The AEAT free invoicing app: when it is enough and when it is not

What the free AEAT application is

The Agencia Tributaria has built its own free, official invoicing application, set out in article 19 of Orden HAC/1177/2024, a Spanish ministerial order. With it you issue invoices that already comply with Verifactu: each invoice is stored as a hash-chained record and carries the printed QR code used to verify it.

Its basic functions are to capture, store, view and download your invoice data, generate the invoice as a PDF, and create and keep the invoicing records. Because it is made by the tax agency itself, it complies by design: you do not have to check any vendor's declaración responsable (the producer's statement of compliance) or worry about whether the software is adapted.

You use it inside the AEAT electronic office, identifying yourself with a digital certificate or Cl@ve. The application's conditions are described in the AEAT frequently asked questions. In short, it is the cheapest, most direct way to invoice within the law: free, official and with nothing to install.

What it does well

For what it is designed to do, the free application performs well:

• It is free and official. No licence or subscription, and it comes from the tax agency itself, so any doubt about whether it complies with Verifactu simply disappears.
• It issues correct invoices. It generates the invoice as a PDF with all the mandatory data and its QR code, ready to send to your client.
• It keeps the chain for you. Each invoice is chained to the previous one through its hash, which is exactly what the rules require; you never have to understand hashes or chaining.
• It stores and lets you download your data. You can view your issued invoices and download them whenever you need, for example to hand them to your accountant.
• Zero maintenance. Nothing to install, update or configure: you log in with your certificate and invoice.

If your only need is to issue a few invoices a month within the law, this already solves the problem without spending a cent.

Its real limits

This is where it pays to be blunt, because it is where most people get a surprise. The application does one thing: invoicing. It does not keep your accounts, it has no built-in income and expense books, it does not calculate or fill in any tax form, and it does not reconcile your bank. That is not a flaw: it is its scope.

On top of that, article 19 of Orden HAC/1177/2024 sets some concrete limits worth knowing:

• Every invoice needs an identified recipient. The app always requires a recipient, so it cannot issue simplified invoices or tickets with no identified client, which is common in retail and hospitality.
• Your invoices stay inside the app. The invoices and their records can only be managed from within the application itself: you can download them, but you cannot move the chain to another program to keep invoicing there.
• Only in your own name. Invoices can only be issued in your own name or through an authorised representative; it is not a tool designed to manage the invoicing of many clients at once.
• You need to identify yourself. To log in you need a digital certificate or Cl@ve, without which you cannot use it.

There is no need to invent limits that do not exist: the AEAT does not publish a cap on the number of invoices or users. The real limit is one of functions, not of volume.

Who it is enough for

Let us be honest, because this guide is not selling you anything. The free AEAT application can genuinely be enough for you if:

• You issue few invoices a year, always to business clients whose details are identified.
• Your gestor (a Spanish accountant and tax adviser) already keeps your books and files your forms, and you only need a legal way to issue the invoices.
• You are just starting, with low volume, and want to comply with Verifactu without spending while the business gets going.

In those cases, setting up paid software to make three or four invoices a month would be overkill. If you run an SL (a Spanish limited company), remember too that your invoicing system must be operational before 1 January 2027 (autónomos, the self-employed in Spain, have until 1 July 2027), and the free app is a perfectly valid way to reach that date compliant.

The honest question is: besides invoicing, who takes care of your taxes? If the answer is your gestor, the app works for you. If the answer is you, read on.

What you also need for your taxes

Invoicing is only part of your obligations. The invoice records the app generates do not turn themselves into your taxes, and that is where the work the app does not do appears:

• Your tax returns. Invoices do not fill in your modelo 303 VAT return by themselves, nor, if you are an autónomo, your modelo 130 income tax instalment. Someone has to work out the boxes.
• Your withholdings and summaries. If you pay rent or professionals with a withholding, the corresponding forms and their annual summaries still have to be filed.
• Your accounting. You need to record income and expenses and keep your books, which the app does not cover.
• Your bank. Matching what you invoice and spend against the real movements in your account is not something the application does.
• The deadlines. Nobody warns you that a quarter is due: the calendar is on you.

If your gestor takes on all of that, the free app fits perfectly into your routine. If not, you will end up combining the AEAT application with spreadsheets and scattered reminders, which is exactly where mistakes and missed deadlines creep in.

The AEAT app versus all-in-one software

Put together, this is how the free application compares with all-in-one management software, with no dressing up:

• Invoicing under Verifactu: both do it. Hash-chained records and QR, the same.
• Accounting: the app keeps no books; all-in-one software records income and expenses by double entry.
• Tax forms: the app calculates none; all-in-one software prepares the drafts of the 303, 111, 115, 349 and the rest, box by box.
• Bank reconciliation: the app does not do it; all-in-one software matches your invoices against your bank movements.
• Deadline alerts: the app does not warn you; all-in-one software reminds you of every due date.
• Cost: the app is free; all-in-one software is paid, although some offer a free beta.
• Portability: the app's invoices can only be managed inside the app; all-in-one software keeps them alongside the rest of your admin.

kontora is one example of that kind of all-in-one software: it builds your tax form drafts box by box, keeps double-entry accounts, reconciles your bank using the norma 43 standard and watches the BOE daily to warn you of deadlines and changes; its core is already Verifactu-ready and it currently runs as a free beta with a waitlist. Filing each form at the AEAT is still done by you.

The bottom line, no hype

The free AEAT application is a good tool, not a consolation prize: it is free, official and genuinely Verifactu-compliant. If the only thing you need from software is to issue invoices, and your taxes are already handled by your gestor or by you with ease, use it without any guilt. It is the most sensible choice for many small businesses.

It stops being enough the day you want your invoices, your accounting, your tax forms and your bank in one place, or the day you get tired of nobody warning you about deadlines. That is the moment for all-in-one software, not before.

Choose by what you actually do, not out of fear. If you invoice little and are well supported, the free app is more than enough. If your admin is getting away from you, a program that brings it all together will save you more than it costs. Both answers are valid; what is not valid is paying out of habit or falling short out of inertia.

Frequently asked questions

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