Where it comes from
Law 11/2021 on preventing tax fraud added to the General Tax Act an obligation for producers, sellers and users of systems supporting accounting, invoicing or management: they must ensure the integrity, retention, accessibility, legibility, traceability and unalterability of records (Art. 29.2.j). It has been in force since October 2021.
The same law set the penalties (Art. 201 bis): 150,000 euros per year for anyone producing or selling non-compliant systems, and 50,000 euros per year for users holding an uncertified or altered system.
Royal Decree 1007/2023 implements that obligation for computerised invoicing systems (SIF), and Order HAC/1177/2024 sets out their technical specifications.
What it requires of an invoicing system
- Each invoice generates a registration record when it is issued, and each cancellation a cancellation record.
- Each record includes a fingerprint (SHA-256 hash) that takes part of the previous one. This forms a chain: changing an old record breaks every later fingerprint.
- Corrections are made with new records, never by modifying existing ones.
- The invoice carries a QR code with the issuer's tax ID, series and number, date and total, which can be checked on the Tax Agency's website.
- The software producer signs a statement of compliance, visible in every version.
The two modes
| VERI*FACTU | Non-VERI*FACTU | |
|---|---|---|
| Sending to the Tax Agency | All records, automatically and continuously | No; records are retained |
| Electronic signature of records | Not needed: the fingerprint is enough | Mandatory |
| Event log | No | Mandatory |
| Wording on the invoice | «VERI*FACTU» or «Factura verificable en la sede electrónica de la AEAT» | None |
| QR code | Yes | Yes |
According to the Tax Agency's FAQ, you can switch to VERI*FACTU at any time and must keep that mode until the end of the calendar year.
The timeline
The dates have changed several times. The wording in force is that of Royal Decree-Law 15/2025:
| Who | Date in force |
|---|---|
| Corporate income tax payers | Before 1 January 2027 |
| Everyone else covered (self-employed, permanent establishments, pass-through entities) | Before 1 July 2027 |
Who is covered and who isn't
- Covered: corporate income tax payers, self-employed people with business activity, non-residents with a permanent establishment and pass-through entities with business activity.
- Not covered: those keeping VAT records through Immediate Supply of Information (SII).
- The Basque Country and Navarre have their own systems; the regulation only reaches those with a tax address in the rest of Spain.
Pro forma invoices and legal invoices issued elsewhere
In logistics it is common to prepare the pro forma invoice in the operations software and issue the legal invoice in the accounting software. The Tax Agency has addressed this in its FAQ and its developer clarifications:
- Drafts and pro forma invoices are not prohibited and carry no QR code, as long as they are ultimately replaced by the invoice and the invoice is given to the client.
- The system generating pro forma invoices must be linked to the invoicing system, forming a single unit. Using preparatory documents without controls linking them to the final invoice would not be lawful and could be penalised.
- Under the general obligation in the General Tax Act, records of delivery notes, pro forma invoices and preliminary invoices must be kept unaltered; any change is made with a later record that leaves a trace.
- Invoices issued by another system can be imported with their records, without adding a QR code again or resending them to the Tax Agency.
In practice, if you prepare the pro forma in one program and invoice in another, each legal invoice should be linked to its pro forma, a closed pro forma should not be editable and its history should be kept.
Not to be confused with mandatory e-invoicing
VERI*FACTU is about how invoicing records are generated and kept. Mandatory B2B e-invoicing under Law 18/2022 is about how invoices are sent to the client and how their status is reported. They are two different obligations with different timelines.
E-invoicing is implemented by Royal Decree 238/2026, and Order HAC/1028/2026 regulates the public solution. According to the Tax Agency, it becomes mandatory on 6 October 2027 for businesses invoicing more than 8 million euros and on 6 October 2028 for everyone else.
Checklist
- Ask your invoicing provider for its statement of compliance.
- Decide whether you will work in VERI*FACTU or non-VERI*FACTU mode.
- Review the path from pro forma to invoice: they should be linked and a closed pro forma should not change.
- Review your series and how you cancel or correct an invoice.
- Follow the Official Gazette: the announced postponement isn't effective until it is published.
Sources
- Ley 11/2021, de 9 de julio, de medidas de prevención y lucha contra el fraude fiscal · BOE
- Ley 58/2003, General Tributaria (arts. 29.2.j y 201 bis) · BOE
- Real Decreto 1007/2023, Reglamento de los sistemas informáticos de facturación (consolidado) · BOE
- Orden HAC/1177/2024, de 17 de octubre (especificaciones técnicas) · BOE
- Real Decreto-ley 15/2025, de 2 de diciembre · BOE
- Nota informativa sobre VERI*FACTU (5-10-2026) · Ministerio de Hacienda
- Preguntas frecuentes: cuestiones generales, conceptos y definiciones · Agencia Tributaria
- Preguntas frecuentes: sistemas VERI*FACTU · Agencia Tributaria
- Aclaraciones a dudas de los desarrolladores (versión 1.3) · Agencia Tributaria
- Ley 18/2022, de creación y crecimiento de empresas · BOE
- Real Decreto 238/2026, de 25 de marzo (factura electrónica) · BOE
- Orden HAC/1028/2026, de 2 de octubre (solución pública de facturación electrónica) · BOE
This article is for information only and does not replace reading the official text or professional advice.