Verifactu: the Spanish invoicing rule that only applies if you use billing software

Spain's Verifactu system is only mandatory if you use a computerised invoicing system. Paper invoicing is exempt, but Excel counts. The fine print and the commercial noise.

English · Original discussion in Spanish · Published

Verifactu is not mandatory if you invoice by hand

A claim that stirs up controversy: Verifactu, the controversial system Spain's tax agency (AEAT) wants to impose to monitor invoices in real time, is not mandatory for everyone. The key lies in the type of invoicing you use. If you are one of those who still fill in invoices by hand or in Word without automation, you are exempt. But beware, the fine print of the law adds a caveat.

The regulation that clarifies it

The Anti-Fraud Law 11/2021 and Royal Decree 1007/2023 establish that the obligation to use Verifactu falls on those who use a Computerised Invoicing System (SIF). That is, any program, application or ERP designed to generate invoices automatically. If your business does not use any software to invoice — paper, pen or a non-computerised cash register — the AEAT does not require Verifactu from you. That is how clear it is in the official guides. However, the message that has taken hold among many self-employed workers and SMEs is the opposite: that everyone must adopt it. Commercial interest? Several software providers have taken advantage of the confusion to sell their solutions, sowing doubt among professionals.

The caveat that changes everything: Excel counts too

Here comes the catch. The tax agency considers that any computer program, even a spreadsheet like Excel, is a SIF if you use it to generate invoices. That means that if you keep your accounts with Excel, you fall under the obligation to have certified software or adapt to Verifactu. A software provider summed it up like this: "Verifactu is not mandatory if you invoice on paper, but if you use any invoicing program, you are required to comply". Most programs already include the module, but the self-employed worker who makes their invoices in Excel will have to migrate or certify their system. The cheapest solution, some point out, is to use the free program offered by the tax authorities, although its usability generates scepticism.

Commercial noise and doubts about the future

Underlying the debate is a suspicion: that antiestéticar of sanctions is being fuelled by those who sell certified software. The regulation, although clear on paper, leaves room for interpretation. For example, the changes planned for 2027, which will tighten the requirements, lead many to get ahead of the curve. But the question that remains is whether it is really worth investing now or whether one can wait. The AEAT, for its part, maintains an ambiguous position: it says Verifactu only applies to SIF, but defines SIF so broadly that almost any use of a computer for invoicing falls within its scope.

Prediction with reservations

The likely outcome is that, as 2027 approaches, the pressure will increase and more self-employed workers will end up adopting certified systems, even if they are not required to today. But as long as paper and pen remain legal, there will be those who prefer the old school to dodge the control. Time will tell whether the AEAT's interpretation narrows or expands. For now, the rule is clear: if you don't use software, you're out; if you use Excel, you're in. And the commercial noise does not help to see it clearly.

Summary of a discussion on Burbuja.info - Foro de economía, actualidad y política., translated from Spanish and reviewed before publication. Read the full discussion (13 replies).

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