Six questions about your business and how you invoice in Spain. We tell you whether Verifactu applies to you, from what date (the legal one and the one the Ministry of Finance announced on 5 October 2026) and what to do with your software, whether it is a commercial program, your own system, an online store or a POS. Also for foreign companies with or without a presence in Spain.
General guidance based on Royal Decree 1007/2023 (the invoicing-systems regulation), Order HAC/1177/2024 (the technical specifications) and the Spanish Tax Agency (AEAT) FAQs. It does not replace advice from your tax adviser on specific cases.
The Dates Today
What the BOE (Official State Gazette) says and what the Ministry of Finance has announced but not yet published.
29 Jul 2025
Software producers
They may only sell compliant systems. Already in force, and the postponement does not affect them.
1 Jan 2027
Companies
Legal deadline in force for Corporate Income Tax (Impuesto sobre Sociedades) payers.
1 Jul 2027
Self-employed and others
Legal deadline in force for the self-employed, pass-through entities and non-residents with a permanent establishment.
Oct 2028
Announced date
The Ministry of Finance plans to move the pending obligations here, together with e-invoicing for SMEs and the self-employed. Not yet in the BOE.
We will update this page and the checker result the day the postponement is published in the BOE.
Check Your Case
Answer with what you know; if you are unsure about one, choose “I don’t know” and we will take it into account.
Your result
Already obliged
As a producer, your obligation is already in force
Since 29 July 2025 you may only sell invoicing systems that comply with the regulation, with a responsible declaration (declaración responsable) for each version. The postponement announced for your customers does not change your date. The penalty for producers is €150,000 per financial year and per system type.
Legal deadline today (BOE)
29 July 2025
Does not apply
Verifactu does not apply to you: you have your regional (foral) system
Businesses taxed under the foral rules of the Basque Country (TicketBAI and Batuz) or Navarre comply with their own system, not with Verifactu. Check the foral timeline that applies to you with your tax adviser.
Does not apply
If you are in the SII, Verifactu does not apply to you
The regulation excludes those who keep their books through the Immediate Supply of Information, whether mandatory or voluntary. Note: if you leave the SII, you fall under Verifactu.
Does not apply
Fully exempt entities are out of scope
The regulation only covers Corporate Income Tax payers that are not fully exempt (article 9.1 of the Corporate Income Tax Act). If your exemption is partial, it applies to you for the non-exempt income.
Does not apply
Without a permanent establishment in Spain, Verifactu does not oblige you
The regulation covers non-residents operating in Spain through a permanent establishment. If you invoice from abroad without one, it does not oblige you. If you have a Spanish subsidiary, the subsidiary is a Spanish company and it does apply to it, even if it invoices with the group’s ERP.
Does not apply today
You do not use an invoicing system today, so Verifactu does not oblige you
Invoicing by hand, or with Word or Excel only to type, print and save, is not a computerised invoicing system. But you cannot mix: if you issue even one invoice with software, you are in. And B2B e-invoicing will require you to use one.
Applies to you
Verifactu applies to you as a company
Your invoicing software must comply with the regulation. The legal deadline in force is 1 January 2027; on 5 October 2026 the Ministry of Finance announced that it plans to delay it to October 2028, but it is not yet in the BOE. Until your date arrives, you can run it for real and switch back.
Legal deadline today (BOE)
1 January 2027
Date announced by the Ministry of Finance (not in the BOE)
October 2028
Applies to you
Verifactu applies to you
Your invoicing software must comply with the regulation. The legal deadline in force for the self-employed and other obliged parties that are not companies is 1 July 2027; on 5 October 2026 the Ministry of Finance announced that it plans to delay it to October 2028, but it is not yet in the BOE.
Legal deadline today (BOE)
1 July 2027
Date announced by the Ministry of Finance (not in the BOE)
October 2028
You said you don’t know whether you are in the SII. If you are (it is mandatory if you invoice more than €6 million a year, are in the monthly VAT refund register, REDEME, or in a VAT group), Verifactu does not apply to you. Your Spanish tax adviser will know: it is a box in your census registration return.
What to do with your software
With a commercial program
Ask your vendor for the responsible declaration for the version you use. If they cannot provide it, that is a red flag.
Ask whether it works in VERI*FACTU mode (sends to the AEAT) or NO VERI*FACTU mode (signs and retains), and which one suits you.
Check whether your plan includes B2B e-invoicing or how much it will cost to add it.
If your program is connected to your store, POS or ERP, make sure invoices are not issued in two places.
With in-house or custom software
Your software is an invoicing system like any other: it must comply and carry the responsible declaration of whoever programs it, even if that is your own team.
At a minimum it will be missing issuance and cancellation records with a chained hash, the QR code and, if you choose VERI*FACTU, submission to the AEAT with flow control.
Decide whether it is worth adapting or replacing, and whether submission goes through a third-party API or directly to the AEAT.
That is exactly what we do at Kiwop: Verifactu compliance with the responsible declaration.
With an online store
If the store issues the invoices, it is an invoicing system and must comply.
An off-the-shelf module or app covers the simple case. Check how it handles returns, partial refunds and simplified invoices, which is where they fail.
If you have several stores or channels under the same tax ID, check that the numbering and the hash chain do not cross.
If your volume is high, compare the API’s per-invoice fee with a custom integration.
With a POS
Ask the manufacturer for the responsible declaration for your version and whether the till works offline.
Receipts (simplified invoices) also generate a record and carry a QR code.
If the network goes down, the POS must store the records, retry the submission and alert you. Ask how it does this.
With several tills, each has its own installation number: they must not share a chain without control.
With the AEAT’s free app
It complies with Verifactu for all purposes: you have nothing else to do.
But it does not issue simplified invoices (receipts), always requires a recipient and only invoices in your own name or with a power of attorney.
Nor does it export your invoices to other software: if you switch one day, you start from scratch.
If you sell or develop invoicing software
A responsible declaration for each version, inside the software and accessible outside it, with the content set out in article 15 of Order HAC/1177/2024.
If you modify another producer’s system, you provide your own declaration.
If you submit records on behalf of your customers, you need to evidence the authorisation or sign the AEAT collaboration agreement (colaboración social).
Design for B2B e-invoicing now: the Ministry of Finance has announced the technical convergence of the two regulations.
If you invoice by hand or with Word
Do not switch halfway: as soon as you issue invoices with software, all of that software must comply.
If you are moving to software, choose one that already has its responsible declaration and B2B e-invoicing.
For a few invoices to other businesses, the AEAT’s free app is an option, with its limits.
And B2B e-invoicing
As you invoice more than €8 million a year, B2B e-invoicing will apply to you around October 2027 (12 months from Order HAC/1028/2026, in force since 6 October 2026). It makes sense to adapt both at the same time.
If you invoice €8 million or less, B2B e-invoicing will apply to you around October 2028, the same date the Ministry of Finance has announced for Verifactu. A single adaptation should cover both.
General guidance based on Royal Decree 1007/2023 (the invoicing-systems regulation), Order HAC/1177/2024 (the technical specifications) and the Spanish Tax Agency (AEAT) FAQs. It does not replace advice from your tax adviser on specific cases.
Result generated at kiwop.com/en/verifactu-checker on
How the Checker Decides
The same rules the AEAT publishes, in the order we apply them.
The “four noes” rule
The AEAT sums up Verifactu’s scope like this: it applies to you if you issue invoices and you do not only write them by hand, are not in the SII, do not have your tax address in the Basque Country or Navarre and do not have a ruling that excludes you. The checker first looks at whether you produce software (your date is different), then at the territory, the SII, whether your entity is exempt or a foreign company without a permanent establishment, and how you invoice.
Which date applies to you
The regulation separates Corporate Income Tax payers (legal deadline today: 1 January 2027) from everyone else: self-employed people with a business activity, pass-through entities and non-residents with a permanent establishment (1 July 2027). On 5 October 2026 the Ministry of Finance announced that it plans to move both dates to October 2028. Until that is published, the checker shows you both.
Cases to review with your tax adviser
The checker covers the general cases. Review them with your adviser if any of these apply to you:
You are under the flat-rate scheme (módulos) or the equivalence surcharge scheme (recargo de equivalencia): in general you do not issue invoices, but if you do (even voluntarily), those invoices are in scope.
You have an establishment in the Canary Islands that is not registered in the IGIC SII even though you are in the VAT SII: for those transactions, you are in scope.
You invoice on behalf of others, or your customers issue your invoices (self-billing or third-party billing).
You are a pharmacy under the equivalence surcharge scheme taxed under the direct assessment method (estimación directa).
FAQ
Frequently Asked Questions
The questions we get most about whether Verifactu applies and when.
Has Verifactu been postponed to 2028?
The Ministry of Finance announced it on 5 October 2026 in an information note: it plans to postpone the pending obligations until October 2028 so that they coincide with e-invoicing for SMEs and the self-employed. As of 7 October 2026 it has not been published in the BOE, so the legal dates are still 1 January 2027 (companies) and 1 July 2027 (everyone else).
Does Verifactu apply to foreign companies?
Only if they operate in Spain through a permanent establishment: their legal deadline today is then 1 July 2027. If you invoice from abroad without an establishment in Spain, Verifactu does not apply to you. A Spanish subsidiary is a Spanish company and it does apply, with a legal deadline of 1 January 2027, even if it invoices with the group’s ERP. For both cases Spain’s Ministry of Finance has announced a delay to October 2028, not yet published in the Official State Gazette.
Does Verifactu apply to the self-employed?
Yes, to those who issue invoices with software and are not in the SII or taxed in the Basque Country or Navarre. Their legal deadline today is 1 July 2027, with the announced postponement to October 2028. Self-employed people under the flat-rate or equivalence surcharge schemes who do not issue invoices are out; if they do issue them, they are in.
If I invoice with Excel, do I have to comply with Verifactu?
It depends on how you use it. If Word or Excel only help you type, print and save the invoice, the AEAT does not consider them an invoicing system. If your Excel file has macros that generate the record books or the accounts, it is one, and it will not be able to comply unless you replace it with compliant software.
Does Verifactu apply in the Canary Islands?
Yes. The Canary Islands, Ceuta and Melilla are in scope: the regulation reads references to VAT as referring to IGIC or IPSI. What is out of scope is businesses domiciled in the Basque Country and Navarre that are taxed under the foral rules.
I am in the SII. Do I need to do anything?
For Verifactu, no: those who keep their books through the SII, mandatorily or voluntarily, are excluded. For B2B e-invoicing, yes: it is a separate obligation and will reach you depending on your turnover.
What happens if I do not comply?
For the user, the penalty is €50,000 per financial year in which they use a non-compliant or altered system. For whoever produces or sells the software, €150,000 per financial year and system type. There are no fines “per invoice”.
Sources
Sources
Regulations and official documents the checker is based on, checked on 7 October 2026.