Verifactu: the question is not whether it affects you, but whether it will arrive on time
If you run a business or are self-employed, you’ve probably heard about Verifactu in three different ways over the last few months: that it was coming into force straight away, that it had been postponed, and that it might not affect you. All three versions are circulating at the same time, and this confusion comes at a cost: some people are paying for upgrades they don’t yet need… whilst others haven’t taken any action and will be issuing invoices in 2027 using software that could cost them up to 50,000 euros in fines per financial year.
In this article, we’ll explain – without technical jargon and using the actual dates – what Verifactu is, how to find out in two minutes whether it affects you, and what you should have sorted out before the end of the year.
What is Verifactu (explained in a minute)
Verifactu is the Tax Agency’s new standard for invoicing software, approved by Royal Decree 1007/2023 implementing the Anti-Fraud Act. The idea is simple: every invoice issued by your software must generate an unalterable, chained and verifiable record – complete with a QR code – so that no one can delete or tamper with it afterwards. Once issued, any correction requires a corrective invoice. In other words: ‘B’ accounts – even those created unintentionally due to administrative disorder – no longer have anywhere to hide.
The actual dates (and why it’s in your best interests to know them)
This is the information that causes the most confusion, and where bad advice can prove costly. The current timetable is set out in Royal Decree-Law 15/2025, which has already been approved by Parliament:
- Companies (Corporation Tax): mandatory from 1 January 2027.
- Self-employed individuals and other taxpayers: from 1 July 2027.
- Right now: voluntary phase. You can adapt and test the system without the threat of penalties.
Does this mean you can put the matter out of your mind until 2027? No, for two reasons. Firstly, because the penalty regime for dual-use software is already in force. And secondly, because anyone who leaves the migration until the final quarter of 2026 will face overburdened suppliers, rising prices and no scope to test anything. We saw this with the SII and with electronic signatures: those who adapt in good time do so more effectively and more cheaply.
Check in 2 minutes whether this affects you
Answer these four questions:
- Do you issue invoices using software, an ERP system or a POS terminal (even if only for part of your business)?
- Are you not covered by the Immediate Information Reporting Scheme (SII)? Most SMEs and self-employed people are.
- Do you pay tax in mainland Spain (not in the Basque Country or Navarre, which have their own regional tax systems)?
- Do you issue invoices using Excel, Word or templates? These systems will not meet the requirements: you will definitely need to migrate.
If you have answered ‘yes’ to the first three questions — or to the last one — Verifactu affects you. The question is no longer whether to adapt, but when and how to do so without any surprises or extra costs.
The mistakes we’re seeing (and which could cost you money)
- Relying on outdated dates. There are websites and marketing emails that still refer to 2026. Planning based on the wrong timeline leads to hasty decisions or, worse still, duplicate investments.
- Believing this is ‘the IT department’s job’. Verifactu is a tax obligation with penalties. The software is merely the means; the responsibility to the tax authorities lies with you.
- Failing to ask your software provider. Many maintenance contracts do not clarify whether the update is included, when it will be available or how much it will cost. That silence, with just a year to go, is a warning sign.
- Confusing Verifactu with the mandatory electronic invoice. These are two separate obligations: the B2B electronic invoice under the ‘Crea y Crece’ Act is still awaiting regulations and has no set date. Anyone who sells them to you together ‘because they’re the same thing’ is not advising you properly.
- Ignoring internal processes. With tamper-proof records, the usual ‘workarounds’ (reusing invoice numbers, cancelling and reissuing, improvised series) become visible issues. Adapting also means getting your house in order.
What happens if you do nothing
The General Tax Law (Art. 201 bis) penalises the mere possession or use of non-certified invoicing software with fines of up to 50,000 euros per financial year, in addition to the vulnerable position you find yourself in when facing an audit with invoicing that does not meet the standard. In contrast, a well-organised transition costs far less and, when properly planned, offers something valuable: traceable invoicing that strengthens your reputation with clients, banks and suppliers.
How we at SF Abogados can help you
We do not sell software: we defend you. That is why our support with Verifactu is independent and covers what a technology provider does not:
- Situation assessment: we analyse your invoicing practices and inform you, in writing, whether you are obliged to comply, from when, and what options you have (including whether or not it is advisable to voluntarily submit your records to the AEAT).
- Review of your supplier and contracts: we examine what compliance commitments your software or POS terminal has and ensure any missing guarantees are in place before it is too late to switch.
- Adaptation plan with a timetable: invoicing processes, invoice series, corrective invoices and training for your administrative team, so that everything is fully tested by 2027.
- Defence against the tax authorities: if you have already received a notice or are subject to an ongoing audit relating to your invoicing, we’ll take on your defence from the very first letter.
Take the first step today: Verifactu assessment
Tell us how you invoice and we’ll tell you, based on actual dates, what affects you, what doesn’t, and what you need to resolve this year. Email us at www.sfabogados.com or call us, and a tax lawyer will review your case.
Quick questions
Do I have to send all my invoices to the tax authorities in real time? No. What is mandatory is that your software generates verifiable records. Automatic submission to the AEAT (the ‘Verifactu’ method in the strict sense) is optional, although it simplifies technical requirements and provides security.
I issue very few invoices – am I exempt? The volume does not exempt you. The decisive factor is whether you use (or will be required to use) a computerised invoicing system and whether you are outside the SII system.
My accountancy firm issues my invoices – is that their problem or mine? Liability to the tax authorities lies with the issuer: you. Ensure that whoever issues your invoices uses compliant software.
I’ve already invested in adapting my business with 2026 in mind – have I wasted my money? No: the technical regulations haven’t changed, only the deadlines. You’re ahead of the game and can already take advantage of the voluntary compliance period.
Article prepared by SF Abogados on 2 July 2026 based on Royal Decree 1007/2023, Order HAC/1177/2024, Article 201 bis of Law 58/2003 (General Tax Law), and Royal Decree-Law 15/2025 (BOE 3 December 2025), ratified by the Congress of Deputies. This is for information purposes only; it does not constitute tax advice on a specific case.
