Verifactu FAQ: the real questions of autónomos and small companies

FAQ on whether Verifactu applies to you

Does Verifactu apply to me? If you use a program to issue invoices, almost certainly yes. Article 3 of Royal Decree 1007/2023 covers corporate income tax payers, autónomos with an economic activity, non-residents with a permanent establishment and communities of property owners with an activity, "even if they only use them for part of their activity".

What if I invoice very little? It makes no difference. The rule sets no minimum amount or number of invoices: what counts is whether your invoicing system is computerised, not how much you invoice.

Who is left out? Anyone who keeps their VAT books through the SII (the immediate VAT information supply system, art. 3.3), anyone whose tax residence is in the Basque Country or Navarre (art. 1.3), entities fully exempt from corporate income tax (art. 3.1.a) and anyone who issues all their invoices by hand, because the regulation only covers computer systems (art. 1).

I am in módulos or in recargo de equivalencia. Am I off the hook? Not because of the regime itself, but because in those activities you are normally not required to issue invoices: article 3 of the Invoicing Regulation exempts the recargo de equivalencia (the retail surcharge system), the simplified VAT regime (except when the quota is calculated by volume of income) and the agricultural regime. If you still issue an invoice with a program, for example when selling a property or a fixed asset, that program must comply. The detail is in the guide on what Verifactu is.

I am a non-resident. Does it apply to me? It depends on how you operate. If you have a permanent establishment in Spain (a branch or fixed office), yes, with the date of 1 July 2027. If you do not, article 3 does not name you among those obliged. And if you are a foreigner but a Spanish tax resident and an autónomo, you pay IRPF (personal income tax) and it applies to you like any other autónomo.

Since when is Verifactu mandatory

Since when? Companies must have the system adapted before 1 January 2027 and autónomos before 1 July 2027, according to Royal Decree-law 15/2025. In practice, the last invoice of an SL with an unadapted program is the one dated 31 December 2026. The story of the two postponements is in the guide on the postponement of Verifactu to 2027.

I have an SL and I am also an autónomo. Which date do I follow? Two dates: the SL follows January and your own autónomo activity follows July. If one program invoices for both, work with the earlier one.

Can I start earlier? Yes. Order HAC/1177/2024 allows a system to start operating as VERI*FACTU "at any time" (art. 17.1). The AEAT (the Spanish tax agency) has clarified in its frequently asked questions that the period before your date "is a trial period": until 31 December 2026 (companies) or 30 June 2027 (everyone else) you can stop sending records and go back to invoicing with another system. From your date onward, if you start sending, you will have to stay at least until 31 December of that year.

Excel, Word, paper and handwritten invoices

What happens to my Excel? According to the criterion published by the AEAT, a Word or Excel template that you only use to fill in, print and save invoices is not an invoicing system. It is one if it also generates your record books or your accounting, for example with a macro: then it must comply. We explain it with the sources in the guide on the postponement and, for autónomos, in Verifactu for autónomos.

Can I stay on paper? Yes, in two different ways. If you invoice by hand or with an invoice book, you are outside the regulation. If you invoice with a program and print the invoice, paper is fine, but it must carry the QR code: article 20 of the order requires it "whether it is printed on paper or is the digital image".

I invoice almost everything by hand, but some invoices come out of the computer. Does it apply to me? Yes. Article 3.1 reaches anyone who uses a computer system even for just part of their activity, and for those invoices the program must comply.

Submissions to the tax agency, the QR code and receipts

Do I have to send every invoice to the tax agency? Not necessarily. In the VERI*FACTU mode your program sends each invoicing record automatically when the invoice is issued. In the other mode you send nothing periodically, but each record must be electronically signed and is only handed over if the AEAT requests it (art. 14 of the regulation).

What is the QR? A code printed on the invoice, between 30x30 and 40x40 millimetres, that contains an AEAT address with four data points: your NIF (tax ID), the series and number, the issue date and the total amount (art. 21 of the order). It appears in both modes. We take it apart data point by data point in the example of a Verifactu invoice with QR.

What happens if my client scans the QR? They see the invoice data on the AEAT website and, if your invoice carries the phrase "VERI*FACTU", they can check that you submitted it. That query is not a report against you (art. 17 of the regulation).

What about simplified invoices or receipts? They are included too. The regulation understands invoice to mean both the full one and the simplified one (art. 1.2), and article 7.5 of the Invoicing Regulation requires the same QR on receipts. Note that the AEAT's free application always asks for a recipient, so it does not work for receipts without an identified customer (you will see this in the guide on the AEAT free app).

Mistakes, cancellations and corrective invoices

What if I make a mistake on an invoice? It depends on the error. If the invoice should never have been issued (a duplicate, the wrong client), the system generates a cancellation record, provided for in article 11 of the regulation for when "an invoice has been issued in error". If the invoice existed but has a wrong detail or amount, you need a corrective invoice (factura rectificativa).

Does anything change with corrective invoices? The substantive rules are still those of article 15 of the Invoicing Regulation: a new invoice, in its own series, that identifies the corrected one. What is new is that its issue record states that it is a corrective invoice, its type and the invoices it corrects (art. 10.1.g of the regulation). When and how to issue one is covered in the guide on the corrective invoice.

Can I delete the wrongly made invoice and reuse the number? No. The chain contains both issue records and cancellation records (art. 7.d of the order), so whatever is cancelled remains visible. Sequential numbering per series was already mandatory before Verifactu (art. 6.1.a of the Invoicing Regulation).

Software, certificate, cost and gestorías

Does my program need an AEAT certificate? There is no such thing. The producer proves compliance with a declaración responsable (a sworn statement of compliance) visible in the program itself, whose content is set by article 15 of the order. Ask your provider for it before you pay.

And the digital certificate? Do I need it? To send records in VERI*FACTU mode, the system must identify itself to the AEAT with an electronic certificate valid on its website, and the submission can be made by a third party who represents you (art. 5 of the order). In the no-submission mode, the records are electronically signed.

How much does compliance cost? The rule sets no price. The free option is the AEAT's invoicing application, which article 7.b of the regulation provides for as an alternative and which article 16.4 treats as a VERI*FACTU system. The rest depends on the program you choose.

My gestoría (a Spanish tax and admin adviser) makes my invoices. Who complies? The program the gestoría uses must comply, and the record states that the invoice is issued by a third party (art. 10.1.c). But delegating does not remove your responsibility: article 6 of the regulation says the obliged person remains liable. If the gestoría uses one program for many clients, it must keep a separate chain per client (art. 2 of the order). How to split the tasks is in what a gestor is.

What is the fine if I do not comply? 50,000 euros per year for the user of a non-compliant system (art. 201 bis.2 and 4 of the General Tax Law). It is a fixed amount, not dependent on what you invoice.

Frequently asked questions

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