Verifactu: 2025-2026 E-Invoicing Regulation

Spain is implementing Verifactu, a comprehensive e-invoicing regulation that will fundamentally transform how businesses issue, store, and report invoices. This guide explains everything you need to know about Verifactu and how Factumo ensures your business stays compliant.

What Is Verifactu?

Verifactu (short for "Verificación de Facturas" or Invoice Verification) is Spain's new mandatory electronic invoicing system, set to roll out in 2025 with full enforcement by 2026. It's part of a broader EU initiative to combat VAT fraud, improve tax collection, and modernize tax administration.

Core Objectives

Verifactu aims to:

• Prevent VAT fraud through real-time invoice verification
• Ensure invoice integrity with digital signatures and cryptographic sealing
• Enable automated tax reporting reducing manual declaration work
• Standardize electronic invoicing across all Spanish regions
• Improve audit efficiency for tax authorities
• Support business digitalization while maintaining compliance

Unlike simple electronic invoicing (which many businesses already use), Verifactu mandates specific technical requirements, software certification, and real-time reporting obligations.

Why Verifactu Matters for Your Business

Every business operating in Spain will be affected by Verifactu, regardless of size, sector, or current invoicing methods.

The End of Simple Digital Invoices

Currently, you can create invoices using basic accounting software or any tool that includes mandatory fields. As long as the invoice contains required information and you store it properly, you're compliant.

Verifactu changes this fundamentally.

Under the new regulation, invoices must be:

• Generated through certified software that meets technical specifications
• Digitally signed or sealed to ensure integrity and non-repudiation
• Reported in real-time (or near real-time) to tax authorities
• Traceable through standardized formats and unique identifiers
• Verifiable by clients and authorities through QR codes or electronic validation

Simply put: your current invoicing method likely won't meet Verifactu requirements without significant upgrades or replacement.

Who Is Affected?

Large enterprises: Companies with revenue over €6M annually will be first to implement, likely starting in early 2025.

Medium businesses: Companies with €1M-€6M revenue will follow, probably mid-2025.

Small businesses and freelancers: All autónomos and small businesses will eventually need to comply, likely by early 2026.

All VAT-registered businesses: If you charge VAT (IVA) and issue invoices to Spanish clients, Verifactu will apply.

Legal Consequences of Non-Compliance

While some aspects may have transition periods, eventual compliance will be mandatory. Non-compliant businesses could face:

• Fines for invalid invoice formats or missing technical elements
• Rejected VAT deductions for invoices that don't meet standards
• Inability to work with large clients who require Verifactu-compliant suppliers
• Audit complications and increased scrutiny from tax authorities
• Competitive disadvantages as compliant businesses gain efficiency advantages

Implementation Timeline

Understanding the timeline helps you plan your transition and avoid last-minute scrambling.

2024: Preparation Phase

Throughout 2024, the Agencia Tributaria is:

• Finalizing technical specifications
• Publishing detailed implementation guidelines
• Certifying initial software providers
• Conducting pilot programs with early adopters
• Providing education and resources to businesses

What you should do now: Stay informed, evaluate your current invoicing systems, and begin researching compliant solutions.

2025: Gradual Implementation

The rollout will likely be phased:

Q1-Q2 2025:

• Large enterprises (€6M+ revenue) begin mandatory implementation
• Software vendors release certified Verifactu solutions
• Voluntary early adoption encouraged for all businesses

Q3-Q4 2025:

• Medium businesses (€1M-€6M revenue) must comply
• Regional variations (if any) announced
• Support programs for SMEs launched

What you should do: Select and implement compliant software, train staff, test systems, and transition invoicing processes.

2026: Full Enforcement

By 2026, Verifactu compliance becomes mandatory for virtually all businesses:

• Q1 2026: Small businesses and remaining sectors must comply
• Q2 2026: Enforcement begins with penalties for non-compliance
• Mid-2026 onwards: Verifactu becomes the standard operating environment

What you should do: Ensure complete compliance, maintain certification, and optimize your processes for the new reality.

Important Note

These timelines are approximate based on current government communications. Official dates may shift, and specific sectors might have different deadlines. Monitor official Agencia Tributaria announcements for definitive timelines.

Technical Requirements

Understanding the technical aspects of Verifactu helps you evaluate software solutions and prepare your systems.

Software Certification

Under Verifactu, you cannot use uncertified software for invoicing. Your invoicing system must be:

Certified by the Agencia Tributaria: Software providers must submit their solutions for official testing and certification.

Compliant with technical specifications: Meeting exact standards for data structures, security, and functionality.

Regularly updated: Certifications must be maintained as regulations evolve.

Audit-ready: Built-in features for record keeping, reporting, and verification.

What this means for you: You'll need to use certified software from approved vendors. Your homemade Excel templates or generic accounting software won't suffice unless the provider obtains certification.

Digital Signatures and Cryptographic Seals

Every Verifactu invoice must include a digital signature or cryptographic seal ensuring:

Authenticity: Proof that the invoice came from your business.

Integrity: Verification that the invoice hasn't been altered after creation.

Non-repudiation: You cannot later claim you didn't issue the invoice.

Timeline verification: Proof of when the invoice was created.

These signatures use public-key cryptography (similar to SSL certificates for websites) and create a unique "fingerprint" for each invoice that can be mathematically verified.

Technical implementation: Your certified software handles this automatically. You won't need to manually sign each invoice, but your system will generate and attach cryptographic data to every invoice created.

Certificate management: Businesses will need digital certificates (similar to electronic ID or fiscal certificates). These may be:

• Company digital certificates from approved providers
• Integration with existing company certificates
• Simplified solutions for small businesses

QR Codes for Verification

Verifactu invoices must include QR codes containing:

• Invoice identification (number, date, issuer)
• Transaction summary (amounts, VAT)
• Digital signature reference
• Link to verification portal

How it works: Clients or tax authorities can scan the QR code with a smartphone to instantly verify invoice authenticity and access complete invoice data through the Agencia Tributaria's verification portal.

Benefits:

• Immediate fraud detection
• Easy validation for clients
• Simplified audit processes
• Reduced paper documentation needs

Format: QR codes must meet specific technical standards ensuring they contain properly structured data in certified formats.

Real-Time Reporting Obligations

Verifactu requires submitting invoice data to the Agencia Tributaria in real-time or near real-time.

What gets reported:

• Complete invoice data (not just summaries)
• Client information
• Product/service details
• VAT calculations
• Payment terms
• Any corrections or credit notes

When to report:

• Immediately upon invoice creation (preferred)
• Within 4-8 days maximum (likely requirement)
• Before certain business events (still being defined)

Technical implementation: Your certified software automatically transmits invoice data to tax authority systems via secure APIs. You won't manually upload files, but your system needs reliable internet connectivity.

Challenges to consider:

• Connectivity requirements: Businesses need stable internet for real-time reporting
• System downtime: What happens if tax authority systems are unavailable?
• Volume handling: High-volume businesses need systems that can report thousands of invoices efficiently
• Error handling: Rejected invoices require correction and resubmission processes

XML/JSON Data Formats

Verifactu mandates structured data formats for invoices:

XML (Extensible Markup Language): Hierarchical format defining invoice data in standardized tags.

JSON (JavaScript Object Notation): Alternative format with similar structured data in a different syntax.

Both formats ensure:

• Machine-readable invoice data
• Standardized field definitions
• Automated processing by tax systems
• Integration with accounting and ERP systems
• International interoperability

What this means for you: Your invoices will exist as structured data files, not just PDFs. Certified software generates both human-readable PDF versions and machine-readable XML/JSON versions simultaneously.

Invoice Storage Requirements

Verifactu doesn't replace existing 7-year retention requirements but adds new elements:

What you must store:

• Human-readable invoice (PDF or printed)
• Machine-readable XML/JSON file
• Digital signature/seal data
• Transmission confirmation from tax authorities
• Any supporting documentation

How to store:

• Electronic storage in certified formats
• Cloud or local storage with proper backups
• Searchable and retrievable within specified timeframes
• Protected from unauthorized alteration
• Accessible for audit purposes

Certified software typically includes: Integrated storage solutions meeting all retention requirements.

How Verifactu Differs from Current Invoicing

Let's compare traditional invoicing practices with Verifactu requirements to highlight the changes.

Invoice Creation

Current: Create invoices using any software (Word, Excel, accounting software, specialized tools) as long as mandatory fields are included.

Verifactu: Use only certified software that generates cryptographically signed invoices with proper data structures and QR codes.

Format Requirements

Current: Any readable format (PDF, paper, even email) containing mandatory information.

Verifactu: Dual format—human-readable (PDF/paper) plus machine-readable (XML/JSON) with digital signatures.

Client Delivery

Current: Send via email, postal mail, or hand delivery. No specific format requirements.

Verifactu: Electronic delivery preferred; invoice must include QR code for verification; structured data should be available to client.

Tax Reporting

Current: Manual quarterly VAT declarations (Modelo 303) summarizing your invoices.

Verifactu: Automatic real-time reporting to tax authorities as invoices are created; potentially simplified or automated periodic declarations.

Verification

Current: No standardized way for clients to verify invoice authenticity except contacting issuer.

Verifactu: Instant verification via QR code scan and tax authority portal; clients can confirm invoice validity immediately.

Corrections

Current: Issue credit notes (facturas rectificativas) with proper references and documentation.

Verifactu: Same credit note requirements, but corrections must also be digitally signed, reported in real-time, and linked cryptographically to original invoices.

Record Keeping

Current: Store invoices in any organized system (physical files, digital folders, accounting software) for 7 years.

Verifactu: Maintain both formats (readable and structured), preserve digital signatures, store transmission confirmations, use certified storage systems.

Evolution from TicketBAI

Verifactu didn't appear from nowhere—it builds directly on TicketBAI, a regional system that's been operating in the Basque Country since 2021.

What Is TicketBAI?

TicketBAI (Ticket Bien/Árbitro/Irrefutable—"Good/Referee/Irrefutable Ticket") is a mandatory invoicing system in the Basque provinces (Álava, Bizkaia, Gipuzkoa) that requires:

• Software certification for invoice generation
• Digital signatures on every invoice
• XML format for invoice data
• QR codes for verification
• Real-time or near-real-time reporting to Basque tax authorities

TicketBAI was designed to eliminate "dual registers" (hidden sales) and ensure all transactions are properly recorded and taxed.

From Regional to National

Verifactu essentially takes the TicketBAI concept and extends it nationwide with some modifications:

Similarities:

• Certified software requirements
• Digital signatures/seals
• QR codes on invoices
• Structured data formats (XML/JSON)
• Real-time reporting obligations

Differences:

• Nationwide scope vs. regional
• Potential for unified reporting (not multiple regional systems)
• Different technical specifications adapted for broader application
• Integration with EU-wide ViDA initiative
• More flexibility for different business sizes and sectors

Lessons from TicketBAI Implementation

The Basque experience provides valuable insights:

Initial challenges: Businesses faced learning curves with new software, workflow changes, and training needs.

Adaptation period: Most businesses needed 3-6 months to fully integrate TicketBAI into operations.

Software quality matters: Certified solutions varied significantly in usability and feature richness.

Support is essential: Businesses with good vendor support and training transitioned more smoothly.

Long-term benefits: After initial adjustment, many businesses reported improved accounting accuracy and reduced administrative burden.

Preparing Your Business

Successful Verifactu implementation requires planning and systematic preparation.

Now Through Early 2025: Research and Planning

Assess your current situation:

• How many invoices do you issue monthly?
• What software do you currently use?
• What's your typical invoice complexity?
• Do you have specific industry requirements?

Research solutions:

• Identify certified software providers
• Request demos and trial accounts
• Compare features, pricing, and support
• Check certification status with Agencia Tributaria

Budget allocation:

• Software costs (monthly or annual)
• Implementation and setup fees
• Training expenses
• Potential hardware (if needed for digital certificates)
• Consultant fees (if using external help)

Stakeholder communication:

• Inform staff about upcoming changes
• Discuss with accountant or fiscal advisor
• Notify key clients about invoice format changes
• Coordinate with IT support if you have it

Q1-Q2 2025: Selection and Initial Implementation

Choose your software:

• Make final provider selection
• Sign contracts and establish accounts
• Obtain necessary digital certificates
• Complete initial software setup

Data migration:

• Export existing client data
• Import into new system
• Verify data accuracy
• Set up product/service catalogs

Process documentation:

• Document new invoicing workflows
• Create templates for common invoice types
• Establish approval processes if needed
• Define roles and responsibilities

Initial training:

• Complete provider training programs
• Practice with test invoices
• Learn troubleshooting basics
• Understand error handling

Q3-Q4 2025: Testing and Parallel Operation

Run parallel systems:

• Continue current invoicing while testing new system
• Create invoices in both systems for comparison
• Validate that Verifactu invoices are accurate
• Test real-time reporting functionality

Client communication:

• Inform clients about upcoming invoice format changes
• Explain QR code verification process
• Update billing agreements if needed
• Address any client concerns or questions

Troubleshooting:

• Identify and resolve any technical issues
• Work with provider support on problems
• Refine workflows based on real-world use
• Document solutions to common problems

Final preparation:

• Complete staff training
• Verify digital certificate validity and renewal process
• Test backup and recovery procedures
• Ensure reliable internet connectivity

2026: Full Transition and Optimization

Complete migration:

• Discontinue old invoicing methods
• Operate exclusively with Verifactu-compliant system
• Monitor compliance continuously
• Stay current with certification renewals

Optimization:

• Streamline workflows based on experience
• Leverage automation features
• Improve efficiency and reduce manual effort
• Explore advanced features

Ongoing compliance:

• Monitor regulatory updates
• Apply software updates promptly
• Maintain proper documentation
• Conduct periodic internal reviews

Penalties for Non-Compliance

While specific penalty structures for Verifactu non-compliance haven't been fully detailed, we can anticipate enforcement similar to other tax regulations.

Likely Penalty Categories

Technical non-compliance: Using non-certified software, missing required technical elements (signatures, QR codes), improper data formats.

Reporting failures: Not submitting invoice data in real-time, missed reporting deadlines, incomplete information.

Record-keeping violations: Inadequate storage, inability to provide documentation during audits, lost digital signatures.

Systematic violations: Repeated non-compliance, patterns of invalid invoices, intentional circumvention.

Potential Consequences

Based on existing Spanish tax penalties, expect:

Minor infractions: €150-€400 per invoice for technical errors or format issues.

Serious infractions: €400-€2,000 per invoice for systematic non-compliance or reporting failures.

Very serious infractions: €2,000+ per invoice for deliberate evasion or fraud.

VAT complications: Rejected VAT deductions, additional tax assessments, interest on unpaid amounts.

Business restrictions: Inability to invoice certain clients (particularly government or large corporations requiring compliant suppliers).

Risk Mitigation

Avoid penalties by:

• Implementing certified software before mandatory deadlines
• Testing thoroughly before go-live
• Maintaining proper record keeping
• Staying informed about regulatory updates
• Working with qualified fiscal advisors
• Responding promptly to any compliance issues

International Context: ViDA and EU E-Invoicing

Verifactu isn't just a Spanish initiative—it's part of a broader European Union movement toward standardized electronic invoicing.

VAT in the Digital Age (ViDA)

The EU's ViDA directive aims to:

• Harmonize e-invoicing requirements across member states
• Reduce VAT fraud (estimated at €50 billion annually)
• Enable real-time reporting for cross-border transactions
• Simplify compliance for businesses operating in multiple countries
• Modernize VAT systems for the digital economy

Spain's Verifactu implements ViDA principles at the national level, joining other countries like Italy (FatturaPA), France (Chorus Pro), and Poland (KSeF) with mandatory e-invoicing systems.

Implications for International Business

Spanish companies with EU clients: Future standardization may simplify cross-border invoicing as more countries adopt compatible systems.

Foreign companies in Spain: Non-Spanish businesses with Spanish operations must comply with Verifactu for local transactions.

Export/import considerations: While Verifactu focuses on domestic and EU transactions, international trade documentation may eventually integrate with these systems.

Competitive advantage: Early adoption positions businesses well for expanding into other EU markets with similar requirements.

How Factumo Prepares You for Verifactu

At Factumo, we've been preparing for Verifactu since the regulation was announced. Our development team has been working closely with the evolving specifications to ensure seamless compliance when requirements take effect.

Built-In Certification

Factumo is pursuing official Agencia Tributaria certification and will be fully compliant before mandatory implementation deadlines. You won't need to migrate to different software when Verifactu goes live—your existing Factumo invoices will automatically meet new requirements.

Automatic Technical Compliance

Factumo handles all technical requirements automatically:

• Digital signatures: Integrated cryptographic signing for every invoice
• QR code generation: Compliant QR codes added to all invoices automatically
• Structured data: Proper XML/JSON formatting behind the scenes
• Real-time reporting: Automatic transmission to tax authorities
• Certificate management: Simplified digital certificate integration

Seamless Transition

Current Factumo users will experience:

• No workflow disruption: Your invoicing process remains familiar
• Automatic updates: Verifactu features deployed without user action required
• Guided setup: Step-by-step assistance for any new requirements
• Training resources: Documentation and support for understanding changes
• Continued simplicity: Complexity hidden behind user-friendly interface

Future-Proof Solution

As Verifactu evolves and regulations change:

• Regular software updates maintaining compliance
• Integration with future EU standards
• Adaptation to new technical requirements
• Ongoing certification renewals
• Continuous improvement based on regulatory changes

Spanish Market Expertise

Unlike generic international accounting platforms, Factumo was built specifically for Spain:

• Deep understanding of Spanish tax law
• Native Spanish interface and support
• Relationships with Spanish tax authorities and advisors
• Focus on requirements specific to Spanish businesses
• Proven track record with complex Spanish invoicing rules

Best Practices for Verifactu Readiness

Start Early

Don't wait until the last minute:

• Begin researching solutions in 2024
• Allow 3-6 months for full implementation
• Test thoroughly before mandatory deadlines
• Learn from early adopters

Stay Informed

Monitor official sources:

• Agencia Tributaria website and bulletins
• Software provider communications
• Professional tax advisor updates
• Industry association announcements

Choose Certified Software Carefully

Your provider choice impacts compliance, efficiency, and daily operations:

• Verify official certification status
• Test user experience thoroughly
• Evaluate support quality
• Consider long-term relationship
• Ensure integration capabilities

Train Your Team

Successful adoption requires proper training:

• All staff who create invoices
• Accounting/finance team members
• Management understanding compliance requirements
• Ongoing education as regulations evolve

Communicate with Clients

Keep clients informed:

• Explain upcoming invoice format changes
• Educate about QR code verification
• Address any concerns proactively
• Maintain professional relationship

Frequently Asked Questions

Do I really need to comply with Verifactu?

Yes, if you're a VAT-registered business operating in Spain. Compliance will be mandatory for virtually all businesses by 2026.

What if I'm just a freelancer (autónomo)?

Freelancers must comply too. The requirements apply to all businesses that issue invoices, regardless of size.

Can I continue using my current software?

Only if your current provider obtains Verifactu certification. Otherwise, you'll need to switch to certified software.

When exactly do I need to be compliant?

Specific deadlines depend on your business size and sector. Large enterprises likely in 2025, smaller businesses by 2026. Monitor official announcements.

How much will Verifactu-compliant software cost?

Costs vary by provider and features. Budget for monthly subscription fees, potential setup costs, and training time.

What happens if I don't comply on time?

You risk fines, rejected VAT deductions, inability to work with certain clients, and audit complications.

Will my clients need to do anything differently?

They'll receive invoices with QR codes and can verify authenticity instantly. Otherwise, the experience is similar for them.

Can I still issue paper invoices?

Digital invoicing will become the standard under Verifactu. While paper copies may be allowed, the underlying invoice must be generated through certified digital systems.

What about my historical invoices?

Historical invoices remain valid. Verifactu applies to new invoices created after implementation deadlines.

How does this affect my VAT declarations?

Real-time reporting may simplify or automate portions of your quarterly VAT declarations (Modelo 303).

Next Steps

Learn more about related compliance topics:

• Audit Trail - How Factumo maintains complete audit records
• Data Retention - 7-year storage requirements and best practices
• Spanish Requirements - Current invoicing legal requirements

Stay Updated

Verifactu is an evolving regulation with ongoing announcements and clarifications. Factumo will keep you informed as details emerge and ensure your business remains compliant throughout the transition.

Stay ahead of Verifactu requirements with Factumo. Our platform is being built from the ground up for compliance with Spain's new e-invoicing regulations. Focus on growing your business while we handle the complexity of Verifactu compliance automatically.

Questions about Verifactu? Contact support at support@factumo.com or consult your tax advisor for specific situations.