulated) invoicing software is subject to a fixed fine of €50,000 per tax year. The AEAT does not need to prove fraud: mere possession of non-compliant software is already punishable.
- For the software manufacturer or distributor: €150,000 per tax year per system type, plus €1,000 per system sold without the required declaración responsable.
Key point: the €50,000 penalty applies per tax year. Non-compliant software used across three tax years can result in three cumulative fines. Adapting costs far less in most cases: 52% of SMEs estimate the cost of adaptation at below €5,000 (Qonto/IO, 2025).
VeriFactu and Mandatory Electronic Invoicing: They Are Not the Same Thing
This is the most widespread source of confusion, and it is worth resolving clearly because these are two distinct obligations that will arrive almost in parallel:
| VeriFactu (RRSIF) | B2B Electronic Invoicing (Ley Crea y Crece) | |
|---|---|---|
| What it regulates | How your software records invoices (anti-fraud fiscal control) | The format and electronic exchange of invoices between businesses (combating late payment) |
| Regulation | RD 1007/2023 + Orden HAC/1177/2024 | Ley 18/2022 + RD 238/2026 |
| Timeline | Before 1-1-2027 (companies) and 1-7-2027 (self-employed) | 12 months (billing >€8M) or 24 months (others) from the future ministerial order on the public solution: in practice, between 2027 and 2029 |
| Who it applies to | Anyone invoicing with software | All B2B transactions between Spanish companies and self-employed professionals |
We have also published a complete guide to Spain's mandatory B2B e-invoicing covering the real timeline, the AEAT public platform and the penalties.
The regulatory framework for mandatory B2B electronic invoicing was finally approved in March 2026 (Real Decreto 238/2026, in force since 20 April 2026). It defines four accepted syntaxes (Facturae, UBL, CII, and EDIFACT) based on the European semantic model EN 16931, and requires the recipient to communicate invoice status — acceptance, rejection, and full payment — within 4 working days.
The strategic takeaway: any investment you make now for VeriFactu should also leave you ready for mandatory B2B electronic invoicing. Adapting twice, with two separate projects and two separate budgets, is the expensive mistake that can already be avoided by choosing the right architecture from the outset.
How to Prepare Your Invoicing Without Paying for Adaptation Twice
At Technova Partners, we approach VeriFactu for what it truly is: a transformation project for the entire order-to-cash cycle, not a compliance checkbox.
"The company that treats VeriFactu as a simple software patch in 2026 will reopen the same project in 2028 for mandatory B2B electronic invoicing. The one that treats it as a redesign of its entire invoicing cycle will close it once and for all," says Alfons Marques, founder of Technova Partners.
The approach we apply with our clients works on four fronts:
- Systems diagnosis: which tools currently issue invoices, which are compliant, which ones make sense to consolidate. Fewer invoicing systems almost always means better compliance and lower cost.
- Compliant and future-proof architecture: choosing the right mode (VERI*FACTU in most cases), securing the declaración responsable for every component, and designing the integration with RD 238/2026 already in view: EN 16931 formats, invoice status communications, and connectivity with the future public platform.
- Process automation: order capture, issuance, recording, accounting entries, and payment reconciliation operating as one continuous flow. Compliance stops being a cost and starts saving administrative hours every week.
- Team enablement: invoicing touches finance, sales, and management; adoption matters as much as technology.
Want to know where your invoicing currently stands and what you still need to comply? Tell us about your situation and we will prepare an initial assessment at no obligation.
Conclusion
VeriFactu is real, but the timeline is clear: companies must comply before 1 January 2027, and self-employed professionals before 1 July 2027, under the currently applicable RD-ley 15/2025. Any software you purchase today must already be compliant, the penalties — up to €50,000 per tax year — do not require proven fraud, and mandatory B2B electronic invoicing under RD 238/2026 will arrive right behind it. The smart question is not "which software should I buy to comply?" but "how do I redesign my invoicing to comply with both regulations, just once, and automate the process at the same time?" The 2027 deadlines may seem distant; a well-executed integration project is not.
Frequently Asked Questions About VeriFactu
Is VeriFactu already mandatory in 2026?
No. Following the second postponement approved by RD-ley 15/2025, companies must comply before 1 January 2027 and self-employed professionals before 1 July 2027. What has been in effect since 29 July 2025 is the obligation for manufacturers: all invoicing software placed on the market must already be adapted and must carry a declaración responsable.
Can I keep invoicing with Word or Excel?
If your templates do not process or store invoices — meaning they do not function as an invoicing computer system — you are in principle outside the scope of the regulation. The Dirección General de Tributos has nevertheless flagged grey areas: a spreadsheet containing macros or invoice lists may be considered invoicing software. And forgoing a digital system also means forgoing the efficiency gains it provides.
What if my company is enrolled in the SII or in a foral territory?
Companies enrolled in the SII are excluded from VeriFactu because they already submit their VAT records to the AEAT. In the Basque Country, TicketBAI applies; in Navarre, the region's own system. Watch out for mixed situations: a company registered in a foral territory with operations in the common territory may need to comply with both regimes simultaneously.
Is VeriFactu the same as mandatory electronic invoicing?
No. VeriFactu regulates how your software records invoices (the AEAT's anti-fraud control mechanism); mandatory electronic invoicing under the Ley Crea y Crece, developed through RD 238/2026, regulates the format and electronic exchange of invoices between businesses to combat late payment. These are distinct obligations with distinct timelines, and it is worth addressing both in a single, unified technology adaptation project.
