Verifactu 2027: Requirements and Who Is Exempt

Verifactu is not a program to install or a form to file. It is a set of requirements that your invoicing software has to meet so the Spanish tax authority can accept the records it produces. The distinction matters, because it determines who you need to call: not your tax adviser, but your software vendor.

This is the rule's second postponement — the first had already moved the dates to 2026 — and it has created a dangerous reflex: waiting for the next one. This article goes into what exactly is required, who falls outside the scope — more companies than people think — and what to ask your vendor. If what you need is the difference between Verifactu and mandatory e-invoicing, we cover that in a separate article.

1Who is outside Verifactu's scope (check this first)

Before spending a single euro it is worth checking whether it applies to you. There are four situations in which the regulation does not apply, and the first two are more common than they look.

2The two modes: send or store

The regulation allows two ways to comply, and the choice is not trivial: it changes what the software must do and what you must keep.

For most small and mid-sized companies the sending mode is the sensible option: it shifts much of the retention and event-logging burden to the authority's side. The non-sending mode makes sense when there are connectivity, volume or internal-policy reasons not to transmit in real time, but it demands more technical discipline.

3Verifactu requirements for your software

These are the requirements the program must meet, whichever mode you choose.

In the sending mode, invoices also carry a statement that they can be verified at the tax authority's electronic office. That is the part the customer sees and the one that usually prompts the first question.

4What to ask your vendor

The useful conversation takes ten minutes and consists of these questions. If any of them goes unanswered, that is where the risk sits.

• Have you issued the declaration of compliance? "We're working on it" does not count. Ask for the document.
• Which mode will you work in? With or without transmission to the authority, and whether the customer can choose.
• Is it included in my current licence or is it a separate module? This is where the costs nobody budgeted for show up.
• What happens to my history? How earlier invoices coexist with the new chain of records.
• And the invoices I issue from elsewhere? The sales rep's spreadsheet, the shop till, the ecommerce platform. All of them are invoicing systems.
• When will it be available and what do you need from me? So it can sit in a real calendar rather than in the final weeks before your deadline.

5What non-compliance costs

Article 201 bis of the Spanish General Tax Act provides for a fixed fine of 50,000 euros per financial year for holding or using invoicing systems that do not comply, or that have been altered. And it accumulates: each year the situation persists counts separately.

For those who produce or market the software the amounts are higher: 150,000 euros per financial year for each type of non-compliant system, and 1,000 euros for each system sold without the required certification, which the regulation implements as a declaration of compliance. That is why serious vendors have been moving for a while: the risk is theirs too.

6How to make it more than an expense

Adapting to Verifactu on its own does not save a single minute of work. It is pure cost. What does change is the context: to comply you are going to review how every invoice is issued, from where and with what data. That inventory is exactly the starting point of any automation project.

The official reference, with the technical specifications and the updated FAQ, is the electronic office of the Spanish tax authority, the Agencia Tributaria. This article is informative and does not replace tax advice.

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