Verifactu in Spain: an SMB guide (2027 deadlines, modes, and the real penalties)

If your SMB invoices in Spain, Verifactu affects you, but probably not the way you have been told. There is a lot of misinformation around: that it starts in July 2026, that you will have to send every invoice to the tax authority in real time, that there are fines of hundreds of euros per invoice. None of that is accurate. In December 2025 the government postponed the obligation by one year, and the system is more flexible than it looks. This guide summarizes, with the real dates and figures (verified in the BOE and at the Spanish tax authority), what Verifactu is, when it becomes mandatory for you, and what you should do.

What Verifactu is (and what it is not)

Verifactu is the set of requirements your invoicing software must meet to prevent invoices from being manipulated. It comes from the Anti-Fraud Law (Ley 11/2021) and is developed in the Regulation on Invoicing Software Systems (Royal Decree 1007/2023). The underlying idea is simple: every invoice is recorded in an unalterable way, chained with a digital fingerprint, so it cannot be deleted or modified without leaving a trace. The stated goal is to reduce fraud and so-called dual-use software, the programs that let a business keep one set of books for the tax authority and another real one.

Two common confusions are worth clearing up. Verifactu is not the SII (the Immediate Supply of Information that large companies already use), and it is not the mandatory business-to-business e-invoice from the Crea y Crece law (Ley 18/2022), which is a different rule with its own calendar. These are three separate things. This guide is only about Verifactu.

The real dates: 2027, not 2026

This is the most widespread mistake. The obligation for businesses was postponed by one year through Royal Decree-law 15/2025, published in the BOE on December 3, 2025 and later ratified by Congress. The current calendar is:

• Software manufacturers and resellers: already required since July 29, 2025 to offer programs that comply with the regulation.
• Companies subject to Corporate Income Tax: January 1, 2027.
• Self-employed and other taxpayers (IRPF): July 1, 2027.

In other words, during 2026 you are not required to use Verifactu. It is a year of preparation. That said, the postponement does not remove the technical requirements: it only delays the date on which they become mandatory for you.

Verifactu or No Verifactu: you do not have to send anything in real time

Another wrong idea is that you will be forced to send every invoice to the tax authority the moment you issue it. That is not the case. The regulation provides for two modes, and both are legal:

• Verifactu mode: your software sends the invoicing records to the tax authority automatically and immediately. In exchange, your retention obligations are lighter, because the copy is already with the tax authority.
• No Verifactu mode: your software sends nothing, but it must keep the records guaranteeing their integrity, traceability and unalterability, with a chained fingerprint and an event log.

Sending in real time is optional. What is mandatory is using a program that complies with the regulation. What disappears is invoicing with a manipulable Excel or Word, or with dual-use software.

What actually changes in your operation

1. Your software must comply (and self-certify)

The tax authority does not approve or homologate programs, and there is no official list of authorized software. It is the manufacturer who certifies, through a responsible declaration, that its system complies with the regulation, and that declaration must be visible inside the program itself. Your job is not to look for a tax-authority seal, but to confirm with your provider that its product includes that responsible declaration and meets the requirements.

2. Every invoice will carry a QR code

Invoices issued by a Verifactu-compliant system include a QR code. If your software works in Verifactu mode, the invoice also carries the legend "Factura verificable en la sede electronica de la AEAT" (invoice verifiable on the tax authority website). That QR lets the recipient verify the invoice or report it to the tax authority.

3. It only affects the invoices you issue

Verifactu records the invoices you issue, not the ones you receive. You do not have to report your suppliers invoices (that is something else). The focus is on guaranteeing that your own invoicing is complete and unalterable.

4. Keeping the records

Whether you send to the tax authority or not, you must keep the invoicing records complete and accessible for a possible audit. In No Verifactu mode this obligation is stricter, because you hold the only copy.

Who is left out

• Those who already keep their VAT books through the SII (large companies and others required to use the Immediate Supply of Information) are excluded from Verifactu.
• The Basque Country and Navarra have their own system, TicketBAI, with its own rules and deadlines. If you invoice there, that is your framework, not Verifactu.
• Operations and taxpayers with no obligation to issue invoices through software systems.

The real penalties (and the per-invoice fine myth)

There is no 600 euro fine per invoice, or anything like it. That figure circulates online and is false. The real penalties are in article 201 bis of the General Tax Law and apply per fiscal year, not per document:

• User (your company): up to 50,000 euros per year for holding or using a system that does not comply or that lacks the responsible declaration.
• Manufacturer or reseller: up to 150,000 euros per year and per type of product that fails to comply or that enables double bookkeeping.

These are fixed annual amounts, designed as a deterrent against dual-use software, not a fee per invoice. The practical consequence for you is simple: use a compliant program before your deadline.

8-point checklist (with the 2027 calendar)

1. Identify your real deadline: January 1, 2027 if you pay Corporate Income Tax; July 1, 2027 if you are self-employed or another IRPF taxpayer.
2. Ask your software provider: will your program comply with the regulation and carry the responsible declaration? Request a date in writing.
3. Choose your mode: Verifactu (automatic sending, less retention) or No Verifactu (no sending, more retention). For most SMBs, Verifactu mode makes life simpler.
4. If your software has no plan, look for an alternative early: migrating an invoicing system takes weeks or months between data, training and testing.
5. Review your invoice volume: if you issue a lot, weigh whether an ERP, a cloud solution or delegating to your accounting firm makes more sense.
6. Train your admin team: the change is operational, not just IT.
7. Use 2026 to test: you can adopt Verifactu voluntarily before your deadline and arrive fully prepared.
8. Confirm your case with your tax advisor: exclusions (SII), territory (TicketBAI) and the specifics of your activity.

What to do now, even if the date is 2027

Having room is not the same as doing nothing. The mistake would be to arrive at the end of 2026 in a rush. Three sensible steps for the coming months:

1. This week: email your software provider and ask about their Verifactu plan and their responsible declaration.
2. This month: confirm your 2027 deadline and whether any exclusion applies to you (SII, TicketBAI).
3. During 2026: if your software will not comply, pick an alternative and test it calmly. Voluntary adoption is available.

Conclusion

Verifactu is real and it will apply to you, but not in 2026 and not with per-invoice fines. It is regulation with a clear calendar (2027) and a concrete goal: that your invoicing is unalterable. Once you cut through the noise, the real work is manageable: confirm that your software will comply and choose your mode. SMBs that use 2026 to prepare the transition will get there without surprises.

At COBIZ we help SMBs put this kind of regulatory change in order: reviewing your current system, choosing the right software, and planning the transition without surprises. If you want an initial review of your situation, get in touch.

Last updated: June 2026. This guide is informational and does not constitute tax advice. Verifactu dates and requirements may change; always confirm your specific case with your advisor and on the Spanish tax authority website.