Does my billing software need to be Verifactu-compliant?
If your billing software was certified by its vendor after 29 July 2025, it is almost certainly Verifactu-compliant. If it was not, you may be using non-compliant software and face a €50,000 fine per fiscal year when enforcement starts: January 2027 for SLs and July 2027 for autónomos. This guide shows you how to check your current software, what compliance actually requires, and what to do if yours does not qualify.
TL;DR: does my software comply?
Software vendors had until 29 July 2025 to release a Verifactu-certified version
If your provider has not updated the software since then, it does not comply
The key document to ask for: the vendor's declaración responsable filed with AEAT
Non-compliant software after your deadline triggers a fixed €50,000 fine per fiscal year
SL deadline: 1 January 2027. Autónomo deadline: 1 July 2027
01. What Verifactu-compliant software actually means
Verifactu is Spain's mandatory invoicing verification system. From your compliance deadline, every invoice you issue must be generated by a certified invoicing system (SIF, Sistema Informático de Facturación). The software must:
Create a tamper-proof hash chain linking each invoice to the previous one
Generate a QR code on every invoice that AEAT can scan and verify
Send invoice records to AEAT in real time (VERIFACTU mode) or store them with a digital signature for inspection (no-VERIFACTU mode)
Log every action: creation, modification, cancellation, with timestamps
Include the vendor's declaración responsable, a formal declaration filed with AEAT confirming the software meets all technical requirements
Non-compliant software is not just a paperwork problem. Using it after your deadline is a direct infraction of the Ley Antifraude, regardless of whether you issued incorrect invoices or not. The fine is fixed at €50,000 per fiscal year. Full context on the regulation: Verifactu Spain: dates, QR code and what changes.
02. How to check if your software complies
Three checks, in order:
Ask your vendor directly. Email or call and ask: "Has your software been certified as a SIF under Real Decreto 1007/2023? Can you send me the declaración responsable?" A compliant vendor will answer immediately. If they hesitate or don't know what you're referring to, that's your answer.
Check the AEAT registry. AEAT publishes a list of software that vendors have declared compliant. Search for your provider at the AEAT Sede Electrónica under "Sistemas informáticos de facturación."
Look at your invoices. If your software is already generating invoices with a QR code and a hash code (código de verificación), it is operating in compliant mode. If your invoices look the same as they did two years ago, it is not.
03. Software that does NOT need to comply
Not every business is in scope. Your software does not need to be Verifactu-compliant if:
You are already in the SII (Suministro Inmediato de Información) system, which applies to businesses with turnover above €6 million. SII replaces Verifactu for these companies.
You only issue invoices covered by special regimes explicitly excluded from Verifactu scope (check your gestor for your specific activity code).
You are a non-resident entity with no permanent establishment in Spain.
If none of these apply to you, your software needs to comply by your deadline.
04. Common situations where software does NOT comply
Excel or Word invoices. Spreadsheets and word processors are not SIFs. They have no hash chain, no QR generation, no AEAT connection. Using them after your deadline is non-compliant from day one.
Old desktop software not updated since 2024. Many legacy accounting programs have not been updated for Verifactu. If your provider has not communicated a certified update, assume it does not comply.
Free online invoice generators. Generic PDF invoice tools with no Spanish tax compliance layer are not SIFs. The invoice looks correct but the software is not certified.
Your bank's built-in invoicing tool. Some banks offer basic invoicing in their business apps. These are rarely certified as SIFs. Check explicitly with your bank.
Custom-built internal software. If your company built its own invoicing system, it needs to be certified independently. This requires filing your own declaración responsable with AEAT.
05. What to do if your software does not comply
Switch before your deadline, not on it. Migration takes time: exporting data, setting up the new system, testing invoice numbering continuity, training whoever issues invoices.
Ask your current vendor first. Many providers are releasing compliant updates. You may not need to switch platforms at all.
Check whether your gestoría has a recommended tool. Most gestorías work with one or two platforms they know are compliant and can integrate with your filings.
If you need a free option: AEAT offers a free basic invoicing tool for autónomos and small businesses that is Verifactu-compliant. It covers simple invoicing needs. Details: Verifactu free: how to comply at zero cost.
Do not wait until January or July 2027. Switching invoicing software mid-fiscal year creates numbering and continuity issues. Switch in Q4 2026 at the latest.
06. What the QR code on your invoice proves
A key sign that your software is compliant is the presence of a Verifactu QR code on every invoice. When scanned, the QR takes the recipient to AEAT's verification portal, where they can confirm the invoice was registered. This is the visible proof of compliance for your clients.
If your invoices already carry this QR, your software is operating correctly. If they do not, and your deadline has passed, you are non-compliant. Full explanation of how the QR works: Verifactu QR code: what it is and how it works.
Does my billing software need to be Verifactu-compliant: frequently asked questions
What is a declaración responsable in the context of Verifactu?
It is a formal declaration that the software vendor files with AEAT confirming their product meets all Verifactu technical requirements under Real Decreto 1007/2023. It is the vendor's legal commitment that the software is a certified SIF. Ask your provider for a copy.
Can I keep using Excel to issue invoices after 2027?
No. Excel is not a certified SIF. From your compliance deadline (January 2027 for SLs, July 2027 for autónomos), all invoices must be generated by certified software. Using Excel after that date is a direct infraction with a €50,000 fine per fiscal year.
What happens if my software vendor goes out of business before 2027?
You are responsible for compliance, not your vendor. If your provider shuts down, you need to migrate to a certified alternative before your deadline. Do not wait for a vendor crisis to force the switch.
Is cloud-based invoicing software automatically Verifactu-compliant?
No. Being cloud-based is not the same as being Verifactu-certified. Ask your provider explicitly for the declaración responsable. Many cloud tools used by Spanish freelancers have not yet been updated.
My software already adds a QR code to invoices. Does that mean it complies?
Probably yes, but verify. Some tools generate QR codes that link to their own portal, not AEAT's. A Verifactu-compliant QR must link to AEAT's verification page. Ask your vendor to confirm.
If I am in SII, do I also need Verifactu-compliant software?
No. Businesses already enrolled in SII (turnover above €6 million) are excluded from Verifactu. SII is a parallel system that satisfies the same regulatory objective.
