Your TPV is also an invoicing system
RD 1007/2023 does not talk about "invoicing programs" in the abstract. Its article 1.2 defines the computerised invoicing system as "the set of hardware and software used to issue invoices", which accepts the information by any method, keeps it and processes it. And the same paragraph clarifies that, for these purposes, the term invoice includes the full one and the factura simplificada (simplified invoice).
A hospitality TPV, a hairdresser's terminal or a cash register that prints tickets with the data of a simplified invoice fits squarely into that definition. It does not need to be called an "invoicing program" or have a computer: the touchscreen, the printer and the software behind them form the system. What is not one, according to the AEAT's frequently asked questions (the AEAT is the Spanish tax agency), is the scale that only weighs and gives an amount that you then key into the till: in that case the system is the till, not the scale.
Article 3.1 extends the obligation to companies, autónomos with an economic activity, permanent establishments and entities under income attribution that use an invoicing system, "even if they use it only for part of their activity". There is no exemption for being small or for invoicing little. Outside are, under article 3.3, those who keep their books through the SII (immediate VAT reporting); under article 1.3, those whose tax domicile is in the Basque Country or Navarre; and under article 3.1.a), entities fully exempt under article 9.1 of the corporate income tax law.
What changes on the ticket: the QR and the chain
For the customer, the visible change is a QR code printed on the ticket, which lets them check it against the AEAT. If your system works in VERI*FACTU mode, a legend identifying it also appears next to the QR. For you, the invisible change is that every ticket generates a billing record chained to the previous one by a hash: a ticket can no longer be deleted or its amount changed without leaving a trace. The two modes and their requirements are in what Verifactu is.
The type of document does not change. In hospitality and catering, in hairdressing and beauty salons and in retail you can keep using a simplified invoice up to 3,000 euros including IVA (VAT), under article 4.2 of the Reglamento de facturación (the invoicing regulation). What changes is the system that issues it.
A detail the AEAT clarifies: if at close of day you produce a summary or a recapitulative invoice to make a single accounting entry, that avoids nothing. Every simplified invoice you issued during the day is subject to the regulation and, in VERI*FACTU mode, is reported one by one.
The old cash register and the paper pad
The cash register that prints simplified invoices is an invoicing system. The AEAT says so for the small shop: if the register records sales and prints for each one what should be a simplified invoice, you have to comply, "either by adapting the cash registers (if this were possible), or by acquiring" an adapted system. Many old registers cannot be updated; ask the manufacturer or distributor before assuming yours can.
The paper pad or receipt book is outside: if you issue all your invoices by hand, you use no computer system and the regulation does not reach you. Beware of the nuance the AEAT adds: as a general rule, one part of the invoicing cannot be done with a computer system and another by hand. If the TPV issues your tickets, invoices to companies should not come out of the pad either.
If you want to move from paper to something computerised at no cost, there is the AEAT's free application, but it requires an identified recipient on every invoice, so it does not work for counter tickets to anonymous customers.
Módulos and recargo de equivalencia: who is really outside
A lot of half-information circulates here. Article 3 of RD 1007/2023 does not exclude anyone because of their IVA or income tax regime: neither those under estimación objetiva (módulos, the flat-rate income tax scheme), nor those under recargo de equivalencia (the retail equivalence surcharge). What happens is something else: the Reglamento de facturación releases those regimes from the duty to issue an invoice in certain cases, and if you do not issue invoices with a system, Verifactu has nothing to regulate.
- Recargo de equivalencia. Article 3.1.b) of the Reglamento de facturación says there is no duty to invoice the transactions of those activities, except deliveries of real estate and except in the cases of article 2.2 (a business customer, a public administration or a legal person that is not a business, or someone who requires it for a tax right).
- Simplified IVA regime (módulos). Article 3.1.c) says the same, unless the quotas are determined by volume of income, with the exception of the sale of fixed assets and, again, except in the cases of article 2.2.
- But income tax rules. Article 26.1 requires an invoice from every autónomo who determines their income under estimación directa (direct estimation), "regardless of the regime they are under" for IVA, and also from anyone under estimación objetiva whose income is calculated by volume of income. The AEAT gives the example of the pharmacy under recargo de equivalencia: Verifactu affects it because it is taxed under estimación directa.
- And article 2.2 as well. It requires invoicing in every case, whatever your regime, when the recipient is a business owner or professional acting as such, a public administration or a legal person that is not a business, or when the buyer requires it for a tax right.
In short: the business outside Verifactu is one that is not required to invoice and also issues no invoices, full or simplified, with any computer system. According to the AEAT, receipts that are neither an invoice nor a simplified invoice, issued in excepted transactions, are not subject to the regulation. As soon as your TPV prints simplified invoices, even voluntarily, it has to comply.
Typical situations and their obligation
| Situation | Required to invoice? | Verifactu |
|---|---|---|
| Bar of an autónomo under módulos (estimación objetiva by signs, indices or modules, and simplified IVA regime) | In general no (articles 3.1.c and 26 of the Reglamento de facturación), except in the cases of article 2.2 (a business customer, a public administration or a legal person that is not a business, or someone who requires it for a tax right) | If the TPV prints simplified invoices, even voluntarily, it must comply before 1 July 2027. If it only issues receipts that are not invoices, those receipts are outside; mandatory invoices, on paper or with a compliant system, never both at once |
| Restaurant run as an SL | Yes (article 2.1 of the Reglamento de facturación) | TPV adapted before 1 January 2027. Tickets as simplified invoices up to 3,000 euros (article 4.2.e) |
| Hairdresser of a self-employed woman under estimación directa | Yes, whatever her IVA regime (article 26.1) | TPV adapted before 1 July 2027. Simplified invoices up to 3,000 euros (article 4.2.h) |
| Shop of an autónomo under recargo de equivalencia | Not for IVA (article 3.1.b), but yes if their income tax is under estimación directa (article 26.1) | Under estimación directa, TPV adapted before 1 July 2027. Under módulos, like the bar: only if it issues invoices with a system |
The dates are those of Royal Decree-law 15/2025: corporate income tax taxpayers before 1 January 2027, and everyone else, autónomos included, before 1 July 2027. What happened with the postponements is in the Verifactu postponement, and the detail for those who work for themselves is in Verifactu for autónomos.
The TPV issues, the accounting records
It is common to have two programs: the TPV at the counter and accounting software, your own or your gestoría's (tax adviser's). For Verifactu they do not play the same role. The one that issues the invoice is the one that has to comply: the TPV that prints the ticket. The accounting program that later receives the sales summary to make the entry does not issue invoices by receiving that data.
If you also issue full invoices from another program, for example to the companies that hire you for catering, each system keeps its own chain of records and each has to comply separately. What does not work is having part of your invoicing come out of an unadapted tool. When a business customer asks you for an invoice for a ticket already issued, the full invoice is issued in place of the simplified one, with nothing to correct (article 15.6 of the Reglamento de facturación); what data it carries is covered in your first invoice.
The responsibility, in any case, is yours. The fine is 50,000 euros per year for having a non-compliant or altered system (article 201 bis, paragraphs 2 and 4, of the Ley General Tributaria, the general tax law), and it is aimed at the business that uses it.
What to ask your TPV provider
- The declaración responsable (the producer's responsibility statement) under article 15 of Order HAC/1177/2024, visible in the TPV itself and referring to the version you have installed. An "AEAT certificate" does not exist.
- Whether your current equipment can be updated or has to be replaced, and what each costs. Ask for it in writing and dated.
- The mode: VERI*FACTU, with automatic submission, or non-VERI*FACTU, with each record signed.
- That the ticket printer prints the QR with enough quality to be scanned.
- What happens without internet: records must be queued and sent as soon as the connection returns, without stopping sales.
- How a ticket is corrected (cancellation only applies if it was issued by mistake) and how the full invoice that replaces it is made.
- How it works with several tills or several terminals in the same premises.
- How you export and keep the records if you change provider tomorrow.
Do it in 2026. SLs have the last quarter of this year to get it operational, and in hospitality changing TPV in high season is the last thing you want.
Frequently asked questions
Does Verifactu force bars to change their TPV?
I am under módulos. Does Verifactu affect me?
I have a shop under recargo de equivalencia. Am I exempt?
Can I keep writing tickets by hand with a receipt book?
Can the customer scan the QR on my ticket?
Does the AEAT free application work for the counter?
Keep reading
What is Verifactu and does it affect you?
Verifactu for autónomos: your July 2027 deadline explained
The AEAT free invoicing app: when it is enough and when it is not
Rather have this calculated for you?
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