Verifactu and Excel: what the rules say and what the AEAT clarifies
Verifactu, the verifiable invoicing system created by Royal Decree 1007/2023, does not regulate files, it regulates computerised invoicing systems. Article 1.2 of Royal Decree 1007/2023 defines them as the set of hardware and software used to issue invoices that does three things: accepts the input of invoicing data, keeps it (including printing it on paper or sending it to another system) and processes it to produce other derived results.
The AEAT turns that definition into practice in a frequently asked question on spreadsheets and word processors. According to it, the regulation does not affect you if you use Excel, Numbers, Word or Pages exclusively to:
- enter the invoice data;
- issue and print it;
- keep the information.
By contrast, the sheet is a computerised invoicing system if it also processes that information to directly generate your VAT or personal income tax (IRPF) record books, your accounts or any other result you use to comply with the tax authorities. The AEAT's own example: a list of invoices with totals does not turn you into a system; a macro that builds the book of issued invoices does. The AEAT adds that it may check whether your sheet meets the criteria of a system "according to the capabilities and tools they use".
Careful, because there is a lot of confusion here. A template that you only fill in and print stays outside just like a handwritten invoice book: it does not comply with Verifactu, it is simply not covered. What does not exist is an Excel "adapted to Verifactu". You will find the general context in what Verifactu is.
Why a spreadsheet cannot be a Verifactu system
If your sheet falls within the definition, it has to comply with article 8 of the regulation. And that is where any spreadsheet falls short, by design:
| What the rules require | Why Excel or Word fall short |
|---|---|
| Integrity and inalterability (art. 8.2.a): once generated, the record cannot be altered without the system detecting it and raising an alert; any correction goes in a new record. | In a sheet you change a cell, save and no trace remains. Nothing detects or warns. |
| Traceability (art. 8.2.b): records chained from the first to the last, dated with the moment of recording. | Rows can be sorted, inserted or deleted without anything visibly breaking. |
| Keeping and export (art. 8.2.c): download and secure storage of the records in a readable format. | You save the file, but not a protected record of each invoice. |
| Event log (art. 8.3): automatically noting interactions with the system. | It does not exist. |
| Simultaneous recording (art. 9): the issue record is generated at the same time as, or immediately before, the invoice is issued. | The invoice comes out when you print; no record is born with it. |
| Fingerprint and signature (arts. 12 and 16.3): each record carries its fingerprint or "hash" and, except in VERI*FACTU mode, an electronic signature. | It calculates neither. |
| QR code on the invoice (art. 6.5 of the Invoicing Regulation). | You could paste in an image, but a QR that does not correspond to a real record is useless. |
There is one more detail few people know. If you program that sheet yourself with macros, the AEAT considers that you are the producer and that you must sign the declaración responsable (the producer's formal statement of compliance) of article 13, as it explains in its frequently asked questions on the declaración responsable. Signing that an editable sheet guarantees inalterability would simply be false. And having, from your deadline, a non-compliant system capable of invoicing is the conduct punished with 50,000 euros per year by article 201 bis, sections 2 and 4, of the Ley General Tributaria (General Tax Law); full details in Verifactu penalties.
Word or Excel invoice template with Verifactu: when it is still fine
If you want to keep your Word or Excel invoice template after your deadline, these are the conditions that follow from the AEAT's criterion:
- The template is only used to type, print or turn into a PDF and file. You can keep a separate list with totals for your own control.
- Nothing is processed automatically. No macros that generate the record book, no formulas that dump the data into your accounts, no automations that prepare your tax forms.
- All your invoicing goes the same way. If any invoice comes out of a program, the rule in the next section comes into play.
- The invoice still meets the usual Invoicing Regulation: sequential number within its series, date, details of the parties, taxable base, rate and VAT amount. You have it point by point in what your first invoice must contain.
What you lose with the template is everything a program does: the QR your client can check, guaranteed gap-free numbering and the transfer to your record books, which you will have to keep elsewhere, by hand or with your gestor (accountant-adviser). The template is not illegal, but it does not save you work either.
The trap of printing from Excel and then entering it in the program
It is the easiest mistake to make in 2027, and it comes in two versions.
First: you have a program, but "I make that invoice in Excel because it is quicker". The AEAT is blunt in its frequently asked questions on scope: as a general rule, invoices issued with a computerised system and invoices made by another route cannot coexist; if you use a system that produces invoices, all your invoicing must be computerised. The regulation applies "even if they use them only for part of their activity" (art. 3.1). The only exception the AEAT cites is electronic invoices to public administrations issued through MiFacturae and FACe by someone who uses no invoicing system at all.
Second: you make the invoice in Excel, send it to the client and then type it into the program "so it is registered". It fixes nothing. The record must be born at the same time as, or immediately before, issue (art. 9), and the invoice had already been issued. If the program issues it again, you will have two documents for one transaction: the one your client has, with no QR, and another with a QR that your client never received. An invoice is not fixed by issuing it twice; if there are errors, they are corrected with a factura rectificativa (corrective invoice).
Booking is different. If you issue your invoices by hand or with a template and hand them to your gestor to enter in their accounting program, the AEAT says the regulation does not affect you: entering an invoice already issued is not issuing it. What you cannot do is have your gestor issue them for you with their program while you go on thinking you invoice by hand; in that case the system is theirs, and the responsibility is still yours.
Your old Excel invoices: they do not need to be redone
Verifactu has no retroactive effect. The fourth final provision of the regulation, as worded by Royal Decree-law 15/2025, sets from when your system must be operational: before 1 January 2027 if you are a company and before 1 July 2027 if you are an autónomo. Invoices issued earlier with Excel or Word are valid and do not have to be reissued, moved into a program or given a QR.
What you do have to do with them:
- Keep them for four years for tax purposes (you have it in what Verifactu is); if you are a company, also check the commercial-law period, as PDF or on paper, with their numbering intact.
- Do not renumber or "clean up" the history. Start a new series in the program and leave the old one closed at its last number.
- Disable the sheet if it had macros. If your Excel generated books or accounts, it was an invoicing system. Applying the same criterion the AEAT gives for old programs, keep the invoices, but remove the macros or make the sheet read-only so that it cannot issue anything more from your deadline. Details on the old program are in the postponement guide.
The two alternatives: the free AEAT app or a program with a declaración responsable
If you want to drop the template, you have two routes that comply by design, both provided for in article 7 of the regulation:
- The free AEAT app. It invoices in your name with chained records and a QR, at no cost. Its limits (each invoice needs an identified recipient, so it is no use for tickets, and it is managed only inside the app itself) are in when the free AEAT app is enough.
- A program with a declaración responsable. Before paying, ask for the document that article 13 requires: it must be in writing and visible in the program itself, in each version. There is no "AEAT certificate". If you also want the program to keep your books or your tax forms, compare it with the guide to choosing a program.
What is no use to you is a halfway third route, such as templates "with QR" or add-ons for spreadsheets that promise to comply. If someone offers them to you, ask for the declaración responsable and check that it identifies the system and the version you are going to use.
If you invoice twice a year
The regulation has no minimum: it does not exempt you for invoicing little. But it does not force you to computerise either. If you issue a couple of invoices a year (an autónomo with a residual activity or someone who is paid for an occasional collaboration), you have three legal options:
- By hand or with an invoice book. Outside the regulation, according to the AEAT.
- With your Word or Excel template, as long as you only fill it in, print it and keep it, as in the previous section.
- With the free AEAT app, if you have a digital certificate or Cl@ve (the state's electronic identification system) and your clients are identified. It is the option the AEAT itself proposes to those who invoice by hand today.
Whichever you choose, stick to one. What gets you into trouble is not invoicing little, it is mixing: two invoices in Word and a third with the app or a trial program. From that moment you are using a computerised system and, according to the AEAT's criterion, all your invoicing must go through it.
What to do in 2026 so you are not late
- Now: open your sheet and honestly answer one question: does it generate anything more than the invoice (books, totals for the modelo 303, the quarterly VAT return, accounts)? If the answer is yes, it is an invoicing system and you have to replace it.
- Before the end of 2026: choose between the AEAT app or a program and ask for the declaración responsable. If you have an SL, this is your limit: the last invoice from the macro sheet is the one of 31 December 2026.
- First half of 2027: if you are an autónomo, invoice for real with the new system and close the old series by 30 June 2027 at the latest.
- Always: keep the old invoices and do not mix routes.
The full list by quarter is in the Verifactu postponement and the deadlines for your tax forms in the 2026-2027 tax calendar.
Frequently asked questions
Can I keep making invoices in Excel under Verifactu?
Is there a Word or Excel invoice template adapted to Verifactu?
Do I have to redo my old invoices made in Excel?
If I make the invoice in Excel and then enter it in my program, do I comply?
What if my gestor moves my Word invoices into their accounting program?
I invoice two or three times a year. What suits me?
Keep reading
What is Verifactu and does it affect you?
The AEAT free invoicing app: when it is enough and when it is not
Verifactu for autónomos: your July 2027 deadline explained
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