The compliance countdown has become operational.
Spanish companies subject to Corporate Income Tax must have compliant invoicing systems in place before 1 January 2027. For self-employed individuals and the other taxpayers covered by the rules, the deadline is 1 July 2027. With less than three months remaining for companies, VERI*FACTU is no longer a future tax reform: it is a systems, controls and business-continuity project.
The rules stem from Royal Decree 1007/2023, as subsequently amended, and are designed to ensure the integrity, preservation, accessibility, legibility, traceability and unalterability of invoicing records. The Spanish Tax Agency updated its detailed FAQs on 21 July 2026, providing useful guidance on scope, implementation and legacy software.
Who is affected — and who is not?
The regime generally covers businesses using computerised invoicing systems that are subject to Spanish Corporate Income Tax, individuals carrying on economic activities under Personal Income Tax, and non-residents operating through a Spanish permanent establishment. It applies in the Spanish common tax territory.
An important exclusion concerns taxpayers whose invoicing records are reported through the Immediate Supply of Information system (SII). Companies already within the SII do not have to adapt those invoicing processes to the Royal Decree 1007/2023 requirements. Groups should nevertheless confirm the position entity by entity: one Spanish subsidiary may be in the SII while another is not.
Transactions for which there is no legal obligation to issue an invoice are also outside the relevant invoicing-system requirements. However, this should not be confused with a general exemption for small businesses or low invoice volumes.
VERI*FACTU is a choice of mode
The terminology creates a common misunderstanding. The regulation governs compliant Computerised Invoicing Systems, or SIFs. VERI*FACTU is one of the two permitted operating modes; it is not the only way to comply.
A VERI*FACTU system sends a structured invoicing record to the Tax Agency automatically, securely and continuously when an invoice is issued. The customer can use the invoice’s QR code to check the record.
A non-verifiable compliant system does not send each record immediately. Instead, it must preserve the records and provide stronger internal safeguards, including electronic signatures and an event log, to guarantee integrity and traceability. Both modes require adapted software, chained records and the prescribed QR information on invoices. The operational choice should therefore be based on connectivity, data governance, storage, control and audit requirements — not merely on a desire to avoid sending data.
Manual invoicing requires careful analysis
The regulation targets systems that receive invoicing information, preserve it and process it to generate invoices or other derived outputs. Businesses that invoice exclusively by genuinely manual means, without the assistance of a SIF, may fall outside the system rules.
The label placed on a tool is not decisive. A Word or spreadsheet file used only as a basic manual template may be different from a workbook that stores invoice data, performs calculations, produces sequences, generates accounting information or feeds another application. Functionality and integration determine the answer. Businesses should document their analysis rather than assume that “Excel” automatically means exemption.
Likewise, outsourcing invoice preparation does not transfer the tax responsibility. Where a customer, adviser, platform or third party materially issues invoices, the business carrying out the underlying transactions remains responsible for compliance.
Legacy software is a significant risk
The Tax Agency’s FAQs contain a particularly important warning. After the applicable 2027 deadline, retaining a non-compliant invoicing system that is still capable of issuing invoices may itself constitute an infringement, even if the company says it no longer uses the program.
Historical data may be retained for consultation, but the old application should be uninstalled, disabled or technically prevented from creating new invoices. This point must form part of the migration plan. Simply moving daily invoicing to a new platform while leaving the old system operational on a server is not sufficient risk control.
Article 201 bis of the General Tax Law provides for a fixed penalty of €50,000 per financial year for holding systems that should be certified but are not, or where certified devices have been altered. The exposure makes documented decommissioning as important as installing the replacement.
Five actions before January
Spanish companies should complete five workstreams now:
- Map every invoicing channel: ERP, point-of-sale terminals, e-commerce platforms, mobile applications, spreadsheets, marketplace tools and self-billing arrangements.
- Confirm the scope for each legal entity, including SII status and any permanent establishments.
- Obtain the supplier’s responsible declaration identifying the compliant software version and whether it operates in VERI*FACTU, non-verifiable or dual mode.
- Test invoice series, corrections, cancellations, QR codes, offline scenarios and the connection between billing, accounting and tax reporting.
- Plan the cutover and disable legacy invoice-issuing functionality while preserving accessible historical records.
International groups face an additional issue. A global ERP may be compliant in commercial terms but still lack the Spanish record format, chained hash, QR code, event log or transmission functions. Local tax and technology teams should test the Spanish configuration, rather than rely on a group-wide assurance.
Conclusion
VERI*FACTU is not simply a new invoice layout. It changes how invoice data is created, linked, protected, transmitted or retained. The companies best prepared for 1 January 2027 will be those that assign ownership across tax, finance, IT and operations, document their scope decisions and test the full invoice lifecycle before year-end.