Verifactu and e-invoicing in Spain: what changes for freelancers and small businesses

This article is about Spanish tax rules. If you run a business or work as a freelancer (autónomo) in Spain, few regulations have caused as much confusion as Verifactu. Deadlines announced and then postponed, software that claims to be “compliant”, sales emails quoting dates that are no longer in force and, on top of that, a separate but related obligation: mandatory business-to-business e-invoicing under the so-called Crea y Crece law. It's no surprise that many business owners don't know whether this affects them, or when.

In this article I explain, using the official information available at the end of October 2026, what each of these is, where the deadlines stand, what kind of software you need and how it all fits with your CRM or online shop. I'm writing as a developer, whose job is to build and connect the systems that issue invoices, not as a tax adviser.

Verifactu is the popular name for Spain's Regulation on computerised invoicing systems, approved by Royal Decree 1007/2023 of 5 December. It develops an obligation introduced by Law 11/2021 on measures to prevent and combat tax fraud: the software that businesses and professionals use to invoice must ensure that invoicing records cannot be deleted or modified without leaving a trace.

The aim is to put an end to so-called dual-use software, programs that let you issue an invoice and then make it disappear or alter it. To achieve this, the regulation requires invoicing systems to guarantee the integrity, preservation, accessibility, legibility, traceability and unalterability of records. Put simply: every invoice you issue is recorded, chained to the previous one and protected against changes.

It's worth being clear from the start: Verifactu is not the same as e-invoicing. Verifactu governs how the program you invoice with must work and what records it generates for the tax authorities. B2B e-invoicing governs the format and channel through which invoices are sent between businesses. They are two different rules which, as you'll see, the Spanish government intends to bring together.

An invoicing system adapted to the regulation generates an invoicing record with the key details every time you issue or cancel an invoice. That record is chained to the previous one by means of a digital fingerprint (a hash), so any later alteration would break the chain and be detectable. Invoices also carry a QR code that lets the customer check the invoice against the Tax Agency's records.

The regulation allows two ways of complying:

• Verifactu mode (VERI*FACTU, in the official terminology): the software automatically sends each invoicing record to the Tax Agency as soon as it is generated. Because records are sent in real time, some technical requirements are simplified compared with the other mode.
• Mode without automatic submission: the software stores records with an electronic signature, chaining and an event log, and must make them available to the Tax Agency whenever it requests them.

In addition, the software producer must issue a responsible declaration (declaración responsable) stating that its software complies with the regulation. When you choose or review your invoicing software, that declaration is the first thing to ask for. And watch out for penalties: article 201 bis of Spain's General Tax Law classifies possessing invoicing systems that don't meet the requirements as a serious offence, with a fixed fine of 50,000 euros per financial year, as the Tax Agency itself explains in its FAQs.

According to the Tax Agency's FAQs, the regulation applies to businesses and professionals whose tax residence is in Spain's common tax territory (including the Canary Islands, Ceuta and Melilla) and who use a computer system to invoice. There are important exceptions:

• Those who keep their VAT books through the Immediate Supply of Information system (SII) are excluded: the two systems are mutually exclusive.
• Those taxed under the regional (foral) rules of the Basque Country or Navarre follow their own systems (in the Basque territories, TicketBAI).
• Anyone who invoices by hand, with a receipt book or on a typewriter, without any software, is not affected by this regulation.

If you're unsure about your specific situation, the Tax Agency has an information assistant on its website, and your adviser will be able to confirm it.

This is where most of the confusion lies, because the timetable has moved several times. The 2025 and 2026 dates you'll see in many older articles are no longer in force. This is the situation as of the date this article was published:

1. 1Dates in force under published law. Royal Decree-Law 15/2025 of 2 December set the deadline for having systems adapted at 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else, including freelancers. These are the dates given in the Tax Agency's information note on the extended deadline.
2. 2Postponement announced, pending approval. On 5 October 2026, Spain's Ministry of Finance published an information note stating its plan to postpone the regulation's pending obligations until October 2028, to align them with mandatory e-invoicing for businesses with annual turnover of up to 8 million euros. The note itself presents this as a planned amendment, and until the corresponding rule is published in the BOE, the legal deadlines remain those of 2027.

The same Ministry note says that, once the timetables are aligned, a further amendment will bring the two sets of rules together, and that the regulation's requirements on integrity, preservation, traceability and unalterability will remain substantially equivalent. In other words: what changes is the when, not the what.

This is one of the most frequent questions, and the answer has nuances. According to the Tax Agency, if you use a spreadsheet or word processor only to type in the invoice details, issue it, print it and keep it, the regulation doesn't affect you. But if that tool processes the data to generate VAT or income tax record books, accounts or other results with tax effects, it is considered an invoicing system and would have to meet all the requirements. The Tax Agency's own example: a simple list of invoices with totals is not affected; a macro that generates the book of issued invoices is.

In practice, a spreadsheet cannot meet the regulation's technical requirements (chaining, event log, unalterability), so if your Excel file does more than act as a template, it's time to change tools. There's a second reason to rethink it: once mandatory B2B e-invoicing arrives, a PDF made in Word won't count as an electronic invoice under that rule, which requires structured formats. For those who invoice very little, the Tax Agency offers a free basic invoicing application, provided its features match what you need.

The second piece is mandatory e-invoicing between businesses and professionals, provided for in Law 18/2022 on business creation and growth, known as the Crea y Crece law. It was pending implementation for years, but 2026 has brought the decisive steps:

• Royal Decree 238/2026 of 25 March, published in the BOE on 31 March 2026, sets out the mandatory e-invoicing system between businesses and professionals.
• Order HAC/1028/2026 of 2 October, published in the BOE on 5 October 2026, regulates the Public E-Invoicing Solution and, with its entry into force on 6 October 2026, starts the countdown for the deadlines.

According to the timetable published by the Tax Agency in its news item on the Public E-Invoicing Solution, the dates are:

• 6 October 2027: businesses and professionals with a turnover above 8 million euros must issue, send and receive e-invoices, and report the status of invoices and payments.
• 6 October 2028: all other businesses and professionals must issue, send and receive e-invoices. Legal entities with up to 8 million must also report the status of invoices and payments.
• 6 October 2029: individuals and entities under the income attribution regime must report the status of invoices and payments.

E-invoices can be sent through the Tax Agency's public solution or through private platforms, which in turn must send a copy to the public solution. And, as mentioned, an electronic invoice in this context is not a PDF sent by email, but a file in a structured format that software can read and process automatically.

Even though the dates have moved, there are tasks that don't depend on the timetable and that you'd do well to tackle as soon as possible:

1. 1Take stock of where you issue invoices. Invoicing software, ERP, online shop, CRM, Excel templates. Many small businesses discover they invoice from two or three different places.
2. 2Ask your provider for the responsible declaration and for their roadmap for Verifactu and B2B e-invoicing.
3. 3Review your customer data. Correct tax IDs, company names and addresses: with chained records and structured e-invoices, mistakes are harder to fix.
4. 4Centralise. Ideally, all invoices should come out of a single compliant system, with your other tools connected to it.
5. 5Talk to your adviser about your specific case, especially if you're close to the 8 million turnover threshold or unsure whether the SII applies to you.

This is where my work comes in. If your online shop generates invoices through a plugin, or your CRM issues invoices on its own, that program is an invoicing system and must comply with the regulation. You have two options:

• Make sure the tool is compliant: check that the plugin or invoicing module has its producer's responsible declaration and is kept up to date.
• Have the tool delegate instead of invoicing: the shop or CRM sends the order data via API to compliant invoicing software, which issues the invoice and generates the records. For most small businesses this is the cleanest option, because the regulatory side stays with specialised software and your website or CRM simply feeds it.

This second approach is a typical automation integration: every sale in your online shop reaches the invoicing software on its own, the invoice goes back to the customer and the payment status shows up in the CRM. If you work with a custom CRM, the usual approach is to design it to connect to verifiable invoicing software rather than reinventing that part, so you get the best of both worlds: a CRM built around you and invoicing that complies with the rules.

Verifactu and B2B e-invoicing will change the way almost every small business and freelancer in Spain's common tax territory invoices, even though the deadlines have moved. As of today, the legal Verifactu deadlines are still those of 2027, with a postponement to October 2028 announced but not approved; and B2B e-invoicing now has a firm timetable, starting in October 2027 for large companies and October 2028 for everyone else. The sensible move is to use the time to centralise invoicing in compliant software and connect your website and CRM to it, always working with your tax adviser.

I'm Elmar Mamedova, a full stack developer based in Málaga. I'm not a tax adviser, but I do build and connect the systems my clients' invoices pass through: online shops, custom CRMs and integrations with invoicing software. If you want to reach Verifactu and e-invoicing with your website and tools properly connected, let's talk and plan it together with your accountant.