Verifactu Spain: Compliance for Your Invoicing Software

Today, according to the BOE, on 1 January 2027 for Corporate Income Tax payers and on 1 July 2027 for everyone else (self-employed people with a business activity, pass-through entities and non-residents with a permanent establishment). On 5 October 2026 the Ministry of Finance announced that it plans to delay those obligations until October 2028, but as of 7 October 2026 the change has not been published in the BOE. Software producers have been obliged since 29 July 2025.

It depends on how you operate in Spain. If you invoice from abroad without a permanent establishment in Spain, the regulation does not oblige you. If you have one, or a Spanish subsidiary, it does: the subsidiary is a Spanish company, even if it invoices through the group’s ERP. In that case we adapt your central ERP or SaaS, or build the Spanish layer that connects to it, and we coordinate the tax side with your Spanish adviser. We work in English, Spanish, Catalan, French, German, Dutch and Portuguese.

If you only use a commercial program, probably yes, although the prudent thing is to wait until the postponement appears in the BOE. But there are two cases where waiting is expensive: if your software is in-house or custom-built, because its producer (your team or your supplier) should have had the responsible declaration since July 2025; and if you will have to issue B2B e-invoices, because the Ministry of Finance is going to merge the two obligations and adapting twice costs twice as much.

Those that keep their books through the SII (mandatory or voluntary), those taxed under the regional (foral) rules of the Basque Country or Navarre, those that only invoice by hand and those with a ruling that excludes them. Entities fully exempt from Corporate Income Tax are also out. The Canary Islands, Ceuta and Melilla are not exempt. If in doubt, the free checker tells you in a minute.

Adapt it and have its responsible declaration, signed by whoever programs it, even if that is your own team. The AEAT makes this clear in its FAQs: custom software is an invoicing system like any other. We carry out the adaptation and sign the declaration for the version we deliver.

It is the self-certification in which the software producer declares that its system complies with the regulation. It is signed by whoever produces or modifies the software, one per version, and it must be inside the software and accessible outside it. There is no AEAT approval or register: anyone selling “software approved by the Spanish Tax Agency” is using a term that does not exist.

In VERI*FACTU mode the system sends each record to the AEAT automatically and the invoice carries the “VERI*FACTU” legend. In NO VERI*FACTU mode the records stay in your system, electronically signed (XAdES) and with an event log, and are handed over if the AEAT requests them. The first is simpler to build and to defend; if you choose it, you stay with it until 31 December of that year.

With us, the assessment costs €900 at a fixed price and is deducted if you go ahead. Adapting an online store starts at €2,900, in-house software or a custom ERP at €8,900 and a new invoicing platform at €24,000. If you choose a third-party API for submission, you pay its fee separately (between about €3 and €16 per tax ID per month on published rates).

Between four and twelve weeks from the assessment to the first real record accepted, depending on the system. A store with a well-chosen module can be ready in three or four weeks; an ERP with several series, corrective invoices and tills, in two or three months. Testing in the AEAT environment always comes before anything real is sent.

No. Verifactu (Royal Decree 1007/2023) requires your software to record invoices in an unalterable way and, in its main mode, send them to the AEAT. B2B e-invoicing (Law 18/2022 and Royal Decree 238/2026) requires businesses to issue and receive invoices between them in a structured format. They are two different regulations, but the Ministry of Finance has announced it will align their timelines in October 2028 and their technical aspects afterwards.

Article 201 bis of the General Tax Law (Ley General Tributaria) sets €50,000 per financial year for anyone who uses a non-compliant system or alters it, and €150,000 per financial year and per system type for whoever produces or sells it, plus €1,000 for each system sold without certification. There are no fines “per invoice”: that figure going around is a mistake.

If your store issues the invoices, yes: the AEAT considers an online store that issues invoices to be an invoicing system. There are off-the-shelf modules and apps that cover the simple case; where they tend to fail is returns, partial refunds, simplified invoices and several stores under the same tax ID. We review it in the assessment and solve it with a module, an API or a custom integration.

Yes: submission is made with the electronic certificate of the company, of an authorised representative or of an AEAT social collaborator. If your software submits records on behalf of many customers, that authorisation must be evidenced with the forms the AEAT approved in December 2024: accepting terms of use is not enough.

If you issue a few invoices to other businesses, it may be: it is VERI*FACTU for all purposes. But it does not issue simplified invoices (receipts), always requires a recipient, does not export invoices to other software and only invoices in your own name or with a power of attorney. For a store, a POS or an ERP, it is not an option.