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Compliance

Verifactu for the self-employed, without the scare

The rule is short and what it asks for is specific. The problem is that almost everything written about it was written to sell a piece of software.

appnweb Published Reviewed 7 min read

The short answer

If you invoice in Spain, Verifactu applies to you. It requires invoices to be issued by software that cannot alter them afterwards: each invoice is chained to the previous one by a hash, carries a QR code, and states whether its record is being sent to the tax agency. Companies are obliged from 1 January 2027 and everybody else, the self-employed included, from 1 July 2027. The only thing you have to do is use software that complies — and ask yours today whether it will.

What it actually requires

The regulation does not ask you to keep your books differently or change your prices. It asks that the software you issue invoices with be incapable of altering a record once made, and that it prove as much.

That comes down to four visible things: each invoice generates a record with a cryptographic hash chaining it to the previous one, the software cannot delete or modify that record, the invoice carries a QR code that allows it to be checked, and it carries text saying whether the record is being sent to the tax agency.

There are two ways to comply. One is automatic submission of each record to the AEAT at the moment of issue, which is what Verifactu properly means. The other is not submitting, in which case the system faces additional retention and signature requirements. For a sole trader, submitting is usually simpler and cheaper.

  • A chained, unalterable record per invoice
  • A QR code on the invoice
  • Text stating whether it is submitted to the AEAT
  • Retention of the record for the statutory period

From when

The original timetable was extended. As it now stands, companies are obliged from 1 January 2027 and other obliged parties, the self-employed included, from 1 July 2027.

That sounds far away and it is not. What takes time is not switchover day but finding out whether your current software will comply, and what happens to the history if it does not and you have to change. That conversation is better had with twelve months in hand than two.

Four questions for your software

If you already use invoicing software, you do not need to replace it by default. You need to ask it four things, and to ask them in an email so the answer is kept.

If the answer to any of them is vague, treat it as a no. By this stage a serious vendor has a public page saying exactly what it does and from which version.

  • Will your software be adapted, and in which version?
  • Is it included in my current licence or a separate cost?
  • Will I have to migrate my invoice history, and who does it?
  • Does it support Verifactu mode with AEAT submission, or only the non-submitting mode?

What it has to do with your website

If you sell online, the invoice is issued by your shop, not by your accountant. That means the requirement falls on the shop’s software, and it is where most people will get a surprise: an invoicing plugin nobody has touched in three years is not going to comply by itself.

If you raise invoices one at a time from a desktop program and the website is only a shop window, this does not affect your website at all. It is worth being clear which of the two yours is before paying to fix something that is not broken.

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Common questions

If your question isn’t here, write to us and we’ll answer it. Contact

Does it apply if I only issue ten invoices a year?

Yes. The obligation depends on issuing invoices in Spain, not on volume. What volume does change is how expensive it is to solve: with ten invoices a year, a free compliant program is plenty.

Can I keep making invoices in a spreadsheet?

No, once the obligation applies to you. A spreadsheet lets you modify what was issued, which is exactly what the regulation sets out to prevent. It is the most uncomfortable change for anyone who has done it that way for twenty years, and the hardest to avoid.

What about old invoices?

They do not have to be redone. The obligation applies to invoices issued from your start date onwards, not retrospectively. What is worth doing is keeping the history accessible, which was already required before any of this.

Do I have to send everything to the tax agency?

Only if you opt into Verifactu mode with submission, which is one of the two ways to comply. The other does not submit but imposes stricter requirements on the system itself. For most sole traders, submitting is the simpler option.

Is this the same as mandatory e-invoicing?

No, and the two are constantly confused. Verifactu is about how the invoices you issue are recorded. Mandatory business-to-business e-invoicing is a separate rule with its own timetable. Two separate things arriving at roughly the same time.

We set it up before the date

If you invoice from your shop or your website, we prepare it in good time and wired into what you already use. If your case is solved by a €12-a-month program, we will say so.

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