Verifactu: what it is, who must comply and from when, after the postponement to 2027

Invoicing for companies and self-employed workers is facing a structural change. The system known as Verifactu will require invoices to be issued through billing software that guarantees the integrity and traceability of every record, so that they cannot be altered after being issued. It is worth placing the change in its proper dimension, however: what it is exactly, what legal basis it rests on, who it applies to and from when. The timetable has changed —the obligation has been postponed to 2027—, and that margin should be used to prepare the transition in an orderly way.

What Verifactu is and what billing software systems are

Under the name Verifactu sits the new regulation of billing software systems —known in Spain as SIF, that is, the programs with which businesses and professionals issue their invoices—. Its origin lies in Law 11/2021 of 9 July on measures to prevent and combat tax fraud (the Anti-Fraud Law), which introduced a new duty into Law 58/2003, the General Tax Act (LGT): under its article 29.2.j), the systems and programs supporting billing processes must guarantee the integrity, preservation, accessibility, legibility, traceability and unalterability of the records. The stated aim is to eradicate so-called dual-use software —programs that allow parallel accounting to be kept or sales to be altered without leaving a trace—.

That legal duty is developed by Royal Decree 1007/2023 of 5 December, which approves the Regulation on billing software systems, and by Order HAC/1177/2024 of 17 October, which sets out the technical, functional and content specifications. From that body of rules comes what the public knows, in short, as Verifactu.

How it works: the fingerprint, the chaining and the two modes

The mechanism is uniform. Each invoice generates a billing record which the program signs with a fingerprint or hash —a string of characters that summarises the content of the record— and which is chained to the previous record, so that any subsequent modification would break the chain and become evident. Under Order HAC/1177/2024, those records are structured in XML format and the invoice carries a QR code that allows it to be verified.

From there, the Regulation provides for two modes. In the strict Verifactu mode, the system automatically transmits each billing record to the Tax Agency at the moment the invoice is issued; in return, part of the technical preservation requirements is relaxed. In the non-Verifactu mode, the company does not transmit the records but must keep them with reinforced guarantees of unalterability and hold them at the disposal of the Administration. Both are valid; the choice has operational consequences worth weighing.

Verifactu is not mandatory electronic invoicing —nor TicketBAI—

A common mistake is to confuse Verifactu with mandatory business-to-business electronic invoicing. These are distinct obligations, with independent legal frameworks. B2B electronic invoicing stems from Law 18/2022 of 28 September on the creation and growth of companies (the Crea y Crece Act) and regulates the format in which invoices must be exchanged between companies and professionals —a structured format, automatically readable by another program—; its enforceability still depends on the implementing regulation. Verifactu, by contrast, does not regulate the format of the invoice but the software that produces and records it, and it reaches any invoice, including one addressed to a final consumer.

Nor should it be confused with TicketBAI, the system specific to the Basque foral territories (and its equivalent in Navarre). Anyone who is taxed in foral territory is subject to TicketBAI, not to Verifactu.

Who must comply and who does not

The obligation applies, as a general rule, to businesses and professionals who issue invoices and use software to do so, both companies and self-employed workers. Excluded, among others, are those already enrolled in the VAT Immediate Supply of Information (SII) —who transmit their billing records through that channel— and those taxed in the foral territories mentioned above. Determining precisely whether your activity falls within the scope, and on what date, is the first step: it is not always obvious for someone who carries on several activities or is taxed under special regimes.

From when: the timetable in force after the postponement to 2027

The original timetable has been amended. Royal Decree-Law 15/2025 of 2 December (published in the Official State Gazette on 3 December 2025) amended the fourth final provision of the Regulation and postponed by one year the enforceability of the system. The dates now in force are:

• 1 January 2027 for Corporate Income Tax payers —limited and public limited companies, cooperatives and other legal entities—.
• 1 July 2027 for the remaining obligated taxpayers: self-employed workers taxed under personal income tax (IRPF), non-residents with a permanent establishment and entities under the income-attribution regime.

The postponement does not remove the obligation: it defers it. And it does not authorise the use, in the meantime, of programs that allow invoicing to be manipulated, since the prohibition in article 29.2.j) of the LGT has been in force since 2021. In parallel, software manufacturers and distributors were already required to offer adapted products —the deadline set for them by Order HAC/1177/2024 expired in July 2025—, so an offering of compliant programs already exists on the market.

What a company or a self-employed worker must do to comply

The key lies in the software. From the applicable date, only billing programs that meet the requirements of the Regulation and that the manufacturer has adapted and certified through the corresponding responsible declaration may be used. Preparation therefore involves checking whether the current program will be compatible with Verifactu or will need to be replaced, choosing between the transmission mode and the preservation mode, and reviewing the internal processes for issuing and keeping invoices.

The incentive to get it right is not minor. Article 201 bis of the LGT, also introduced by the Anti-Fraud Law, penalises the manufacture or marketing of non-compliant systems with a fixed fine of 150,000 euros per financial year and type of system, and the mere possession of uncertified systems with 50,000 euros per financial year. Verifactu is not, then, a simple change of program: it affects how income is documented and the company's position in the event of a tax audit. Anticipating the transition, rather than resolving it on the eve of the deadline, is what separates an orderly adaptation from an improvised one.

How we help you with Verifactu and billing systems in Murcia at RCM Legal

Two questions concentrate most of the doubts in adapting to Verifactu: pinning down whether the activity falls within the scope of the obligation and on what date —something that is not always obvious for those who already operate under the SII, carry on several activities or are taxed under a special regime— and ensuring that the billing program will be certified by the manufacturer through the required responsible declaration, in the mode that best suits the company. Resolving both in good time, and not when the date is already imminent, avoids operational incidents and the sanctioning risk of article 201 bis of the LGT.

At RCM Legal, as a tax advisory firm in Murcia, we advise companies and self-employed workers on the scope of their invoicing obligations, the date that applies to them and the requirements their billing software must meet, in coordination with their tax adviser and their software provider, and we review their issuing and preservation processes to bring them into line with the anti-fraud rules. If you wish to prepare your company or your activity for Verifactu with due notice, tell us about your case and we will plan the transition without surprises.