VERIFACTU: New invoicing obligations in 2027

VERIFACTU: New invoicing obligations in 2027

The VERIFACTU system will be mandatory from 1 January 2027 for companies and from 1 July 2027 for other taxpayers. Companies must check that their invoicing software meets the new integrity, traceability and preservation requirements required by the Tax Agency.

Reminder of obligations regarding invoicing software (“VERIFACTU”) pursuant to Royal Decree 1007/2023 and the Ministerial Order published on 10/28/2024.

The implementation of the Regulation on Requirements for Invoicing Software Systems (“VERIFACTU”) was moved to 2027, with the aim of facilitating a more gradual adaptation by companies, professionals and software developers.

Effective dates

• January 1, 2027 → Mandatory application for corporations.
• July 1, 2027 → Mandatory application for all other taxpayers (self-employed and non-residents).

1. Who is required to comply with the regulation?

The Regulation on the Requirements for Invoicing Software Systems (RRSIF), approved by Royal Decree 1007/2023, establishes compliance obligations for:

Business owners and professionals, both individuals and legal entities, established in Spanish territory, if they issue invoices through an Invoicing Software System (SIF).
Entities required to issue invoices, whether complete or simplified (B2B, B2C, B2G), in accordance with current invoicing regulations, which have not been modified.

Exceptions and exclusions

 The following cases are excluded from the RRSIF’s scope of application:

1. Business owners and professionals who issue invoices exclusively manually, without using any invoicing software.
2. Taxpayers who are subject to the Immediate Supply of Information (SII) for VAT, whether mandatory or voluntary.
3. Taxpayers with tax domicile in the Basque Country or Navarre, who must comply with their specific regional tax regulations.
4. Companies with an active administrative resolution that exempts them from compliance with the RRSIF.

Additionally, the regulation does not apply to documents that are not considered invoices, as per the Invoicing Obligations Regulation (ROF), approved by Royal Decree 1619/2012, such as receipts or transaction confirmations that do not require invoicing.

With the upcoming implementation of electronic invoicing, some currently exempt taxpayers (such as those issuing invoices manually) will have to comply with the new requirements.

Software adaptation:

All invoicing software applications must be updated to comply with regulations and allow operation in either Verifactu or Non-Verifactu mode.

2. What is meant by invoicing software?

An Invoicing Software System (SIF) is a combination of hardware and software designed to issue invoices and must allow:

1. Capturing invoicing data, whether:

• – Entered manually.
• – Imported from other systems.
• – Received through automated processes.

2. Storing invoicing data, ensuring accessibility and traceability.
3. Processing data to generate derived records such as accounting entries, tax reports, or communication with tax authorities.

A text processor or spreadsheet used only to enter and print invoices is not considered an SIF, unless it interacts with other systems to generate structured records.

3. Key differences between Verifactu and Non-Verifactu software

4. Other key aspects

Self-invoicing and SII exemptions:

Companies under the SII will not be required to include self-invoices in Verifactu. However, their suppliers must comply.

Public Verifactu portal:

o The Verifactu public platform is available
o It is not possible to generate simplified invoices via this platform.
o This platform will form the basis for the development of the public e-invoicing platform.

Testing and technical standards:

o The AEAT has set up a test environment for developers.
o The email address verifactu@correo.aeat.espara has been set up for technical enquiries, and an external testing portal is available at https://sede.agenciatributaria.gob.es/Sede/iva/sistemas-informaticos-facturacion-verifactu/informacion-tecnica.html

5. How does Verifactu work?

Invoices are not submitted; only invoicing records are.

Submission frequency:

• Every 60 seconds or upon reaching 1,000 records.
• Deferred submission is not allowed.

Who can submit information?

• The taxpayer.
  • A tax advisor or social collaborator with an electronic signature.
  • The invoicing platform, which authenticates records.

All three actors can also view and download information. For tax advisors, their NIF can be included in the Verifactu submission to grant access.

6. General requirements for Invoicing Software Systems (SIF)

The software must generate invoicing records, which will either be stored and voluntarily sent to AEAT or kept for submission during an inspection.

Integrity and immutability of records

• • Use of hash chaining to prevent modifications.
  • Records cannot be altered without leaving a trace.
  • In Non-Verifactu systems, an electronic signature is required.

Traceability and record chaining

• • Mandatory chronological order.
  • Uninterrupted invoice sequencing.
  • Anomalies must be logged in the event record.

Storage and accessibility of information
• Mandatory retention for the tax prescription period.
• Immediate exportability upon AEAT request.

Format and coding: Records must comply with a specific XML format, ensuring consistency in export and storage.

Content of registration and cancellation records:
• Registration records: They must include data such as the issuer’s tax identification number, invoice number, date of issue and hash of the previous record.
• Cancellation records: These include the same type of information, ensuring that any cancelled record is correctly referenced.

Hash and electronic signature: Specifies how the hash and electronic signature are generated using security standards. The hash is calculated using an algorithm and stored with each record to ensure integrity.

QR code on al l invoices
• Mandatory on all the invoices, regardless of the system used.

QR location:
• Electronic invoices: In a specific field of the XML file.
• Paper or PDF invoices: In a visible area of the document.

The QR will contain:

• URL for verification at the AEAT electronic office.
• Issuer’s tax ID.
• Invoice number and series.
• Date of issue.
• Total amount.

7. Responsible declaration requirement

Declaration content:

• Each invoicing system must include a responsible declaration certifying compliance with regulations.
• It must detail: system name and version, components, developer entity, compliance with Article 29.2.j of Law 58/2003, etc.

Availability:

The declaration must be accessible to the system user, distributor, and clients in either paper or digital format.

Expansions:

If the system is expanded with additional components, each new developer must issue a responsible declaration confirming compliance.

AEAT will develop templates for responsible declarations for software manufacturers and developers.

8. Next steps and recommendations

✔ Check with your software provider to confirm compliance with regulations.

✔ Consider activating Verifactu to simplify regulatory compliance.

✔ Consult us if you have doubts or if your provider confirms they will not update their software.

We at Bové Montero y Asociados remain at your complete disposal for any questions or concerns you may have in relation to this or any other matter.