Verifactu delayed until 2027: dates, requirements and how it affects the self-employed and SMEs

Updated on 27 September 2026. The dates are still those set by Royal Decree-law 15/2025: 1 January 2027 for companies and 1 July 2027 for the self-employed and other taxpayers; no further postponement has been approved. We have corrected who is affected, clarified that the tax authorities do not certify software, and added the exemptions, the penalties and the steps to get ready.

The Government once again postponed Verifactu, the system that requires invoicing software to prevent invoices from being deleted or altered without leaving a trace. The delay came through Real Decreto-ley 15/2025, de 2 de diciembre (Royal Decree-law 15/2025 of 2 December), published in the BOE (Spain's Official State Gazette) on 3 December and validated by Congress on 11 December 2025. It was not the first delay: the original date was 1 July 2025, and Royal Decree 254/2025 had already moved it to 2026.

That timetable still stands today, and companies have little more than three months left. Here we explain what Verifactu requires, who it really affects and what you should do now.

The dates in force

It is often said that the January date is for "companies with a turnover of less than six million euros". That is not the case: the date depends on the tax you pay (Corporate Income Tax or IRPF), not on your turnover. The six million figure has a different explanation, which you will see in the section on the SII.

Until those dates you can keep using your current software as long as it complies with the invoicing rules. For the Agencia Tributaria (Spanish Tax Agency), the time remaining is a test period: if you were already sending records, you may stop and invoice with another system. If your software is covered by a multi-year maintenance contract, the provider must adapt it before those same dates. And although some self-employed associations have asked for another postponement, as of today no rule has been published in the BOE that changes the timetable.

What Verifactu is (and what it is not)

"Verifactu" is the popular name for the regulation approved by Real Decreto 1007/2023, de 5 de diciembre (Royal Decree 1007/2023 of 5 December). It implements article 29.2.j) of the Ley General Tributaria (General Taxation Act), introduced by Law 11/2021 (the "Anti-Fraud Act"). The technical specifications are set out in Orden HAC/1177/2024 (Ministerial Order HAC/1177/2024).

It does not create any new tax or change who must issue invoices. It regulates the software you invoice with, to put an end to programs that made it possible to hide sales. An adapted system must:

• Automatically generate an invoicing record for every invoice it issues, whether full or simplified. Till receipts (tiques) or proofs of sale that are not invoices are outside the scope, as you will see below.
• Chain each record to the previous one using a fingerprint or hash, so that any alteration is detected.
• Prevent anything already recorded from being deleted or modified. If an invoice was issued by mistake, a cancellation record is generated; if its content has to be corrected, a corrective invoice (factura rectificativa) is issued where appropriate. The original record is always kept.
• Include on every invoice a QR code that your customer can scan to check its details with the Tax Agency.

The tax authorities do not certify or approve software

You will see adverts for "certified" software or software "approved by the tax authorities", but the Tax Agency does not certify, approve or endorse any software. It is the producer who certifies, by means of a declaración responsable (a self-declaration of conformity), that the system complies (article 13 of the regulation): that is the "certification" the law refers to. It must be visible in the software itself, and you can ask for it in writing before signing up.

Two modes: with or without automatic submission to the Tax Agency

• VERI*FACTU mode. The software sends each record to the Tax Agency as it is created. Invoices carry the legend "VERI*FACTU" or "Factura verificable en la sede electrónica de la AEAT", the records do not need an electronic signature and you do not have to store them yourself (you do still keep the invoices). Once you are bound by the rules, if you choose this mode you must stay in it at least until the end of the calendar year.
• Non-VERI*FACTU mode. Records are not sent, but the software must sign them electronically, keep an event log and store them for the period set by the General Taxation Act, so that they can be handed over if the Tax Agency asks for them.

In both modes you must still keep your record books (libros registro) and file your tax returns: Verifactu does not replace them.

Does it affect you? Who must comply and who is exempt

You must comply if you are a company, a self-employed person, a pass-through entity or a non-resident with a permanent establishment and you use software to invoice, even if only for part of your business. There is no minimum turnover or number of invoices. It also applies in the Canary Islands, Ceuta and Melilla.

If you pay VAT under módulos (the simplified VAT scheme), the equivalence surcharge scheme (recargo de equivalencia) or the special scheme for agriculture, livestock and fishing, you are generally not obliged to issue invoices, and till receipts that are not invoices fall outside Verifactu. It affects you as soon as you issue full or simplified invoices with software, whether because you are required to (for example, when the customer is a business) or because you choose to. The Dirección General de Tributos (Directorate-General for Taxation) confirmed this for a hairdresser under módulos who only invoices occasionally (binding ruling V2055-25): if she uses a computer system to issue those invoices, the regulation applies. And if you are taxed under direct assessment (estimación directa) for IRPF, you must invoice all your transactions whatever your VAT scheme (article 26 of the Invoicing Regulation, approved by Royal Decree 1619/2012), so if you do so with software, you are within the scope.

You are outside the scope in these cases:

1. You only invoice by hand, using an invoice book or in writing.
2. You are in the SII (Suministro Inmediato de Información, the immediate VAT reporting system), whether compulsorily or voluntarily, because you already send your invoices to the Tax Agency almost in real time. It is compulsory for anyone who files VAT monthly: large companies (turnover above €6,010,121.04 in the previous year), those registered in the monthly refund register (REDEME) and VAT groups. Hence the confusion about "six million": large companies are usually outside Verifactu, not inside it. If you leave the SII, you become subject to it.
3. Your tax domicile is in the Basque Country or Navarre, which apply their own regional systems (such as TicketBAI).
4. The Tax Agency has granted you a non-application decision, available for exceptional situations.

Nor does it apply to entities fully exempt from Corporate Income Tax. If in doubt, the Informador VERI*FACTU tool on the Tax Agency's e-office helps you check whether you are affected.

What if I invoice with Word or Excel?

It depends on how you use them. According to the Tax Agency's FAQs, if you only use them to write, print and save invoices, they are not covered, nor are they covered just because you make simple lists of invoices with totals; they are covered if you use them to process the data and directly generate, for example, the VAT record book (the Agency gives the example of a macro). The Directorate-General for Taxation is more cautious: in ruling V2045-25 it warns that it cannot simply be concluded that they fall outside the scope. If you invoice this way, the safest option is to move to adapted software or to the Tax Agency's free app.

What if a gestoría (accounting firm) keeps my books?

A gestoría that only enters invoices you have already issued is not bound by the rules for that reason (ruling V0817-26). The obligation is yours if you issue invoices with software, and you remain responsible even if the gestoría issues them on your behalf.

What is at stake: the penalties

Article 201 bis of the General Taxation Act treats the following as serious offences:

• Users: holding a system that does not meet the requirements and, in addition, lacks the required certification (the producer's self-declaration of conformity) or has been altered. Fine: €50,000 for each financial year.
• Producers and resellers: €150,000 per financial year and per type of software that allows records to be manipulated or does not meet the specifications, and €1,000 for each system sold without the required self-declaration.

Users can only be penalised once the obligation is enforceable against them, that is, from the dates in the table.

The Tax Agency's free app

If you issue few invoices, you do not need to buy software: you can use the Tax Agency's invoicing application, available on its e-office. It always works in VERI*FACTU mode and is designed for micro-businesses and professionals with few invoices, because the data are entered manually. In addition, article 19 of Order HAC/1177/2024 sets two limits: every invoice must name a recipient, so it is not suitable for counter sales to anonymous customers, and whatever you issue with it can only be managed within the app itself. For anything else, check its guide before deciding.

Verifactu is not mandatory e-invoicing

These are different obligations. Verifactu regulates the software you invoice with, whether your customers are businesses or consumers. Mandatory electronic invoicing between businesses and professionals comes from Law 18/2022, known as the "Crea y Crece" (Create and Grow) Act, and is implemented by Real Decreto 238/2026, de 25 de marzo (Royal Decree 238/2026 of 25 March). It will apply 12 months after a ministerial order comes into force if your volume of operations exceeds €8 million, and 24 months after it in all other cases. As of 27 September 2026, that order has not been published in the BOE, so there is no fixed date yet. The draft that the Ministry of Finance put out for public consultation in April 2026 provides for it to come into force on 1 October 2026; if it is approved on those terms, the obligation would arrive in October 2027 for those above €8 million and in October 2028 for everyone else. But it is only a draft: until the order appears in the BOE, the clock does not start. When it arrives, your software will have to comply with both.

How to get ready: steps and common mistakes

1. Take stock of everything that issues invoices: invoicing software, POS terminal or till that issues simplified invoices, online shop, apps and spreadsheets.
2. Ask each provider for the self-declaration of conformity, the date you will have the adapted version and whether the cost is covered by your maintenance contract.
3. Choose a mode. For many small businesses, VERI*FACTU makes things simpler because it saves you signing and storing the records. You can try it before the deadline without being tied to it.
4. Test before the deadline: issue invoices, corrective invoices and cancellations, and check the QR code.
5. Train whoever does the invoicing, especially on how to correct mistakes without deleting anything.

The most common mistakes:

• Thinking that invoicing little or being taxed under módulos keeps you out, even though you issue invoices with software.
• Thinking that simplified invoices do not count.
• Trusting an "approved" program without asking for the self-declaration of conformity.
• Deleting or editing an invoice already issued instead of cancelling or correcting it.
• Confusing Verifactu with e-invoicing and ending up paying for two tools when one program can handle both.
• Leaving it until December if you are a company, or June if you are self-employed.

If you are unsure whether your business is affected, which mode suits you or whether what your provider offers complies, we can review it with you. You can book a tax consultation or read our summary of the 2026 tax changes, where we also cover e-invoicing.

Legislation and sources

• Royal Decree 1007/2023 of 5 December (consolidated text)
• Royal Decree-law 15/2025 of 2 December
• Law 58/2003, General Taxation Act (articles 29.2.j and 201 bis)
• Order HAC/1177/2024 of 17 October
• Royal Decree 238/2026 of 25 March on electronic invoicing
• Tax Agency: invoicing software systems and VERI*FACTU
• Tax Agency: FAQs on the scope of application
• Tax Agency: note on the extended adaptation deadline